News & Analysis as of

BSA/AML Coronavirus/COVID-19

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

ArentFox Schiff

Investigations Newsletter: COVID-19 Fraud Update

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Khadijah Chapman of Georgia, Daniel Labrum of Utah, and Eric O’Neil of Connecticut were all charged in separate indictments with submitting fraudulent Paycheck Protection Program (PPP) loan applications. According to the DOJ,...more

Goodwin

FinCEN Issues Proposed Rule for Beneficial Ownership Information Reporting Requirements

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In This Issue. The Financial Crimes Enforcement Network (FinCEN) announced (1) a notice of proposed rulemaking for beneficial ownership information reporting requirements and (2) a regulatory process for new real estate...more

Goodwin

House Votes to Repeal OCC True Lender Rule

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In This Issue. The House of Representatives voted to pass a Congressional Review Act resolution repealing the Office of the Comptroller of the Currency’s (OCC) “true lender” rule; the Consumer Financial Protection Bureau...more

Morrison & Foerster LLP

Financial Services Report - Summer 2021

As spring turns to summer, climate change is on our minds. A new day, a new story about how financial institutions are addressing climate-related risks. In the past few months, six major banks—Bank of America, JPMorgan...more

Burr & Forman

New Emphasis in SEC 2021 Examination Priorities

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The U.S. Securities and Exchange Commission (“SEC”) released its 2021 Examination Priorities on March 3.  The Examinations group – elevated last December to Division status (formerly the Office of Compliance Investigations...more

Morrison & Foerster LLP

Financial Services Report - Spring 2021

Can you say 0 to 60? Not cars, but pretty much everything to do with financial services. A new year, a new administration, and new challenges for providers. Prior CFPB Director Kraninger is long gone. Acting Director Uejio...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

Nutter McClennen & Fish LLP

Nutter Bank Report: January 2021

Updated Annual Meeting Guidance for Mutual Banks and Mutual Holding Companies - The Massachusetts Division of Banks has issued new guidance to mutual banks and mutual holding companies that have not yet held their 2020...more

Robins Kaplan LLP

Financial Daily Dose 1.19.2021 | Top Story: Fiat Chrysler and PSA Group Finalize Merger to Form Auto Behemoth Stellantis NV

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Fiat Chrysler and France’s PSA Group completed their mega-auto-merger first agreed-to in late 2019, “creating Stellantis NV, a global auto-making giant that executives say will have the heft needed to compete in the...more

K2 Integrity

FATF Plenary Outcomes: October 21-23, 2020

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Beginning on October 21, 2020, the Financial Action Task Force (“FATF”) held its three-day Plenary meeting virtually. It was the first Plenary of Germany’s two-year Presidency. As part of the Plenary outcomes, the FATF...more

Foodman CPAs & Advisors

GAFILAT Identifica Amenazas Emergentes de Lavado de Dinero/Financiamiento del Terrorismo

Foodman CPAs & Advisors on

GAFILAT (Grupo de Acción Financiera de América Latina) publicó una Segunda Actualización del Informe Regional de Amenazas de Lavado de Dinero (2017-2018) que incluye: ANEXO VI: AMENAZAS RELACIONADAS CON LA PANDEMIA COVID-19....more

Morrison & Foerster LLP

Financial Services Report – Fall 2020

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We join the nation in mourning the passing of Supreme Court Justice Ruth Bader Ginsburg. Over her 20-year career before appointment to the D.C. circuit court, Justice Ginsburg fought for equal rights in the workplace, among...more

Foodman CPAs & Advisors

Are Banks Implementing BSA Risk Based Adjustments related to COVID-19 circumstances?

The Office of the Comptroller of the Currency (OCC) Semiannual Risk Perspective Report highlights how the Covid-19 Pandemic has elevated  operational risks for banks as they are challenged with the implementation of new...more

K2 Integrity

Avoiding Missteps in Virtual Exams - Why communication and documentation are key for banks

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Why communication and documentation are key for banks. It goes without saying that a regulatory exam can be stressful for financial institutions even under otherwise “normal” operating conditions. However, add in the...more

Robins Kaplan LLP

Financial Daily Dose 9.21.2020 | Top Story: White House Signs Off on Deal for Oracle & Walmart to Take Stake in TikTok

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The White House has given its crucial imprimatur to a deal for Oracle (and Walmart) to take a stake in Chinese video app TikTok, “an agreement that will delay the U.S. government’s threat to block the popular app in 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: August 2020

Federal Court Dismisses Class Action Claims Against PPP Lenders for Agent Fees - A federal court in Florida has dismissed claims made in a class action lawsuit against several banks and other Small Business Administration...more

Eversheds Sutherland (US) LLP

FinCEN advisory highlights increased cybercrime risks during COVID-19

On July 30, 2020, the Financial Crimes Enforcement Network (FinCEN) released an advisory that signals its focus on cybercrime arising from vulnerabilities potentially created by the COVID-19 pandemic. The “Advisory on...more

K2 Integrity

Post-COVID Banking: Now is the Time to Make the Enterprise-Wide Risk Assessment Process Match the Rapidly Evolving Risk...

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Financial institutions have long suffered from the twin problems of high transaction-monitoring alert volumes and incomplete or low-quality data. Even before the COVID-19 pandemic, these challenges posed a constant risk to...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

Ballard Spahr LLP

Cyber-Enabled Financial Crime and Money Laundering

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Today we are very pleased to welcome guest blogger Moyara Ruehsen, PhD, CAMS, CFCS, who is an Associate Professor and Director of the Financial Crime Management Program at the Middlebury Institute of International Studies in...more

Hogan Lovells

Financial institutions general regulatory news, July 2020 #2

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LIBOR transition and PRA resolution-related rules: PRA statement - The UK Prudential Regulation Authority (PRA) has published a statement outlining the PRA's view on the implications of LIBOR transition for contracts in...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

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