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Bank Secrecy Act › Risk Management

The Bank Secrecy Act is a United States federal statute enacted in 1970 to detect and prevent money laundering within financial institutions. The BSA requires financial institutions to keep records and provide... more +
The Bank Secrecy Act is a United States federal statute enacted in 1970 to detect and prevent money laundering within financial institutions. The BSA requires financial institutions to keep records and provide documentation to authorities for single transactions of more than $10,000 and report other suspicious account activity that could signify money laundering or other financial crimes. less -
Perkins Coie

What Is an “Effective AML/CFT Compliance Program”?

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The Financial Crimes Enforcement Network (FinCEN) and the federal banking agencies recently published the long-awaited notice of proposed rulemaking for the anti-money laundering/countering the financing of terrorism...more

Troutman Pepper

Troutman Pepper Weekly Consumer Financial Services Newsletter - August 2024 # 3

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To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more

Latham & Watkins LLP

Agencies Issue Joint Proposal to Amend Bank Secrecy Act Compliance Programs for Banks

Latham & Watkins LLP on

On July 19, 2024, the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), and the National Credit Union Administration...more

Sheppard Mullin Richter & Hampton LLP

Federal Reserve Board Issues Cease and Desist Order Against Banking-As-A-Service Provider

Sheppard Mullin Richter & Hampton LLP on

On June 14, the Federal Reserve Board (Fed) released a cease and desist order against an Arkansas-based banking-as-a-service (BaaS) provider for compliance and risk management failures. As part of the order, the bank is...more

Ballard Spahr LLP

Treasury Issues Request for Information on Use of AI in Financial Services

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The U.S. Department of the Treasury (“Treasury”) has released a Request for Information on the Uses, Opportunities, and Risks of Artificial Intelligence (“AI”) in the Financial Services Sector (“RFI”).  Written comments are...more

White & Case LLP

FinCEN and SEC Move Closer to New AML Requirements for Investment Advisers & ERAs

White & Case LLP on

On May 13, 2024, FinCEN and the SEC jointly proposed a new rule that would require SEC-registered investment advisers and exempt reporting advisers to maintain written customer identification programs (CIPs). The new rule...more

Ballard Spahr LLP

PLI Anti-Money Laundering Conference to Address Key Issues in BSA/AML (UPDATED)

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I am very pleased to co-chair again the Practicing Law Institute’s 2024 Anti-Money Laundering Conference on May 23, 2024, starting at 9 a.m. in New York City (the event also will be virtual).  I am also really fortunate to be...more

Ballard Spahr LLP

Recent FDIC Consent Orders Reflect Ongoing Scrutiny of Bank Relationships with Fintechs

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In February 2024, the Federal Deposit Insurance Corporation (FDIC) entered into consent orders with two banks who partner with fintechs to offer “banking as a service” (BaaS) related to safety and soundness concerns relating...more

Sheppard Mullin Richter & Hampton LLP

South Dakota Lenders on Tight Deadline for BSA/AML Compliance

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On January 12, South Dakota’s Division of Banking issued a mandate setting March 31, 2024 as the deadline for all South Dakota licensed money lenders and non-residential mortgage brokers to comply with their Bank Secrecy...more

Davis Wright Tremaine LLP

FINRA’s 2024 Annual Regulatory Oversight Report: Select Observations

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FINRA recently published its 90-page 2024 Annual Regulatory Oversight Report (Report) providing member firms with insight into six primary topics: Financial Crimes, Crypto Asset Development, Firm Operations, Communications...more

Harris Beach PLLC

[Webinar] Third Party Risk is Your Risk - January 24th, 11:00 am - 12:00 pm EST

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• Highlights of recent joint agency guidance on Third-Party Risk Management (3PRM) • How 3PRM considerations have increased in importance in BSA/AML compliance programs and enforcement actions • Lessons learned from...more

Nutter McClennen & Fish LLP

Nutter Bank Report: December 2023

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A recent OCC report identified key issues facing the federal banking system, including increasing credit risk due to higher interest rates, increasing risk in commercial real estate lending, prolonged inflation, declining...more

K2 Integrity

The Challenge of Transparency in Preventing Financial Crime: Navigating Financial Integrity in a Changing Risk Landscape

K2 Integrity on

The landscape of financial crimes is constantly evolving, and the concept of transparency is being fundamentally challenged. A dynamic, innovative approach is imperative to preserve and shape the future of financial...more

Ballard Spahr LLP

OCC Risk Perspective Report Focuses on Third-Party Relationships with Fintechs

Ballard Spahr LLP on

In its Fall 2023 Semiannual Risk Perspective, published on December 7, the Office of the Comptroller of the Currency (“OCC”) reported on key issues facing the federal banking system. In evaluating the overall soundness of...more

Proskauer Rose LLP

2024 SEC Examination Priorities –Takeaways for Registered Fund and BDC Managers

Proskauer Rose LLP on

On October 16, 2023, the Division of Examinations (the "Division") of the U.S. Securities and Exchange Commission ("SEC") released its 2024 Examination Priorities ("Annual Priorities").[1] Unlike in previous years when the...more

McGlinchey Stafford

Deep Dive into Payments: Q&A on Bank Partnership Considerations

McGlinchey Stafford on

But upon closer consideration, there is an interplay between a bank partner program and the Electronic Fund Transfer Act (EFTA) as implemented by Regulation E, particularly when it comes to timeframes for disputes, liable...more

K2 Integrity

Crypto in a Time of Uncertainty

K2 Integrity on

On 07 June 2023, K2 Integrity hosted a webinar on the state of cryptocurrency and digital assets in a rapidly evolving regulatory landscape. A discussion was held with Bryan Stirewalt, senior managing director at K2...more

Orrick, Herrington & Sutcliffe LLP

FinCEN offers suspicious activity reporting guidance for human smuggling along U.S.- Mexico border

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On January 13, the Financial Crimes Enforcement Network (FinCEN) issued an alert advising financial institutions on how to detect and report suspicious financial activity that may be related to human smuggling along the...more

Troutman Pepper

Evaluating Fraud Under the Bank Secrecy Act - The Crypto Exchange Podcast

Troutman Pepper on

In this episode of The Crypto Exchange, Troutman Pepper attorney Carlin McCrory welcomes Disputes, Compliance and Investigations Managing Director Terri Sands from Stout to discuss the risks and regulatory scrutiny that...more

Ballard Spahr LLP

NYDFS Releases Virtual Currency Guidance for Banking Organizations

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On December 15, 2022, the New York Department of Financial Services (“NYDFS”) published an Industry Letter detailing the Department’s guidance regarding banking organizations that wish to engage in virtual currency-related...more

Proskauer - Blockchain and the Law

Custodia Bank Is, Once Again, Asking for a Federal Reserve Master Account

Proskauer - Blockchain and the Law on

On December 12, 2022, Custodia Bank (“Custodia”) – a state-chartered, digital asset-focused bank based in Wyoming – was denied its motion for a default judgment in its battle with the Federal Reserve Board of Governors (the...more

K2 Integrity

Opportunities, Risks, and Compliance in the Digital Assets Space

K2 Integrity on

On 14 September 2022, K2 Integrity hosted a webinar on considerations in the digital assets space. K2 Integrity Board Member Christopher Brummer and AML/CFT experts Mariano Federici and Alex Levitov discussed the current...more

American Conference Institute (ACI)

[Event] Canadian Forum on Global Economic Sanctions - September 22nd - 23rd, Toronto, ON, Canada

American Conference Institute (ACI) on

The Canadian Institute’s 7th Annual Canadian Forum on Global Economic Sanctions returns to Toronto in-person and via livestream on September 22-23! Join a Canadian and international faculty of government of officials,...more

Venable LLP

Keeping up with Anti-Money Laundering Rules

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In 1970, Congress passed the Currency and Foreign Transactions Reporting Act, commonly known as the “Bank Secrecy Act” (BSA). The BSA is often referred to as an “anti-money laundering” (AML) law or jointly as “BSA/AML.” The...more

K2 Integrity

Mobile Sports Gambling and Sports Betting Risks

K2 Integrity on

Gambling is an industry that, like it or not, is inherently associated with risk. In fact, its very existence is based on participants willing to take chances with (usually) their own hard-earned money. These truths, as well...more

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