News & Analysis as of

BSA/AML Banking Sector

Orrick, Herrington & Sutcliffe LLP

Congressional Research Service report highlights de-banking risks

On January 29, the Congressional Research Service (CRS) released a report on the challenges banks may face in providing services to certain individuals and businesses. The CRS’s report was based on the perception that an...more

Orrick, Herrington & Sutcliffe LLP

OCC releases enforcement actions for January 2025

On January 16, the OCC released a list of recent enforcement actions against national banks, federal savings associations, and institution-affiliated parties (IAPs) which include bank directors, officers, employees and...more

Bradley Arant Boult Cummings LLP

$3B TD Bank AML Settlement Is A Wake-Up Call For All Banks

On Oct. 10, Attorney General Merrick Garland announced that TD Bank pled guilty to conspiracy to commit money laundering and agreed to pay over $1.8 billion in penalties to resolve the U.S. Department of Justice's...more

Orrick, Herrington & Sutcliffe LLP

OCC releases enforcement actions for October 2024

On October 17, the OCC released a list of recent enforcement actions taken against banks and individuals affiliated with national banks, federal savings associations and institution-affiliated parties, or IAPs. The OCC issued...more

Orrick, Herrington & Sutcliffe LLP

OCC releases FY 2025 bank supervision operating plan

On October 1, the OCC released its bank supervision operating plan for fiscal year (FY) 2025. The OCC outlined its supervision priorities and objectives which will guide the implementation of supervisory strategies for...more

Goodwin

FinCEN and Banking Agencies Propose AML Program Rule Updates for Banks and Other Financial Institutions

Goodwin on

Earlier this summer, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Proposed Rule revising its regulations under the Bank Secrecy Act (BSA) requiring financial institutions to...more

Orrick, Herrington & Sutcliffe LLP

Fed issues cease and desist against bank

On September 4, the Fed and the Texas Department of Banking published a cease and desist order alleging deficiencies identified in a Texas-based bank’s corporate governance, risk management and compliance with BSA/AML laws....more

Orrick, Herrington & Sutcliffe LLP

OCC announces enforcement actions for August 2024

On August 22, the OCC released a list of recent enforcement actions against national banks, federal savings associations, and individuals affiliated with such entities (defined as institution-affiliated parties, or IAPs). The...more

Troutman Pepper Locke

Navigating Bank-Fintech Partnerships: Avoiding Common Pitfalls — The Consumer Finance Podcast

Troutman Pepper Locke on

In this episode of The Consumer Finance Podcast, Chris Willis discusses the complexities and potential pitfalls of bank-fintech partnerships. Joined by colleagues Alexandra Steinberg Barrage, Matthew Bornfreund, and Jesse...more

Sheppard Mullin Richter & Hampton LLP

South Dakota Lenders on Tight Deadline for BSA/AML Compliance

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

Morrison & Foerster LLP

To Approve a Bank Merger or Not: That Is the Question!

On January 29, 2024, the OCC issued a proposed policy statement[1] describing the general principles it uses to evaluate applications for approval of transactions under the Bank Merger Act (“BMA”), principally bank mergers,...more

Womble Bond Dickinson

Navigating the Labyrinth: Artificial Intelligence in the Battle Against Trade-Based Money Laundering

Womble Bond Dickinson on

In the rapidly evolving financial landscape, governments worldwide are intensifying their focus on compliance in Know Your Customer (KYC) and Anti-Money Laundering (AML) efforts for financial institutions. Trade-Based Money...more

Venable LLP

Chalk Talk: OCC Re-Thinks Business Combinations

Venable LLP on

The OCC recently released a proposed rule and policy statement on business combinations involving national banks and federal savings associations (banks), which includes mergers, acquisitions of assets, and assumptions of...more

Morgan Lewis - All Things FinReg

OCC Proposes Substantive and Procedural Revisions for Bank Mergers

The US Office of the Comptroller of the Currency (OCC) on January 29 proposed meaningful revisions to its rules and processes for reviewing proposed transactions involving national banks under the Bank Merger Act. The...more

Orrick, Herrington & Sutcliffe LLP

NYDFS and Fed order bank to pay fines for BSA/AML non-compliance

On January 19, the Federal Reserve Board and NYDFS each issued separate enforcement actions against one of the largest banks in the world for alleged compliance deficiencies and violations under BSA/AML. The Fed issued its...more

Goodwin

FinCEN Issues Final Rule on Beneficial Ownership Information Access and Safeguards; Bank Regulators Issue Interagency Statement...

Goodwin on

On December 21, 2023, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule (Access Rule) regarding access to the beneficial ownership information (BOI) reported to FinCEN...more

Holland & Knight LLP

[Webinar] Financial Services Regulatory Crystal Ball Outlook for 2024 - January 24th, 12:00 pm - 1:00 pm EST

Holland & Knight LLP on

Please join Holland & Knight's Financial Services Regulatory Team for a roundtable discussion on what to expect on the financial services landscape in 2024. Our attorneys will present on a wide range of topics in a "3-Minute...more

Nutter McClennen & Fish LLP

Nutter Bank Report: December 2023

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

Troutman Pepper Locke

Practical Lessons Learned Regarding the Bank Secrecy Act and Anti-Money Laundering for Financial Institutions - The Consumer...

Troutman Pepper Locke on

Join Troutman Pepper Partner Chris Willis and fellow Partner Matthew Orso as they discuss the Bank Secrecy Act, anti-money laundering, and countering the financing of terrorism rules, as they pertain to financial institutions...more

Venable LLP

All Things Seen and Unseen: Bank Supervision and Enforcement After the Spring 2023 Bank Failures

Venable LLP on

Besides being a shock to the market, the 2023 bank failures caused many to ask whether the federal banking agencies had done enough to prevent them. Precisely what the agencies should have done, or should do moving forward,...more

Orrick, Herrington & Sutcliffe LLP

Fed announces enforcement action against Kansas bank for operational deficiencies

On September 5, the Fed announced a cease and desist order (the “order”) against a Kansas bank holding company and its subsidiary bank (collectively, the “bank”) for having significant operational deficiencies, including...more

Perkins Coie

FFIEC BSA/AML Exam Manual Updates - Implications for Banks

Perkins Coie on

The Federal Financial Institutions Examination Council (FFIEC) released the fifth phase of updates to the FFIEC Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual (the Manual) on August 2, 2023. While the...more

Orrick, Herrington & Sutcliffe LLP

FFIEC updates BSA/AML examination manual

On August 2, the Federal Financial Institutions Examination Council (FFIEC) updated its Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual, which provides examiners with instructions for assessing a bank or...more

Orrick, Herrington & Sutcliffe LLP

OCC releases recent enforcement actions

On July 20, the OCC released a list of recent enforcement actions taken against national banks, federal savings associations, and individuals currently and formerly affiliated with such entities. Among the enforcement actions...more

Morrison & Foerster LLP

Banking Agencies Issue Joint Third-Party Risk Management Guidance

On June 9, 2023, the Federal Reserve Board, the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, the “Agencies”) published final joint guidance on managing...more

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