On April 28, the SEC settled with a cryptocurrency ATM operator for allegedly selling unregistered tokens in order to raise money to expand its bitcoin ATM network. Described as a “token sale,” the SEC claimed the respondents...more
In December, the U.S. District Court for the District of New Jersey granted preliminary approval of a $11.9 million settlement in a class action suit resolving allegations pertaining to a defendant national bank’s...more
In September 2022, the Consumer Financial Protection Bureau (CFPB) entered into a consent order against a large national bank for charging unfair and abusive overdraft fees. In support of its action, the Bureau noted that...more
In April, we continued to see a steady pace in the seriousness and frequency of crypto enforcement actions by state and federal law enforcement. (See our March 2022 Crypto Enforcement Actions Roundup blog here where we...more
Sports Teams and Messaging Apps Go All-In on NFTs, Potential Hack Foiled - A major U.S. football team has reportedly inked a lucrative sponsorship deal with a popular digital asset platform. According to reports, the...more
This survey summarizes several recent developments affecting bank deposits and payment systems. The U.S. department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued new guidance concerning the customer...more
The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued guidance on May 9, 2019, underscoring the application of the Bank Secrecy Act (BSA) and its implementing regulations relating to money...more
Overdraft services practices were the basis for a $10 million fine from the Bureau of Consumer Financial Protection (CFPB) in a recent action against a national bank operating primarily in the northeast....more
The Consumer Financial Protection Bureau (CFPB) had another busy week. Here is an overview of what the CFPB was up to recently: Enforcement Actions and Litigation - Enforcement Action Against Santander Bank - ...more
The Fifth Circuit decided a significant case on loss causation. The Court concluded that the truth could emerge from a series of disclosures which, in and of themselves were not sufficient to uncover the fraud, but which when...more
Ponzi and investment scheme cases are a staple of SEC enforcement in the post Madoff world. Emerging, however, may be a new trend based on a subset of these frauds – investments in ATM machines. At the close of last month the...more