News & Analysis as of

BSA/AML Cryptocurrency Risk Management

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

Cadwalader, Wickersham & Taft LLP

FDIC's Annual Risk Review Includes Crypto Risks for First Time

The Federal Deposit Insurance Corporation (“FDIC”) published its annual Risk Review this past Monday, providing an overview of banking conditions for 2022 through early 2023. The FDIC started providing Risk Reviews to the...more

Sheppard Mullin Richter & Hampton LLP

OCC Highlights Focus on Crypto and Bank-FinTech Partnerships, Anticipates Stricter Scrutiny Going Forward

On September 7, Acting Comptroller of the Currency, Michael Hsu, discussed the long-term threats to trust in banking in remarks at the TCH + BPI Annual Conference. Hsu provided updates on key priorities at the OCC, including...more

Venable LLP

Keeping up with Anti-Money Laundering Rules

Venable LLP on

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

Morgan Lewis - All Things FinReg

OCC Issues Clarification on Stablecoin Custody Services

On the heels of an interpretive letter allowing national banks and federal savings associations (FSAs) to provide cryptocurrency custody services to customers (see our LawFlash), the US Office of the Comptroller of the...more

Orrick - On the Chain

Cryptocurrency and OFAC: Beware of the Sanctions Risks

Orrick - On the Chain on

A recent federal criminal action shows the depth of the U.S. government’s concern about the use of cryptocurrency (or virtual currency) to violate economic sanctions laws and the lengths to which it will go to charge such...more

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