Regulated financial services institutions and financial market infrastructure (FMI) providers often rely on third parties who provide significant services to them behind the scenes, including “cloud” services and IT services...more
On November 1, 2023, the New York State Department of Financial Services (“NYDFS”) issued its Second Amendment (the “Amendment”) to its Cybersecurity Requirements for Financial Services Companies adopted in 2017, codified in...more
On August 29, 2023, the U.S. federal banking regulators issued a proposal that would establish a long-term debt (LTD) requirement for large U.S. banking organizations with $100 billion or more in total assets that are not...more
On Friday, April 28, 2023, the Federal Deposit Insurance Corporation (“FDIC”) released a report titled “FDIC’s Supervision of Signature Bank” (the “Report”) providing its assessment of the failure of Signature Bank (“SBNY” or...more
The Federal Reserve released a detailed report on the supervision and regulation of the former Silicon Valley Bank (SVB). The report, released along with a trove of confidential supervisory information pertaining to SVB,...more
The recent closures of Silicon Valley Bank and Signature Bank—the second and third largest bank failures in U.S. history—have raised a myriad of questions amongst borrowers and other counterparties as to the contractual...more
On October 3, 2022, as lawmakers in the United States continue to debate which agencies should regulate crypto-based activities, the Financial Stability Oversight Council (FSOC) released its Report on Digital Asset Financial...more
11/3/2022
/ CFTC ,
Crypto Exchanges ,
Cryptoassets ,
Cryptocurrency ,
Digital Assets ,
Digital Currency ,
FDIC ,
Financial Institutions ,
Financial Markets ,
FSOC ,
Regulatory Oversight ,
Regulatory Oversight Committee ,
Securities and Exchange Commission (SEC)
Today, the Fed announced a new procedural requirement for banks seeking to engage in crypto activities. Going forward, a bank must provide formal notice to its lead supervisory contact at the Fed “prior to engaging in any...more
The Basel Committee on Banking Supervision recently released 18 principles that banks and their supervisors should consider when addressing the financial risks stemming from climate change. In recognition of climate risks...more
Following the recent Russian invasion of Ukraine, many countries, including the United States, the United Kingdom and member states of the European Union, have imposed a coordinated series of sanctions unprecedented in scope...more
3/30/2022
/ Credit Agreements ,
Economic Sanctions ,
EU ,
Financial Conduct Authority (FCA) ,
Financial Institutions ,
Financial Services Industry ,
Lenders ,
Proposed Regulation ,
Russia ,
Sanctions ,
UK ,
Ukraine
On March 9, 2022, President Biden signed an Executive Order on Ensuring Responsible Development of Digital Assets. According to an accompanying fact sheet, it is the “first ever, whole-of-government approach” to regulating...more
On March 1, 2022, the Federal Reserve (the “Fed”) proposed a new framework for evaluating “master account” applications for direct access to the Fed’s payment system. The proposal builds upon the Fed’s original proposal from...more
On November 1, 2021, the President’s Working Group on Financial Markets (“PWG”), joined by the Federal Deposit Insurance Corporation (“FDIC”) and the Office of the Comptroller of the Currency (“OCC”), released a report on...more
The release of the Pandora Papers, a leak of approximately 12 million documents, exposed how foreign leaders and private actors use tax havens to conceal their wealth, with the United States a destination of choice. For...more
10/18/2021
/ Anti-Money Laundering ,
Beneficial Owner ,
Due Diligence ,
Financial Fraud ,
Money Laundering ,
Offshore Funds ,
Pandora Papers ,
Proposed Legislation ,
Regulatory Agenda ,
Regulatory Reform ,
Regulatory Standards ,
Shell Corporations ,
Tax Evasion ,
Tax Haven ,
Trusts ,
White Collar Crimes
The 2020 Election Results and Implications for the Financial Services Industry -
Former Vice President Joseph R. Biden Jr. has won the 2020 presidential election and the Democratic Party will remain in control of the House...more
The Federal Reserve has released FAQs covering its recently revised control regulation, which became effective on September 30, 2020 (the “Control Rule”). For more on the specifics of the Control Rule, please refer to our...more
With fewer than 18 months until the expected cessation of the London Interbank Offered Rate (LIBOR), regulators have developed a keen interest on how financial institutions are preparing to transition from what has been...more
On June 25, 2020, the Federal Reserve, Farm Credit Administration, Federal Deposit Insurance Corporation, Federal Housing Finance Agency and Office of the Comptroller of the Currency (the “Agencies”) finalized amendments to...more
On June 18, 2020, the Securities Exchange Commission’s (SEC) Office of Compliance Inspections and Examinations (OCIE) announced the details of an examination initiative specifically focused on LIBOR preparedness. OCIE has...more
The Federal Reserve Board (the Federal Reserve), the Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance Corporation (FDIC), the Securities and Exchange Commission (SEC) and the Commodity Futures...more
COVID-19 has acted as an accelerator, bringing into play scenarios which were previously only contingencies and making contingencies of (and requiring planning for) situations which were previously barely imaginable. The debt...more
On June 25, 2020, the Federal Reserve Board (the “Fed”) released (i) the results of its supervisory stress tests for 2020; and (ii) aggregate, not bank-specific, results of a special “sensitivity analysis” conducted under a...more