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Information Sharing Financial Institutions

Goodwin

ESA Publications on Digital Operational Resilience: A Reminder That DORA is Less Than Six Months Away and Will Apply to US and UK...

Goodwin on

The publication by the Joint Committee of the European Supervisory Authorities (ESAs) on (a) 17 July 2024 of the second batch of implementing materials and (b) 26 July 2024 of the sub-contracting of information and...more

K&L Gates LLP

Overview of the CFPB's Proposed Open Banking Rule and Final Industry Standard Setting Rule

K&L Gates LLP on

The financial services and banking industry landscape continues to evolve in the face of new and emerging technologies. This phenomenon is especially prevalent in the sharing of consumer data between financial institutions...more

Ballard Spahr LLP

FinCEN Releases Year-in-Review for FY 2023: SARs, CTRs and Information Sharing

Ballard Spahr LLP on

The Financial Crimes Enforcement Network (“FinCEN”) has issued its Year in Review for FY 2023 (“YIR”). It consists of five pages of infographics. According to FinCEN’s press release...more

BCLP

FinCEN Proposes AML/CFT Rules for Investment Advisers

BCLP on

On February 13, 2024, the U.S. Treasury Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking regarding a new proposed rule that would require certain investment advisers to apply anti-money...more

Holland & Knight LLP

FinCEN Proposal Potentially Impacts Registered Investment, Exempt Reporting Advisers

Holland & Knight LLP on

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

Eversheds Sutherland (US) LLP

Financial institutions on the front lines of combating terrorist financing

Immediately following the October 7 attack by Hamas on Israel, the United States Financial Crimes Enforcement Network (FinCEN) announced the creation of the Counter Terrorist Financing Taskforce— Israel (CTFTI)—a coalition of...more

White & Case LLP

UK Money Laundering: Crossing the Million SAR Threshold

White & Case LLP on

Firms that act as financial gate-keepers have obligations to report suspicions or knowledge of money laundering via Suspicious Activity Reports to the National Crime Agency ("NCA"). SARs have been filed for almost 20 years...more

Robinson+Cole Data Privacy + Security Insider

NYDFS Issues Report on SolarWinds

This week, the New York State Department of Financial Services (NYDFS) issued the Report on the SolarWinds Cyber Espionage Attack and Institutions’ Response....more

ArentFox Schiff

A Step Away From the Cash Carrying Days for Cannabis Businesses

ArentFox Schiff on

Now Financial Businesses can provide their services to licensed cannabis businesses without penalty under California law. As of February 1, 2021, licensed cannabis businesses in California gained another avenue, albeit...more

Cozen O'Connor

California Adopts Emergency Cannabis Regulations

Cozen O'Connor on

California’s Bureau of Cannabis Control has announced that on February 1, 2021, the Office of Administrative Law approved the adoption of emergency regulations implementing processes for cannabis businesses to authorize the...more

K2 Integrity

New U.S. Law’s Impacts on Non-U.S. Financial Institutions

K2 Integrity on

The U.S. Anti-Money Laundering Act of 2020 (AML Act) became law on January 1 when the United States Congress passed the broader National Defense Authorization Act for 2021 over a presidential veto. Although it is a U.S. law,...more

BakerHostetler

The Anti-Money Laundering Act of 2020: What Companies Need to Know

BakerHostetler on

On January 1, 2021, Congress overrode President Trump’s veto of the National Defense Authorization Act for Fiscal Year 2021, an omnibus bill that includes the Anti-Money Laundering Act of 2020 (the “AMLA”). The AMLA...more

Sheppard Mullin Richter & Hampton LLP

FinCEN Provides Clarity for Section 314(b) Information Sharing

On December 10, 2020, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a Fact Sheet clarifying the circumstances under which financial institutions can share information under...more

Foodman CPAs & Advisors

While FinCEN lacks Independent Litigating Authority, it is the Regulator for the BSA and is responsible for the administration of...

FinCEN issues implementing regulations that “ensure” compliance with the BSA.  FinCEN delegates its examination authority to federal agencies.  These federal agencies are the “Federal Functional Regulators” who supervise...more

Ballard Spahr LLP

FinCEN Stresses Transparency, BSA Filing Data, and Perils of “Under- Regulating” to Securities Industry

Ballard Spahr LLP on

Last Thursday, FinCEN Deputy Director Jamal El-Hindi appeared at the 20th annual Anti-Money Laundering (AML) and Financial Crimes Conference hosted by the Securities Industry and Financial Markets Association (SIFMA) in New...more

K&L Gates LLP

FinTech Forward: How to Prepare for the California Consumer Privacy Act (CCPA) - Part 2

K&L Gates LLP on

In this miniseries, John ReVeal will discuss key issues and top of mind concerns for businesses under the California Consumer Privacy Act, which will go into effect January 1, 2020. In the second episode, John ReVeal...more

A&O Shearman

Financial Stability Board Publishes Update on Market Fragmentation Work

A&O Shearman on

The Financial Stability Board has published a progress update on its ongoing work to tackle market fragmentation. The update follows the FSB’s June 2019 Report on Market Fragmentation, which explored the link between market...more

Ballard Spahr LLP

FinCEN Deputy Director Stresses Technological Innovation, Virtual Currency Enforcement and the U.S. Culture of Compliance

Ballard Spahr LLP on

Last Wednesday, FinCEN Deputy Director Jamal El-Hindi appeared at the annual conference of the Money Transmitter Regulators Association and delivered prepared remarks. The topics of his address covered three issues of...more

Ballard Spahr LLP

FinCEN Dispenses Law Enforcement Awards Based on BSA Reporting

Ballard Spahr LLP on

Director Blanco Stresses Importance of BSA Filings to Criminal Investigations and Prosecutions - As we have blogged, Kenneth Blanco, the Director of Financial Crimes Enforcement Network (“FinCEN”), has publically and...more

White & Case LLP

AML Information Sharing in a Technology-Enabled and Privacy-Conscious World

White & Case LLP on

Financial firms play an integral role in preventing, identifying, investigating and reporting criminal activity, including terrorist financing, money laundering, and many other finance-related crimes. It is a critical role...more

White & Case LLP

Review of Anti-Money Laundering and Sanctions Policy and Enforcement

White & Case LLP on

TABLE OF CONTENTS: Executive Summary - Developments and Trends in Policy and Enforcement - US Department of the Treasury - The Office of Foreign Assets Control - Treasury's Financial Crimes Enforcement Network -...more

Ballard Spahr LLP

Practical Tips for Ensuring Your AML Program Withstands the Scrutiny of Regulators

Ballard Spahr LLP on

First Post in a Two-Part Series - How do financial institutions get in trouble with their regulators? Recent AML enforcement actions suggest that the following two failures are at the heart of most of these actions: (1)...more

Ballard Spahr LLP

Congress Contemplates Broad AML/BSA Reform

Ballard Spahr LLP on

As we blogged earlier this week, Congress is considering a new draft bill, the Counter Terrorism and Illicit Finance Act (“CTIFA”), in committee in the Senate.  The CTIFA proposes the most substantial overhaul to the Bank...more

Ballard Spahr LLP

Financial Stability Oversight Council identifies cybersecurity as primary area of risk for the banking industry

Ballard Spahr LLP on

On December 14, the Financial Stability Oversight Council (FSOC), which was established by the Dodd-Frank Act to analyze and mitigate potential threats to the financial sector, released its first report under the Trump...more

Ballard Spahr LLP

Information Sharing Exchange Launched by FinCEN to Improve Suspicious Activity Reporting

Ballard Spahr LLP on

FinCEN recently announced the launching of the “FinCEN Exchange” to enhance information sharing with financial institutions. We previously have blogged about the potential benefits of a public-private partnership between law...more

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