Matt Bisanz interviews Ross Delston, a financial crime compliance expert and former FDIC attorney. They discuss his views on the trends we should expect to see in financial crimefighting and AML compliance over the next few...more
On March 25, 2025, the Securities and Exchange Commission (“SEC”) held a Crypto Task Force roundtable to explore regulatory considerations surrounding custody of crypto assets through broker-dealers and other financial...more
Many US and other non-EU financial institutions which lend or undertake trade finance business on a cross border basis into Europe do so in reliance upon exemptions under local law. These exemptions typically permit these...more
On March 28, 2025, the Internal Revenue Service (“IRS”)’s criminal investigative arm, IRS Criminal Investigation (“IRS-CI”), announced that it would be implementing a new program called CI-FIRST (Feedback in Response to...more
On March 28, 2025, the Federal Deposit Insurance Corporation (FDIC) issued guidance on state nonmember bank and state savings association participation in certain cryptocurrency activities (“FIL-7-2025”). ...more
4/9/2025
/ Banks ,
Cryptocurrency ,
Digital Assets ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Financial Services Industry ,
Investment Products ,
OCC ,
Regulatory Reform ,
Regulatory Requirements ,
Stablecoins
On March 13, 2025, the US Senate Banking Committee passed the Guiding and Establishing National Innovation for US Stablecoins Act of 2025 or “GENIUS Act,” out of committee by a vote of 18-6....more
3/20/2025
/ Bankruptcy Code ,
Cryptocurrency ,
Digital Assets ,
Digital Currency ,
Federal Reserve ,
Financial Regulatory Reform ,
FinTech ,
OCC ,
Regulatory Requirements ,
Stablecoins ,
U.S. Treasury
On March 7, 2025, the Office of the Comptroller of the Currency (OCC) issued guidance on national bank and federal savings association participation in certain cryptocurrency activities (“IL 1183”). This guidance is the...more
On February 27, 2025, the US Financial Crimes Enforcement Network (FinCEN) announced that it will not issue fines or penalties or take any other enforcement actions against companies that fail to comply with the March 21,...more
AT A GLANCE -
On February 17, 2025, the US District Court for the Eastern District of Texas stayed its January 7 order, enjoining enforcement of the Corporate Transparency Act and suspending the effectiveness of the...more
2/28/2025
/ Beneficial Owner ,
Business Entities ,
Business Ownership ,
Compliance ,
Corporate Governance ,
Corporate Transparency Act ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Regulatory Requirements ,
Reporting Requirements
FinCEN has confirmed that, since December 7, 2024, reporting companies have not been, and will continue to not be, required to file beneficial ownership reports for as long as an injunction of the CTA remains in effect....more
On December 26, 2024, a panel of the US Court of Appeals for the Fifth Circuit vacated an order issued by a different panel just days before that had stayed the nationwide preliminary injunction suspending enforcement of the...more
12/31/2024
/ Beneficial Owner ,
Business Entities ,
Business Ownership ,
Compliance ,
Corporate Transparency Act ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements ,
Stays
On December 23, 2024, the US Court of Appeals for the Fifth Circuit granted an emergency motion by the federal government to stay the nationwide preliminary injunction that had suspended enforcement of the Corporate...more
12/27/2024
/ Beneficial Owner ,
Business Entities ,
Business Ownership ,
Compliance ,
Corporate Transparency Act ,
Deadlines ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements ,
Stays
Join us for a new episode of Financial Services Focus with partners Gina Parlovecchio and Matthew Bisanz, and associate Kelly Truesdale, as they discuss FinCEN’s recent confirmation that reporting companies are not required...more
12/17/2024
/ Beneficial Owner ,
Business Entities ,
Business Ownership ,
Corporate Transparency Act ,
Filing Requirements ,
Financial Services Industry ,
FinCEN ,
Popular ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements
On December 7, 2024, the US Financial Crimes Enforcement Network (FinCEN) confirmed that reporting companies—i.e., companies that would be required to report their beneficial ownership information to FinCEN under the...more
12/11/2024
/ Beneficial Owner ,
Business Entities ,
Business Ownership ,
Compliance ,
Corporate Transparency Act ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements ,
Stays
On December 3, 2024, the US District Court for the Eastern District of Texas entered a preliminary injunction suspending enforcement of the Corporate Transparency Act (CTA) and its implementing regulations nationwide,...more
12/10/2024
/ Beneficial Owner ,
Business Entities ,
Business Ownership ,
Compliance ,
Corporate Transparency Act ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements ,
Stays
On July 8, 2024, the Financial Crimes Enforcement Network (“FinCEN”) issued interpretive guidance explaining that the beneficial ownership information (“BOI”) reporting requirement applies to certain legal entities that have...more
On May 6, 2024, the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), the Federal Housing Finance Agency (FHFA) and National Credit Union Administration (NCUA; collectively the...more
5/14/2024
/ Disclosure Requirements ,
Dodd-Frank ,
FDIC ,
FHFA ,
Financial Institutions ,
Financial Services Industry ,
Incentive Compensation ,
NCUA ,
New Rules ,
OCC ,
Regulatory Requirements
On December 27, 2023, the US federal banking regulators proposed a new set of reporting requirements for bank loans and commitments to private credit lenders and intermediaries....more
1/17/2024
/ Banking Regulators ,
Banks ,
Creditors ,
FFIEC ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
OCC ,
Proposed Rules ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements
On December 27, 2023, the US federal banking regulators proposed reporting requirements for bank loans and commitments to the fund finance sector. This change reflects not only the rapid growth in this sector but also the...more
On December 21, 2023, the Financial Crimes Enforcement Network (“FinCEN”) released a final rule to implement the beneficial ownership information (“BOI”) access requirements of the Corporate Transparency Act (“CTA”) (the...more
12/29/2023
/ Anti-Money Laundering ,
Beneficial Owner ,
Corporate Transparency Act ,
Final Rules ,
Financial Crimes ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Popular ,
Regulatory Requirements ,
Reporting Requirements
On April 14, 2020, the US federal banking regulators held a webinar to provide further guidance on relief from the effect of the current expected credit losses methodology (“CECL”) on regulatory capital....more