On December 3, 2019, in a rare public statement regarding the provision of banking services to cannabis- or hemp-related businesses, the Federal Banking Agencies, including the Board of Governors of the Federal Reserve...more
12/11/2019
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banks ,
Controlled Substances Act ,
Farm Bill ,
Federal Bank Regulatory Agencies ,
Financial Services Industry ,
FinCEN ,
Hemp ,
Hemp Related Businesses ,
Interagency Guidance ,
Joint Statements ,
NCUA ,
Risk Management ,
Suspicious Activity Reports (SARs) ,
USDA
On October 10, 2019, CFTC Chairman Heath Tarbert commented on Ether’s status as a commodity:
“We’ve been very clear on bitcoin: bitcoin is a commodity under the Commodity Exchange Act. We haven’t said anything about Ether –...more
11/12/2019
/ Anti-Manipulation Rule ,
Bitcoin ,
Brokers ,
CFTC ,
Commodity Exchange Act (CEA) ,
Commodity Trading Advisors (CTAs) ,
CPOs ,
Cryptocurrency ,
Digital Assets ,
Ether ,
Exclusive Jurisdiction ,
False Statements ,
Fraud ,
Futures Commission Merchants (FCMs) ,
Market Participants ,
Misappropriation ,
Popular ,
Registration Requirement ,
Spoofing
As part of the continuing dialogue with market participants working toward developing methodologies for establishing possession or control by broker-dealers over their customers' digital asset securities, on July 8, 2019, the...more
7/22/2019
/ Broker-Dealer ,
Custody Rule ,
Customer Protection Rule ,
Customer Service Standard ,
Digital Assets ,
Digital Securities ,
Financial Industry Regulatory Authority (FINRA) ,
Investor Protection ,
Joint Statements ,
Rule 15c3-3 ,
Securities ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
SIPA
With the regulatory agenda for the US operations of foreign banks in a state of flux, Kevin Petrasic, Paul Saltzman, Glen Cuccinello, Will Giles and Alexander Abedine of global law firm White & Case provide a map to help...more
4/2/2019
/ Banking Sector ,
Board of Directors ,
Combined US Operations (CUSO) ,
Corporate Governance ,
FBOs ,
Federal Reserve ,
Financial Regulatory Agencies ,
Foreign Banks ,
FRB ,
Intermediate Holding Company (IHCs) ,
NYDFS ,
OCC ,
Regulatory Agenda