The recent bank regulatory Joint Statement and request for information (RFI) on third-party deposit relationships and bank-fintech partnerships emphasize afresh regulators’ long-standing concern with financial institutions’...more
8/6/2024
/ Banking Regulators ,
Banking Sector ,
Depository Institutions ,
Enforcement Actions ,
Financial Institutions ,
FinTech ,
Joint Policy Statements ,
Request For Information ,
Risk Management ,
Supervision ,
Third-Party Relationships
On June 28, 2024, the US Department of the Treasury’s Financial Crimes Enforcement Network announced long-anticipated proposed rules on anti-money laundering and countering the financing of terrorism program effectiveness;...more
7/25/2024
/ AML/CFT ,
Anti-Money Laundering ,
Anti-Terrorism Financing ,
Compliance ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Financial Regulatory Agencies ,
FinCEN ,
NCUA ,
NPRM ,
OCC ,
Proposed Rules ,
Suspicious Activity Reports (SARs)
On June 6, 2024, the US Department of the Treasury (Treasury) issued a request for information (RFI) on the “uses, opportunities and risks of artificial intelligence (AI) in the financial services sector.” The RFI seeks...more
On February 15, 2024, the U.S. Department of the Treasury’s (Treasury) Financial Crimes Enforcement Network (FinCEN) issued a long-anticipated Notice of Proposed Rulemaking (NPRM) to impose comprehensive anti-money laundering...more
3/22/2024
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Financial Institutions ,
FinCEN ,
Investment Adviser ,
Popular ,
Proposed Regulation ,
Reporting Requirements ,
Securities and Exchange Commission (SEC)
The Financial Crimes Enforcement Network (“FinCEN”) has continued a spate of regulatory activity related to financial crimes compliance matters in the first year of the Biden Administration, recapped in its recent report...more
7/15/2021
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Biden Administration ,
Compliance ,
Cybersecurity ,
Drug Trafficking ,
Enforcement Priorities ,
Financial Crimes ,
Financial Institutions ,
FinCEN ,
Human Trafficking ,
No-Action Letters ,
Nonbank Firms ,
Ransomware ,
Significant Transnational Criminal Organization ,
Terrorism Funding ,
Virtual Currency
On June 3, 2021, President Biden issued a National Security Memorandum establishing the fight against corruption both at home and abroad as a core United States national security interest and directing the development of a...more
6/9/2021
/ Anti-Corruption ,
Anti-Money Laundering ,
Biden Administration ,
Compliance ,
Corporate Governance ,
Cross-Border Transactions ,
Economic Sanctions ,
Financial Institutions ,
Foreign Corporations ,
Government Agencies ,
National Security ,
NDAA ,
Patriot Act ,
Presidential Memorandum ,
Transparency
Anti-money laundering (“AML”) issues have been a focus of regulators and law enforcement for the past decade and will likely continue to be a priority issue area for the Biden Administration. The AML landscape is shifting...more
2/12/2021
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Beneficial Owner ,
BSA/AML ,
Customer Due Diligence (CDD) ,
Financial Institutions ,
FinCEN ,
Money Laundering ,
NDAA ,
Patriot Act ,
Risk Assessment ,
Suspicious Activity Reports (SARs)
Assets Control (OFAC) and Financial Crimes Enforcement Network (FinCEN) each issued advisories addressing the risks associated with facilitating ransomware payments: the Advisory on Potential Sanctions Risks for Facilitating...more
Two recent actions by the Office of the Comptroller of the Currency (OCC) - one enforcement action and one interpretive note - focus attention on the kinds of anti–money laundering (AML) controls needed for banks to custody...more
8/7/2020
/ Anti-Money Laundering ,
BSA/AML ,
Compliance ,
Consent Order ,
Cryptoassets ,
Cryptocurrency ,
Custody ,
Enforcement Actions ,
Financial Institutions ,
FinCEN ,
OCC
In this alert, we summarize recent guidance from federal regulators and self-regulatory organizations - including the Financial Crimes Enforcement Network (FinCEN), the Office of Foreign Assets Control (OFAC), the Office of...more
4/28/2020
/ Anti-Money Laundering ,
Bank Secrecy Act ,
CARES Act ,
Compliance ,
Coronavirus/COVID-19 ,
Financial Crimes ,
Financial Fraud ,
Financial Institutions ,
Financial Regulatory Agencies ,
Financial Stimulus ,
Paycheck Protection Program (PPP)
On August 5, 2019, President Donald Trump signed Executive Order 13884, Executive Order Blocking Property of the Government of Venezuela (EO 13884). EO 13884 is designed to further increase pressure on the Nicolás Maduro...more
8/7/2019
/ Blocked Person ,
Citgo ,
Economic Sanctions ,
Executive Orders ,
Financial Institutions ,
Foreign Policy ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Petroleum ,
Trump Administration ,
U.S. Treasury ,
Venezuela
The myriad—and conflicting—state, federal and international laws governing the burgeoning marijuana industry have created a complicated legal landscape for financial institutions. In the United States, most states have...more
2/8/2019
/ Anti-Money Laundering ,
Canada ,
Cannabidiol (CBD) oil ,
Cole Memorandum ,
Controlled Substances Act ,
Decriminalization of Marijuana ,
Farm Bill ,
Financial Institutions ,
FinCEN ,
Food and Drug Administration (FDA) ,
Hemp ,
Marijuana ,
Marijuana Related Businesses ,
Proceeds of Crime Act 2002 (POCA) ,
Regulatory Agenda ,
Risk Management ,
State and Local Government ,
Suspicious Activity Reports (SARs)