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2022 Anti-Money Laundering and Sanctions Year in Review

In 2022, anti-money laundering ("AML") and sanctions controls were at the center of regulatory and enforcement activities in the United States and abroad. Globally, governments have continued to recognize the impact of AML...more

Temporary Post-Brexit Regime Applies to UK Financial Institutions Operating in Italy

In Short  The Situation: As of the close of the Brexit transition period ending on December 31, 2020 ("Withdrawal Date"), UK banks, UK investment firms, and UK electronic money institutions ("UK Financial Institutions") can...more

Capital Relief for Software Assets: European Commission Amends Own Fund Requirements

The Development: New Regulation (EU) 2020/2176 (the "Regulation") provides regulatory capital relief, allowing certain software assets to be considered when calculating Common Equity Tier 1 ("CET1") capital. It entered into...more

Getting Cautious on Cloud Outsourcing: ESMA Consults on Proposed Guidelines

The Situation: On June 3, 2020, the European Securities Market Authority ("ESMA") published a consultation paper on Outsourcing to Cloud Service Providers ("Proposed Guidelines"), which will apply to any institution under the...more

Leveling the Financial Institutions Playing Field: EBA Publishes Revised Guidelines on Outsourcing Arrangements

The Situation: The European Banking Authority ("EBA") published its Final Report on EBA Draft Guidelines on Outsourcing Arrangements ("Guidelines") on February 25, 2019, which will eventually replace the existing CEBS...more

EU Council Releases Anti-Money Laundering Action Plan

The Situation: In response to recent cases of money laundering in European banks, the European Union has released an action plan to reinforce its recently proposed anti-money laundering ("AML") and Countering Financing of...more

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