News & Analysis as of

BSA/AML CARES Act

Mintz - Health Care Viewpoints

Acting U.S. Attorney Levy Forecasts False Claims Act COVID Cases Targeting Private Lenders Of CARES Act Loans That Failed In Their...

Acting U.S. Attorney Joshua Levy discussed the enforcement priorities for the Massachusetts U.S. Attorney’s Office (USAO) during a Q&A session on May 29, 2024, and made clear that the historical focus of the office remains...more

Ballard Spahr LLP

New PPP Procedural Requirements Reflect Lenders’ Emerging AML Duties

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The Small Business Administration (“SBA”) recently issued a procedural notice (the “Notice”) to “All SBA Employees and Paycheck Protection Program Lenders” setting forth “Revised SBA Paycheck Protection Platform Procedures...more

Burr & Forman

FINRA 2021 Exam Results and Priorities

Burr & Forman on

On February 1, 2021, the Financial Industry Regulatory Authority (“FINRA”) released its “Report on FINRA’s Risk Monitoring and Examination Activities.”  The Report combines two of FINRA’s long-standing reports:  (a) the...more

Ballard Spahr LLP

PPP Lenders and Fraudulent Borrowers: False Claims Act Liability and AML Risk

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Can BSA/AML Requirements Lead to Deemed Knowledge of Borrower Fraud? The first two weeks of August brought a milestone of sorts in the ongoing recovery from the economic downturn brought on by the COVID-19 pandemic. The...more

Nutter McClennen & Fish LLP

Nutter Bank Report: July 2020

SBA Issues Instructions to Lenders on Submitting PPP Loan Forgiveness Applications The U.S. Small Business Administration (the “SBA”) has issued a procedural notice announcing that the SBA will begin accepting forgiveness...more

Morrison & Foerster LLP

Financial Services Report, Summer 2020

Is it just us or does March 4 — the date of our last issue — feel like a million years ago? Like you, and not necessarily in this order, we have been: doing our work; keeping up with COVID-19-related laws, guidance, and...more

K2 Integrity

PPP Lending—A Unique Compliance Challenge for Banks

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A commitment to PPP compliance now will not only align with regulator expectations, but can help guide innovation and the introduction of new products in the long run. ...more

Foodman CPAs & Advisors

Financial Institutions Can No Longer Afford to Underfund Compliance Hiring and Training

The Covid-19 Pandemic and the accompanying reduction in economic activity has been a rationale for Financial Institutions (FI) to re-analyze their budgets for compliance training and education.  FIs, as well as  businesses in...more

Ballard Spahr LLP

FATF Issues Paper on COVID-19 Enhanced AML and Fraud Risks

Ballard Spahr LLP on

On May 4, the Financial Action Task Force (“FATF”) issued a paper entitled “Covid-19-Related Money Laundering and Terrorist Financing – Risk and Policy Responses (“Paper”). ...more

Foodman CPAs & Advisors

FinCEN re-clarifies FAQ’s on how Lenders can meet BSA requirements when issuing PPP loans

On April 13, 2020, FinCEN, as the administrator of the BSA, re-published FAQs on how borrowers and lenders may rely on the guidance provided for the SBA’s interpretation of the CARES Act and of the PPP (Paycheck Protection...more

Morgan Lewis - All Things FinReg

Fintechs: PPP Lending Comes with Opportunities and Risks

The US Senate approved an additional $310 billion in funds for the Paycheck Protection Program (PPP) on April 20, and the House of Representatives is expected to approve these additional funds within days. As fintech...more

Goodwin

Financial Services Weekly Roundup: April (Liquidity) Showers Bring May Borrower Protection

Goodwin on

In this Issue: Senate Votes to Expand Paycheck Protection Program; FHFA (Finally) Addresses Liquidity Concerns for Mortgage Servicers. Yesterday, the U.S. Senate unanimously passed legislation providing $484 billion in...more

Robins Kaplan LLP

Financial Daily Dose 4.20.2020 | Top Story: Congress nearing agreement to re-fund COVID-19 SBA relief fund

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House leaders and White House negotiators are closing in on a bipartisan deal “to replenish funds in the small-business loan program that ran out of money” last week. The $500 billion measure would also “provide money for...more

Ballard Spahr LLP

FinCEN Issues COVID-19 AML Update for Financial Institutions

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Some Commentary on the Unfortunate Relationship Between Crisis and Fraud - The Financial Crimes Enforcement Network (“FinCEN”) released an update (“Update”) on its March 16, 2020 COVID-19 Notice, on which we previously...more

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