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Due Diligence Financial Institutions

Goodwin

Anti–Money Laundering (AML): Failure by the Client to Update Relevant Personal Information May Lead to the Closure of their...

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On September 9, 2024, a mediator from the French Financial Markets Authority (AMF) issued conclusions regarding the dispute over the closure of a client’s securities account. The account was closed because the client had...more

Ballard Spahr LLP

NYDFS Imposes $35 Million Fine on Nordea Bank for Alleged AML Failures Following Panama Papers Revelations

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On August 27, 2024, the New York State Department of Financial Services (“NYDFS”) announced a consent order involving a $35 million settlement with Nordea Bank Abp (“Nordea”) for alleged significant failures related to...more

Alston & Bird

Structured Finance Spectrum - Summer 2024

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Welcome to the latest edition of the Spectrum, covering hot-topic issues in the structured finance markets in the U.S. and UK. This edition features the new UK securitization regime, eHELOCs, and climate risk disclosures....more

Guidepost Solutions LLC

How the UK High Court Decision on Forced Labor Impacts Your Supply Chain Due Diligence

The recent ruling by the U.K. Court of Appeal declared that the U.K. National Crime Agency’s decision not to investigate the importation of cotton produced through the use of Uyghur forced labor in China was unlawful. This...more

Steptoe & Johnson PLLC

Oklahoma Court Says State Cannot Enforce Anti-ESG Law for Now

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States are taking varied positions on environmental, social, and governance (ESG) policies as a tool for investing and risk management. Many businesses have adopted ESG policies and states’ responses to this practice have...more

Kohn, Kohn & Colapinto LLP

The Double-Edged Impact of AI Compliance Algorithms on Whistleblowing

As the implementation of Artificial Intelligence (AI) compliance and fraud detection algorithms within corporations and financial institutions continues to grow, it is crucial to consider how this technology has a twofold...more

Ballard Spahr LLP

Federal Banking Agencies Issue Guide to Third-Party Risk Management Practices for Community Banks

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On May 3, 2024, the Board of Governors of the Federal Reserve System (the “Federal Reserve”), the Federal Deposit Insurance Corporation (“FDIC”), and the Office of the Comptroller of the Currency (“OCC”) jointly released the...more

StoneTurn

Operationalizing the N.Y. Department of Financial Services Character and Fitness Guidance

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At the start of 2024, the New York State Department of Financial Services (“DFS”) issued an industry letter: Guidance on Assessment of the Character and Fitness of Directors, Senior Officers, and Managers (the “Guidance”),...more

American Conference Institute (ACI)

[Event] European Forum on Global Economic Sanctions - June 5th - 6th, Berlin, Germany

Hosted by the C5 Group Inc., the 2024 European Forum on Global Economic Sanctions will explore the evolution of the global economic sanctions landscape, analyzing everything from the shifting geopolitics around the globe, to...more

Jones Day

Third Time's a Charm: EU Moves to Approve the Sustainability Due Diligence Directive

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The Council of the European Union ("EU") approved the Corporate Sustainability Due Diligence Directive ("CS3D") on March 15, 2024. The CS3D contains due diligence and governance obligations that will have an extensive impact...more

Pillsbury Winthrop Shaw Pittman LLP

FinCEN’s Proposed Rule to Regulate Investment Advisers: The Questions Industry Should Be Following

FinCEN is focused on customer due diligence, and both the 2024 Investment Adviser Risk Assessment and proposed rule indicate that investment advisers will be expected to assess customer identity, business model, and sources...more

Snell & Wilmer

United States Announces Largest Round of Sanctions Since the Start of Russia’s War in Ukraine

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The U.S. Government recently announced the largest round of sanctions against the Russian Federation (Russia) since the invasion of Ukraine two years ago. This multi-agency effort enacted over 500 sanctions against foreign...more

Latham & Watkins LLP

Hong Kong Monetary Authority Issues Guidance for Banks on Crypto Custody and Sale of Tokenised Products

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Regulator sets out its expectations for banks looking to provide digital asset custody services, and sell and distribute tokenised products. On 20 February 2024, the Hong Kong Monetary Authority (HKMA) published two...more

Holland & Knight LLP

FinCEN Proposal Potentially Impacts Registered Investment, Exempt Reporting Advisers

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The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) has issued a new notice of proposed rulemaking (NPRM), referred to herein as the "Proposed Rule," that would subject SEC-registered...more

Akin Gump Strauss Hauer & Feld LLP

FinCEN Proposes New Rule to Expand Anti-Money Laundering Requirements for Investment Advisers

Key Points - On February 13, 2024, FinCEN issued an NPRM that seeks to include certain investment advisers in the definition of “financial institution” under the BSA. As described in the NPRM as well as in FinCEN’s fact...more

Carlton Fields

Impact Investing: Keys to a Responsible Exit

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Impact investing has been gaining new prominence recently to respond to the environmental and social challenges that the traditional frameworks of philanthropy alone could not address. Impact investors generally seek to...more

Conyers

Cayman Islands Removal from the EU Anti-Money Laundering List

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The Cayman Islands is now set to be removed from the EU anti-money laundering (AML) list. This action follows the decision of the Financial Action Task Force (FATF) monitoring group on 27 October 2023 and subsequent removal...more

Ballard Spahr LLP

Criminal Case Round-Up: Recent Prosecutions Involving Financial Institution Officers

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The Department of Justice (“DOJ”) has been very active in the Bank Secrecy Act (“BSA”) / Anti-Money Laundering (“AML”) space, as reflected by a recent series of individual prosecutions and corporate non-prosecution agreements...more

Ballard Spahr LLP

Criminal Case Round-Up: Recent Prosecutions Involving Casinos

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The Department of Justice (“DOJ”) has been very active in the Bank Secrecy Act (“BSA”) / Anti-Money Laundering (“AML”) space, as reflected by a recent series of individual prosecutions and corporate non-prosecution agreements...more

Guidepost Solutions LLC

Will your Due Diligence Program Meet the New DFS Requirement?

The final guidance, issued by DFS on January 22, 2024, requires “regular and rigorous” vetting of key personnel at banking organizations and non-depository institutions. It is clear, that DFS is focused on enhanced scrutiny...more

Seward & Kissel LLP

Credit Union Share Certificates: A Primer

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Over the last several years credit unions have sought to raise funds in the capital markets by issuing their Share Certificates through brokers or other intermediaries. Credit union shares have many of the same attributes of...more

Mitratech Holdings, Inc

Understanding 4th- and Nth-Party Risk: What Do You Need to Know?

Strategies for Mitigating Unseen Threats and Managing 4th- and Nth-Party Risk in Your Modern Business. Organizations today have transitioned from using on-site server rooms to relying on third-party services and cloud...more

Walkers

Removal of the Cayman Islands from the EU AML List and UK AML List

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Following the removal of the Cayman Islands from the Financial Action Task Force's list of "jurisdictions under increased monitoring" in October 2023, on 12 December 2023, the European Commission adopted the Commission...more

Troutman Pepper

Troutman Pepper Weekly Consumer Financial Services Newsletter - January 2024 # 3

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To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more

Jenner & Block

Client Alert: How Regulatory Events of 2023 Should Guide Financial Institutions' New Year's Resolutions for 2024

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As consumer-facing financial institutions of all types—from well-established banks to newly-launched fintechs—set their 2024 regulatory compliance goals, they may wonder if their New Year’s resolutions align with those that...more

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