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Risk Transfer Market Receives CPO Registration Relief from CFTC

On November 21, 2025, the Structured Finance Association, on behalf of the risk transfer market, received no-action relief on the issue of registration as a commodity pool operator (“CPO”) from the staff of the Division of...more

FinCEN Publishes FAQs to Reduce Certain Compliance Burdens Associated with SAR Filings

On October 9, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”), jointly with the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the...more

End of the Penny: A Nickel for Your Thoughts?

The United States has had a one cent coin since the founding of the nation and on Wednesday, November 12, the last American penny will be minted. Even though the relative value of one cent declined to the point that many...more

SEC Signals Incoming Relief for De Minimis Security-Based Swap Dealers

On October 29, 2025, Paul Atkins, Chairman of the Securities and Exchange Commission (“SEC”), signaled that he will ask SEC staff to evaluate relief for certain firms who engage in a de minimis level of security-based swap...more

Federal Reserve Governor Waller Introduces “Skinny” Master Account Concept and Signals Support for Payments Innovation

On October 21, 2025, Governor Christopher J. Waller of the Board of Governors of the Federal Reserve System (the “Federal Reserve”) delivered opening remarks at the inaugural Payments Innovation Conference (the...more

NFA Streamlines Process for Virtual Currency Activities by CFTC Registrants

On October 17, 2025, the National Futures Association (“NFA”) announced a proposal to repeal requirements that firms that are registered with the Commodity Futures Trading Commission (“CFTC”) must make certain disclosures to...more

Treasury Takes Initial Steps Towards GENIUS Act Rulemaking

In July, Congress passed, and President Donald Trump signed, the Guiding and Establishing National Innovation for U.S. Stablecoins Act (the “GENIUS Act”). The GENIUS Act was a watershed moment in the history of...more

Credibly Challenged Podcast - Interview with Nolan Andelin, Founder of Verita

Matt Bisanz interviews Nolan Andelin, the founder of Verita, on how his technology for tracking wine provenance can be adapted to the financial sector. They discuss what makes this technology work and how it might grow to...more

Financial Crime Compliance Requirements for Stablecoins

The podcast dives into the fast-evolving world of stablecoins, explaining how these dollar-pegged digital assets are transforming payments with speed, transparency, and fractional flexibility. We also delve into the GENIUS...more

US FDIC and OCC Issue Joint Notice of Proposed Rulemaking to Prohibit the Use of Reputation Risk by Regulators

On October 7, 2025, the Federal Deposit Insurance Corporation (“FDIC”) and the Office of the Comptroller of the Currency (“OCC”) (together, the “Agencies”) issued a Notice of Proposed Rulemaking regarding Prohibition on Use...more

SEC Grants No-Action Relief to Registered Investment Advisers and Certain Registered Investment Companies to Treat a State Trust...

On September 30, 2025, the staff of the Division of Investment Management of the U.S. Securities and Exchange Commission granted no-action relief that allows, subject to numerous conditions: (i) investment advisers registered...more

FinCEN Issues Request for Information on AML Compliance Costs: Is the Juice Worth the Squeeze?

On September 30, 2025, the Financial Crimes Enforcement Network (“FinCEN”) issued a request for information (“AML Survey”) on the costs that nonbank financial institutions (“NBFIs”) incur to comply with anti-money laundering...more

Recent Amendments to the Illinois Banking Act

Recently, Illinois amended several provisions of its banking laws (HB3467). These changes were supported by the Illinois banking community and are intended to harmonize Illinois Banking Act and Illinois Savings Bank Act....more

Ongoing Developments Related to FinCEN’s CIBanco Order

EXECUTIVE SUMMARY - On June 25, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued its first orders (“Orders”) pursuant to the 2024 FEND Off Fentanyl Act (21 U.S.C. § 2313a)...more

Credibly Challenged Podcast - Interview with Paul Noring, Managing Director at BRG

Matt Bisanz interviews Paul Noring, the head of BRG’s Financial Institution Advisory practice. Together, Matt and Paul take a deep dive into the challenges of continuously advancing bank fraud, cybersecurity best practices,...more

Illinois Adopts Regulatory Regime for Digital Assets

On August 18, 2025, Illinois enacted Senate Bill 1797, the Digital Assets and Consumer Protection Act (the “Act”), establishing a regulatory framework designed to enhance customer protections for digital asset activities and...more

FATF Revises AML Standards For Certain Funds Transfers

On June 18, 2025, the Financial Action Task Force (“FATF”) revised the Travel Rule requirements for certain funds transfers (the “2025 Revisions”). The 2025 Revisions are intended to adapt anti-money laundering (“AML”)...more

President Trump Signs Debanking Executive Order

On August 7, 2025, President Donald Trump issued an Executive Order entitled “Guaranteeing Fair Banking for All Americans” (the “Order”). The Order announces the Administration’s plan to address the exclusion of certain...more

Everyone’s Human: CFTC Rationalizes Swap Error Reporting

On July 31, 2025, the Commodity Futures Trading Commission (“CFTC”) issued no-action relief for certain swap reporting counterparties that fail to submit a swap data error correction notification (“NAL 25-25”). This relief...more

US FDIC Requests Comment on Industrial Loan Company Framework

On July 15, 2025, the Federal Deposit Insurance Corporation (“FDIC”) requested comment on its framework for reviewing applications for deposit insurance from industrial loan companies and industrial banks (collectively,...more

What the New Remittance Transfer Excise Tax Means for Businesses

OVERVIEW OF THE REMITTANCE TRANSFER EXCISE TAX - Do you effect transfers of funds for US residents to recipients abroad? If so, you should review the provision of the “One Big Beautiful Bill Act” (“OBBBA”) that imposes a...more

Faqs – What US Clients Need to Know About PISCES – a New Secondary Private Stock Market in the UK

WHAT ARE THE KEY DRIVERS FOR REFORM? The UK Treasury ("HMT") noted the following as drivers for reform: A key challenge for private companies is that, at early stages in their growth, there are no standardised ways...more

Federal Reserve Proposes Changes to Rating System for Large Financial Institutions

On July 10, 2025, the Board of Governors of the Federal Reserve System (“Board”) proposed changes to its supervisory rating systems for large financial institutions (“LFIs”) and supervised insurance organizations (the...more

GENIUS Act Signed into Law US Enacts Federal Stablecoin Legislation

Today, President Donald Trump signs into law the Guiding and Establishing National Innovation for US Stablecoins Act of 2025 (the “GENIUS Act”), establishing the first federal regulatory framework for stablecoins in the...more

FAQs – What US Clients Need to Know About PISCES – A New Secondary Private Stock Market in the UK

WHAT ARE THE KEY DRIVERS FOR REFORM? The UK Treasury ("HMT") noted the following as drivers for reform: A key challenge for private companies is that, at early stages in their growth, there are no standardised ways...more

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