News & Analysis as of

Bank Secrecy Act Third-Party Service Provider

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 -
King & Spalding

FinCEN Proposes Rule to Extend Bank Secrecy Act Obligations to Certain Investment Advisers

King & Spalding on

The Proposed Rule Would Subject Certain Investment Advisers to a Broad Range of AML/CFT Obligations and Represents a Significant Development for the Sector - Regulators have long considered the lack of anti-money...more

Ballard Spahr LLP

OCC report identifies use of third-party service providers and consumer compliance as key risks for federal banking system

Ballard Spahr LLP on

Last week, the OCC released its Semiannual Risk Assessment for Fall 2017 highlighting credit, operational, and compliance risks to the federal banking system. ...more

Bryan Cave Leighton Paisner

New Interagency Guidance Clarifies CIP Requirements for Prepaid Cards

On March 21, 2016, FinCEN and the federal bank regulatory agencies published Guidance to issuing banks on the CIP requirements applicable to prepaid cards. While the Guidance referred to “prepaid cards,” footnote 5 to the...more

WilmerHale

OCC Revises CMP Policy

WilmerHale on

For the first time in over twenty years, the Office of the Comptroller of the Currency (OCC) has formally changed its policy governing civil money penalties (CMP) against national banks, federal savings associations, federal...more

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