The series of antitrust class action lawsuits first brought by U.S. merchants against Visa and Mastercard in 2006 continued its winding path toward closure as the parties announced in March 2024 that they had reached a...more
Implementation of the Corporate Transparency Act (CTA)[1] is gathering momentum. Most notably, as of the new year the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) is accepting reports of...more
The U.S. Department of Commerce's Bureau of Economic Analysis ("BEA") collects data regarding U.S. multinational enterprise investments and prepares official U.S. economic statistics through a series of quarterly, annual, and...more
While ransomware attacks usually grab the headlines, business email compromise (BEC) attacks continue to cause massive financial losses for businesses. The FBI’s Internet Crime Complaint Center (IC3), reported BEC losses in...more
2/27/2023
/ Anti-Money Laundering ,
Banking Sector ,
BSA/AML ,
Business E-Mail Compromise (BEC) ,
Consumer Financial Protection Bureau (CFPB) ,
Corporate Counsel ,
Data Breach ,
Financial Crimes ,
Financial Institutions ,
Money Laundering ,
Popular ,
Uniform Commercial Code (UCC)
The shifts in customer behavior driven by the global COVID pandemic were a boon for digital payments – consumer adoption in the U.S. reached 82% in 2021, up from 78% in 2020 and 72% in 2016. However, the industry "sector"...more
As described in DWT's October 2021 post, the Corporate Transparency Act ("CTA"), enacted as part of the Anti-Money Laundering Act of 2020, establishes beneficial ownership reporting requirements for a broad range of entities...more
With Real-Time Payments from The Clearing House rapidly gaining traction among banks and FedNow set to launch next July, one might believe that adoption of instant payments among network participants and users will be smooth...more
On September 21, 2021, the U.S. Department of the Treasury announced two major actions by the Office of Foreign Asset Control (OFAC) to combat ransomware: the release of OFAC's Updated Advisory on Potential Sanctions Risks...more
The Corporate Transparency Act (CTA), passed over President Trump's veto as part of the National Defense Authorization Act on January 1, 2021, may have a major impact on the manner in which financial institutions comply with...more
Complaints alleging widespread institutional failures in controlling fraudulent payment processing activity; rogue merchants charging consumer accounts thousands of dollars based on dubious or nonexistent authorizations; and...more
The U.S. Bureau of Economic Analysis’ (BEA) comprehensive survey on financial and operating data of U.S. multinational enterprises (BE-10) is due on May 29, 2020, for filers with fewer than 50 reportable foreign affiliates,...more
Lightning never strikes twice, as the saying goes. But as many merchants are finding out these days, misfortune, in fact, strikes in threes. Not only has COVID-19 caused a substantial slowdown in the U.S. economy and...more
There has been an unprecedented wave of consolidation in the U.S. payment processing industry this year, with two major core processors acquiring the two largest merchant acquirers, and two of the largest remaining payment...more
2018 brought with it President Trump’s decision that the United States would withdraw from the Joint Comprehensive Plan of Action (“JCPOA”). That signaled the U.S.’s intention not only to reimpose trade sanctions on Iran but...more
The BE-120 Benchmark Survey of Transactions in Selected Services and Intellectual Property with Foreign Persons is conducted every five years by the Bureau of Economic Analysis of the U.S. Department of Commerce....more
The Department of Commerce’s Bureau of Economic Analysis (BEA) requires each U.S. business enterprise in which a foreign person owned or controlled, directly or indirectly, 10 percent or more of the voting securities in an...more
The Conference of State Bank Supervisors (“CSBS”) has announced a multi-state framework for state regulators to process an application by a person to become a licensed money services business (“MSB”). The announcement forms...more
The Board of Governors of the Federal Reserve System (Federal Reserve) recently exercised its authority to enforce laws prohibiting unfair or deceptive acts or practices committed by a financial institution under the Federal...more
On January 24, 2017, the Office of the Comptroller of the Currency (the “OCC”) issued examination procedures to supplement its 2013 guidance Third-Party Relationships: Risk Management Guidance. The examination procedures...more
On October 13, the DWT Payments team briefed the Consumer Working Group of the Financial Services Roundtable (FSR) on the CFPB’s final prepaid account rule. The presentation focused on the following topics:
- Scope of...more
Please join us for a complimentary seminar focused on the critical legal issues facing nonprofits as they increasingly engage supporters, raise funds, and create change online and through digital technology....more
9/27/2016
/ 501(c)(3) ,
501(c)(4) ,
Continuing Legal Education ,
Crowdfunding ,
Cybersecurity ,
Events ,
Fund-raising ,
Nonprofits ,
Social Media ,
Tax Exempt Entities ,
Technology
The Federal Financial Institutions Examination Council recently issued a new appendix on “Mobile Financial Services” to the Retail Payment Systems booklet of the FFIEC Information Technology Handbook.
The appendix...more
The number of states that do not regulate money transmitters grows ever smaller as New Mexico recently enacted the New Mexico Uniform Money Services Act. Prior to the enactment, New Mexico only regulated issuers and sellers...more
Have you ever been depressed when a Kickstarter project to make potato salad proceeded to rake in more than your annual salary? Felt a sense of despair as an Indiegogo campaign to develop an X-rated card game went on to...more
Update: The Federal Reserve received forty comments in response to its request. A majority of the commenters supported both mandatory participation by RDFIs and the same-day fee payable by ODFIs to RDFIs. Many commenters...more