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FinCEN Proposes Crypto Reporting and Recordkeeping Requirements

Recently proposed regulations could present significant compliance burdens for the banks and money service businesses that engage in cryptocurrency transactions with unhosted wallets or wallets held in jurisdictions specified...more

Agencies Emphasize Risk-Based Due Diligence Approach for Charities and Nonprofits

The Agencies issued a joint Fact Sheet that lists considerations for a risk-based approach when it comes to charities and nonprofits. While the Fact Sheet purports to not impose additional obligations on banks, it is hard to...more

FinCEN Expands AML, Customer Identification Programs, and Beneficial Ownership Requirements to Banks Lacking a Federal Functional...

The Financial Crimes Enforcement Network (FinCEN) issued a final rule that requires minimum standards for anti-money laundering (AML) programs for banks lacking a federal functional regulator (the Federal Reserve Board, OCC,...more

2019 Year In Review: Select Sec And FINRA Developments And Enforcement Cases

The Morgan Lewis Year in Review highlights key US Securities and Exchange Commission (the SEC or the Commission) and Financial Industry Regulatory Authority (FINRA) enforcement and examination developments, and cases...more

Interagency Statement on Hemp-Related Business: No Comfort for Cannabis

The Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, and the US Department of the Treasury’s Financial Crimes Enforcement Network, in...more

Banking Regulators Release Statement on their BSA/AML Supervision Approach

A working group composed of the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, the Office of the Comptroller of the Currency, and the US...more

FinCEN Issues Guidance on Cryptos

The Financial Crimes Enforcement Network (FinCEN) recently issued guidance consolidating current FinCEN regulations, rulings, and guidance about cryptocurrencies and money services businesses (MSBs) under the Bank Secrecy Act...more

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