News & Analysis as of

Office of the Comptroller of the Currency Customer Due Diligence (CDD)

Troutman Pepper

Federal Banking Agencies Reiterate Guidance on Managing Risks Posed By Fintech Partnerships and Other Third Party Relationships

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Last week, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (collectively, the agencies) issued a joint statement highlighting...more

Troutman Pepper

OCC’s Semiannual Report Highlights Emerging Risk of AI in Banking

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On December 7, the Office of the Comptroller of the Currency (OCC) published the fall edition of its Semiannual Risk Perspective, which discusses key issues facing banks. From the OCC’s perspective, the overall strength of...more

Foodman CPAs & Advisors

CDD – Recordatorio Amistoso De Las Agencias A Los Bancos

El 6/7/22, las Agencias (Junta de Gobernadores del Sistema de la Reserva Federal, la Corporación Federal de Seguros de Depósitos, la Red de Ejecución de Delitos Financieros, la Administración Nacional de Cooperativas de...more

Venable LLP

Bank Provider of BaaS Dinged by OCC; Blueprint for Fintech Partnerships?

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​​​​​​​A recent action by the Office of the Comptroller of the Currency (OCC) highlights how banks need to ensure that they have robust compliance programs for managing risks posed by their banking as a service (BaaS)...more

Cadwalader, Wickersham & Taft LLP

Five Federal Agencies Issue Joint Statement on Approach to Customer Due Diligence

On July 6, five federal agencies − the Board of Governors of the Federal Reserve System (“FRB”), Federal Deposit Insurance Corporation (“FDIC”), Financial Crimes Enforcement Network (“FinCEN”), National Credit Union...more

McGuireWoods LLP

Bank Regulators Remind Financial Institutions Not to Take a One-Size Fits All Approach to Assessing AML Risks from Customer...

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The Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Financial Crimes Enforcement Network, the National Credit Union Administration, and the Office of the Comptroller of the...more

Nutter McClennen & Fish LLP

Nutter Bank Report: November 2020

Federal Banking Agencies Issue New Guidance on Managing the LIBOR Transition - The member agencies of the Federal Financial Institutions Examination Council (“FFIEC”) have issued joint guidance for banking organizations...more

Morgan Lewis - All Things FinReg

Agencies Emphasize Risk-Based Due Diligence Approach for Charities and Nonprofits

The Agencies issued a joint Fact Sheet that lists considerations for a risk-based approach when it comes to charities and nonprofits. While the Fact Sheet purports to not impose additional obligations on banks, it is hard to...more

Holland & Knight LLP

Treasury Releases 2020 National Strategy for Combating Terrorist and Other Illicit Financing

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The 2020 National Strategy for Combating Terrorist and Other Illicit Financing was issued earlier this month by the U.S. Department of the Treasury. Prepared in consultation with regulators and law enforcement, including the...more

Ballard Spahr LLP

The OCC Releases Fiscal Year 2020 Bank Supervision Operation Plan

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On October 1st, the Office of the Comptroller of the Currency (OCC) published the Fiscal Year 2020 Bank Supervision Operating Plan (“FY 2020 Plan”). ...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

OCC Semiannual Risk Perspective Highlights Cybersecurity, Fraud, Money Laundering Concerns

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Last week, the Office of the Comptroller of the Currency (“OCC”) published the Spring 2018 Semiannual Risk Perspective (the “Report”), which uses up-to-date data to identify risks to U.S. banks and measure their compliance...more

Ballard Spahr LLP

OCC Report: Same Threats, Different Season

Ballard Spahr LLP on

OCC Identifies AML/BSA and Cyber Threats as Elevated Risks Facing Banks - Last week, the Office of the Comptroller of the Currency (“OCC”) published the Spring 2018 Semiannual Risk Perspective (the “Report”), which uses...more

Akin Gump Strauss Hauer & Feld LLP

FinCEN Enforcement Action Highlights AML Compliance Program Failures and Conflicts of Interest for High-Risk MSB Customers

On February 27, 2017, FinCEN announced a $7 million civil monetary penalty against Merchants for willful violations of the BSA. Additionally, the Office of the Comptroller of the Currency (OCC), Merchants’ federal functional...more

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