The Military Lending Act (MLA) will apply to credit card accounts starting Tuesday, October 3. The final rule took effect last October but provided a one-year exemption for “credit extended in a credit card account under an...more
Second of a Two-Part Blog: Anti-Money Laundering Programs Coming to the Legal Profession?
Earlier this week, we began our discussion of the proposed Corporate Transparency Act of 2017 (the “Act”), and observed that, if...more
9/22/2017
/ Anti-Money Laundering ,
Banking Sector ,
Beneficial Owner ,
BSA/AML ,
Financial Institutions ,
FinCEN ,
Money Laundering ,
Proposed Legislation ,
Regulatory Standards ,
Reporting Requirements ,
Suspicious Activity Reports (SARs)
In late June, Representatives Carolyn Maloney and Peter King of New York introduced The Corporate Transparency Act of 2017 (the “Act”). In August, Senators Ron Wyden and Marco Rubio introduced companion legislation in the...more
On July 20, the Trump Administration posted its first Unified Agenda of Regulatory and Deregulatory Actions. For the first time, the Agenda included a list of “inactive” actions to notify the public of regulations “still...more
8/3/2017
/ Americans with Disabilities Act (ADA) ,
Department of Justice (DOJ) ,
Deregulation ,
Disability Discrimination ,
Public Accommodation ,
Regulatory Standards ,
Title III ,
Trump Administration ,
Web Content Accessibility Guidelines (WCAG) ,
Website Accessibility ,
Website Owner Liability ,
Websites
On July 26, FinCEN, in coordination with the U.S. Attorney’s Office for the Northern District of California (“NDCA USAO”), assessed a $110,003,314 civil money penalty against BTC-e a/k/a Canton Business Corporation (“BTC-e”)...more
7/31/2017
/ Bank Secrecy Act ,
Banking Sector ,
BSA/AML ,
Civil Monetary Penalty ,
Criminal Investigations ,
Enforcement Actions ,
Financial Services Industry ,
FinCEN ,
Indictments ,
Money Laundering ,
Money Services Business ,
Mt.Gox ,
Popular ,
Virtual Currency
We previously reported that the Connecticut Attorney General, on behalf of himself and the Attorneys General of Indiana, Kansas and Vermont (the “state AGs”), had filed a joint motion to intervene in a CFPB enforcement action...more
On May 23, the federal court of appeals for the District of Columbia Circuit rejected an appeal by the majority shareholders in Banca Privada d’Andorra S.A. (“BPA”) regarding claims that FinCEN violated the Administrative...more
The CFPB’s Office of Servicemember Affairs (OSA) has issued its fifth annual report to Congress addressing issues raised and complaints submitted by servicemembers, veterans, and their families....more
5/26/2017
/ Annual Reports ,
Banking Sector ,
Consumer Complaint Database ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Department of Defense (DOD) ,
Interest Rates ,
Military Lending Act ,
Military Service Members ,
SCRA ,
Veterans
We previously reported that the Connecticut Attorney General, on behalf of the Attorneys General of Indiana, Kansas and Vermont, (the “state AGs”) had filed a joint motion to intervene in a CFPB enforcement action against...more
We previously reported that the Connecticut Attorney General, on behalf of the Attorneys General of Indiana, Kansas and Vermont, (the “state AGs”) had filed a joint motion to intervene in a CFPB enforcement action to request...more
In his remarks during last week’s launch of Case Western Reserve School of Law’s Financial Integrity Institute, FDIC Chairman Martin J. Gruenberg spoke on the historical context of today’s BSA/AML regulatory framework and the...more
According to an announcement posted on the Military Lending Act (“MLA”) Website, “[b]etween February 9, 2017 and February 15, 2017 there was a problem with MLA Multiple Record Requests that prevented 149 request files from...more
In part two of our review of the 2016 developments in Anti-Money Laundering (AML), the Bank Secrecy Act (BSA), the criminal money laundering statutes, forfeiture, and related issues, we discuss four additional key...more
2/7/2017
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Banks ,
Bitcoin ,
BSA/AML ,
Civil Forfeiture ,
Currency Transaction Reports (CTR) ,
Digital Currency ,
Financial Institutions ,
Forfeiture ,
Money Laundering ,
Virtual Currency
2016 was a busy year for developments in Anti-Money Laundering (AML), the Bank Secrecy Act (BSA), the criminal money laundering statutes, forfeiture, and related issues. In part one of our year-in-review, we discuss six key...more
2/3/2017
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Banks ,
BSA/AML ,
Casinos ,
Consumer Lenders ,
Customer Due Diligence (CDD) ,
FATF ,
Financial Institutions ,
FinCEN ,
Fines ,
Gambling ,
Gaming ,
Geographic Targeting Order ,
Money Laundering ,
Mortgage Lenders ,
Mortgages ,
NYDFS ,
Offshore Funds ,
Panama Papers ,
Popular ,
Real Estate Market ,
Suspicious Activity Reports (SARs) ,
Tax Evasion
On November 18, the GAO released a report examining issues related to implementation of the Servicemembers Civil Relief Act (SCRA) interest rate cap for student loans. The Senate Committee on Homeland Security and...more
This week, the FTC announced the launch of a redesigned Military Consumer website as part of its joint initiative with the DoD, CFPB and others. Military.Consumer.gov is a financial readiness website designed to help...more
On October 17, the FDIC released revised interagency Military Lending Act (MLA) examination procedures for use in connection with consumer credit transactions occurring on or after October 3, 2016. The revised procedures...more
10/21/2016
/ Banking Sector ,
Consumer Lenders ,
Credit Cards ,
Department of Defense (DOD) ,
FDIC ,
FFIEC ,
Financial Institutions ,
Industry Examinations ,
Military Lending Act ,
Military Service Members ,
Regulatory Standards
On September 30, the CFPB released updated examination procedures for Military Lending Act (MLA) compliance. Compliance with the final rule amending the MLA, issued by the Department of Defense (DoD) in July 2015, was...more
In a unanimous opinion in Davis v. City of Philadelphia, the U.S. Court of Appeals for the Third Circuit has held that Servicemembers Civil Relief Act (SCRA) protections do not extend to a servicemember's solely owned...more
Following years of delay, the U.S. Department of Justice (DOJ) is requesting comment on more than 120 questions regarding the proposed web accessibility rule under Title II of the Americans with Disabilities Act (ADA). Though...more
On March 31, 2016, President Obama signed into law the Foreclosure Relief and Extension for Servicemembers Act of 2015, which continues through December 2017 a provision of the Servicemembers Civil Relief Act (SCRA) that...more
The Americans with Disabilities Act (ADA) applies to certain entities providing goods and services to the public. In the context of interactions with the public, mortgage lenders have obligations to ensure that information...more
The U.S. Department of Justice (DOJ) has published its Fall 2015 Statement of Regulatory Priorities and announced that its much-anticipated rulemaking on web accessibility under the Americans with Disabilities Act (ADA) will...more
The CFPB recently released a report regarding the use of Mobile Financial Services by underserved populations, including low-income, unbanked, underbanked, and economically vulnerable consumers. The report does not contain...more