The SEC, just a few days ago, announced an enforcement action against a trust company for failure to exercise substantial investment authority over their collective trust funds. According to the SEC, because of this failure,...more
The Office of Comptroller of the Currency (the OCC) has published its 2019 annual report (the Annual Report), which summarized the OCC’s strategic priorities for 2019. The Annual Report also highlighted the OCC’s key...more
1/20/2020
/ Annual Reports ,
Anti-Money Laundering ,
Banks ,
BSA/AML ,
Chief Compliance Officers ,
Compliance ,
CSBS ,
Examination Priorities ,
Federal Reserve ,
Financial Institutions ,
FinCEN ,
Interpretive Opinions ,
Joint Statements ,
OCC ,
Risk Assessment ,
Shell Corporations ,
Suspicious Activity Reports (SARs) ,
Technology ,
Terrorism Funding
On April 29, 2019, the Office of the Comptroller of the Currency (OCC) issued an Advance Notice of Proposed Rulemaking (ANPR) to solicit comment on whether it should issue a formal proposal to expand the reach of its...more
5/17/2019
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Banks ,
Custody ,
de facto Administrators ,
Executors ,
Federal Savings Associations ,
Fiduciary ,
OCC ,
Regulatory Agenda ,
Risk Management ,
Trustees
On July 30, 2014, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued proposed rules (the “Proposed Rules”) to clarify and strengthen customer due diligence requirements for banks, securities...more