On July 8, 2022, the European Central Bank ("ECB") released the results from its annual stress tests, this year focused on banks' ability to incorporate climate risk stress testing into their risk management frameworks. The...more
The Situation: On January 4, 2021, the Office of the Comptroller of the Currency ("OCC") issued an Interpretive Letter permitting national banks and federal savings associations ("Banks") to participate in independent node...more
1/19/2021
/ Banking Sector ,
Cryptoassets ,
Cryptocurrency ,
Digital Assets ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Services Industry ,
FinCEN ,
Interpretive Letters ,
OCC ,
Popular ,
Securities and Exchange Commission (SEC) ,
Stablecoins
Regulation (EU) 2019/2033 on the prudential requirements of investment firms and Directive (EU) 2019/2034 on the prudential supervision of investment firms (collectively, "IFR/IFD Framework") significantly change the...more
The United Kingdom and European Union look to give powers to regulators, rather than using direct legislation, to deal with existing contracts that prove unable to convert or be amended to include fallbacks ahead of IBOR...more
The Situation: The European Commission issued an Action Plan on Anti-Money Laundering/Combating the Financing of Terrorism ("AML/CFT") in response to recent money laundering scandals and concerns of an increase in crime due...more
6/19/2020
/ AML/CFT ,
AMLD V ,
Banking Sector ,
Criminal Investigations ,
Cross-Border Transactions ,
EU Action Plans ,
European Banking Authority (EBA) ,
European Commission ,
Financial Intelligence Unit (FIU) ,
International Data Transfers ,
Law Enforcement
The Situation: From both sides of the Atlantic, United States and French financial authorities are keen to facilitate technology innovations in the financial sector. Beyond having set up dedicated teams to focus on the...more
6/15/2020
/ Banking Sector ,
Consumer Financial Products ,
Financial Services Industry ,
FinTech ,
France ,
Innovation ,
Innovative Technology ,
Memorandum of Understanding ,
NYDFS ,
Regulatory Oversight ,
Regulatory Standards
The Situation: The European Banking Authority ("EBA") issued its Action Plan on Sustainable Finance ("Action Plan") on December 6, 2019, setting forth an outline for its deliverables and activities related to environmental,...more
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
The Situation: The European Central Bank ("ECB") has announced that it will set bank-specific supervisory expectations for the provisioning of non-performing loans ("NPLs") in a consistent way across comparable banks, which...more
The Situation: The second EU Payment Services Directive requires banks to give third-party payment service providers ("TPPs") access to the bank accounts of their customers (with their consent), in order to enable TPPs to...more