News & Analysis as of

Bank Secrecy Act Regulatory Standards

The Bank Secrecy Act is a United States federal statute enacted in 1970 to detect and prevent money laundering within financial institutions. The BSA requires financial institutions to keep records and provide... more +
The Bank Secrecy Act is a United States federal statute enacted in 1970 to detect and prevent money laundering within financial institutions. The BSA requires financial institutions to keep records and provide documentation to authorities for single transactions of more than $10,000 and report other suspicious account activity that could signify money laundering or other financial crimes. less -
Orrick, Herrington & Sutcliffe LLP

FinCEN issues final rule replacing obsolete BSA civil penalty regulations

On December 23, the Financial Crimes Enforcement Network (FinCEN) published a final rule amending the Bank Secrecy Act civil penalty regulations concerning requirements for reporting foreign financial accounts and...more

Nutter McClennen & Fish LLP

Bank Report: December 2019

FDIC and OCC Propose CRA Modernization Rule with Opt-Out for Small Banks The FDIC and the OCC have jointly proposed amendments to modernize the agencies’ Community Reinvestment Act (“CRA”) regulations, which are intended...more

Burns & Levinson LLP

When Privacy Does Not Apply, But Tax Does: Cryptocurrency Transactions

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Overview of Federal Regulation - As transactions involving cryptocurrencies, such as Bitcoin, become more prevalent, regulatory oversight has been evolving....more

K2 Integrity

Art and AML: Regulators Taking a Broad Brush Approach Using Financial Entity Regulatory Compliance as the Model for the Art World

K2 Integrity on

What do people see when they look at a piece of fine art—such as a painting by Cezanne, a sculpture by Giacometti, or a three-dimensional combine by Rauschenberg? To a great extent, it depends on who’s doing the looking. An...more

Orrick - On the Chain

FinCEN’s New Guidance for Cryptocurrency Businesses – Some Questions Answered, Some New Questions Raised, Careful Consideration a...

Orrick - On the Chain on

Last month, the Financial Crimes Enforcement Network (FinCEN) released new guidance to clarify when the Bank Secrecy Act (BSA) will apply to businesses that involve cryptocurrencies (what FinCEN refers to as convertible...more

Ballard Spahr LLP

Senate Committee Hears from OCC, FinCEN and FBI on Risks Posed by Anonymous Corporate Structures

Ballard Spahr LLP on

Testimony Supports Bill Requiring States to Collect Beneficial Ownership Information at Entity Formation - As we have blogged, the proposed Corporate Transparency Act of 2019 (the “Act”) seeks to ensure that persons who...more

Wilson Sonsini Goodrich & Rosati

Regulatory Landscape for Fintech, Electronic Commerce, and Electronic Banking: Part One

Part 1: Electronic Commerce - This is the first part of a two-part article discussing the regulatory landscape for financial technology as applied to electronic commerce and electronic banking. This article focuses on...more

Goodwin

FinCEN Director Addresses Bureau’s Approach to Digital Currency and Financial Innovation

Goodwin on

On August 9, 2018, Kenneth A. Blanco, Director of the Financial Crimes Enforcement Network (FinCEN), delivered remarks at the 2018 (Legal) Tech Conference at Chicago-Kent College of Law at Illinois Institute of Technology. ...more

Ballard Spahr LLP

FinCEN Director Addresses Virtual Currency and Touts Regulatory Leadership and Value of SAR Filings

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Address Emphasizes Role of SARs in Fighting Illegal Activity, Including Drug Dealing Fueling the Opioid Crisis - Kenneth Blanco, the Director of the Financial Crimes Enforcement Network (“FinCEN”), discussed last week...more

Ballard Spahr LLP

OCC report identifies use of third-party service providers and consumer compliance as key risks for federal banking system

Ballard Spahr LLP on

Last week, the OCC released its Semiannual Risk Assessment for Fall 2017 highlighting credit, operational, and compliance risks to the federal banking system. ...more

A&O Shearman

Cybersecurity: Recent Developments in the Protection of Financial Data

A&O Shearman on

As cybersecurity remains in the headlines moving into 2017, we consider recent developments in public policy concerning cybersecurity in the financial services industry....more

Proskauer - Corporate Defense and Disputes

FinCEN Proposal Looks to Extend AML Requirements to Non-Federally Regulated Banks

On April 25, 2016, the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Department of the Treasury, proposed a rule that would require all banks, regardless of whether they are subject to regulation by a...more

Holland & Knight LLP

FinCEN Proposal Extends AML Requirements to Banks Without a Federal Functional Regulator - Proposed Rule Would Include Trust...

Holland & Knight LLP on

The Financial Crimes Enforcement Network (FinCEN) on Aug. 25, 2016, issued a notice of proposed rulemaking (Proposed Rule) to implement Section 326 of the Uniting and Strengthening America by Providing Appropriate Tools...more

Morgan Lewis

The Conference of State Bank Supervisors Adopts Model Regulatory Framework for Virtual-Currency Businesses

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Addressing regulatory concerns pertaining to consumer protection, market stability, and law enforcement, the Framework expands on the CSBS draft framework released in December 2014. The Conference of State Bank...more

Ballard Spahr LLP

Investment Management Update - October 2015

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Below is a summary of recent investment management developments that affect registered investment companies, private equity funds, hedge funds, investment advisers, and others in the investment management industry. Schwab...more

Orrick, Herrington & Sutcliffe LLP

Treasury Request for Public Input on Expanding Access to Credit through Online Marketplace Lending

On July 20, the Department of the Treasury published a Notice and Request for Information (“RFI”) seeking comment on various aspects of online marketplace lending, including – - the business models and products offered...more

Davis Wright Tremaine LLP

State Virtual Currency Regulatory Heat Map

As we approach the end of a very active year in the emergence of virtual currency regulation, we developed a heat map of the regulatory climate faced by virtual currency wallet providers and exchanges – entities who maintain...more

Orrick - Finance 20/20

Financial Regulators Release 2014 Bank Secrecy Act/Anti-Money Laundering Examination Manual

Orrick - Finance 20/20 on

On December 2, the Federal Financial Institutions Examination Council (FFIEC) released the revised Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual. The revisions clarify supervisory expectations and...more

Katten Muchin Rosenman LLP

Corporate and Financial Weekly Digest - Volume IX, Issue 47

In this issue: - SEC Sets October 2015 Target Date for Certain Dodd-Frank and JOBS Act Rulemaking - FINRA Issues Notice on TRACE Trade Reporting Obligations - NFA Issues Guidance on Exempt and Excluded...more

Katten Muchin Rosenman LLP

FDIC Announces Availability of Educational Videos

On April 3, the Federal Deposit Insurance Corporation (FDIC) announced the release of the first in a series of technical assistance videos to provide useful information to bank directors, officers and employees on areas of...more

The Volkov Law Group

AML Enforcement – A New Era Of Compliance

The Volkov Law Group on

Last year was the year of Bank Secrecy, sanctions and anti-Money Laundering enforcement. The HSBC settlement sparked significant controversy over the claim by the Justice Department that HSBC and other banks are “too big to...more

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