News & Analysis as of September 18, 2024

Cybersecurity › Suspicious Activity Reports (SARs)

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Follow this channel for advisories on one of the biggest threats to businesses today. Read a morning brief of fresh guidance and commentary by leading lawyers on security, privacy, risk management, global regulations, data protection, leaks, hacking, cyber insurance, compliance, HIPAA, and every other aspect of cybersecurity of import to corporate readers right now. less -

Top 5 SEC Developments for July 2023

Morrison & Foerster LLP on 8/15/2023

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important SEC enforcement developments from the past month, with links to primary resources. This...more

SEC Division of Examinations’ 2023 Exam Priorities – A Continued Focus on Private Funds, Regulation Best Interest, ESG, and Crypto

Morrison & Foerster LLP on 2/22/2023

On February 7, 2023, the Securities and Exchange Commission’s (SEC) Division of Examinations (EXAMs) announced its 2023 Examination Priorities (the “Priorities”), which highlight areas it expects to target in 2023...more

New York Sends Clear Message Crypto Exchanges and Banks Must Meet AML Obligations

Harris Beach PLLC on 1/10/2023

New York’s Department of Financial Services (“DFS”) recently announced a $100 million settlement with Coinbase, Inc., one of the world’s largest cryptocurrency exchanges, for Bank Secrecy Act/Anti-Money Laundering (“BSA/AML”)...more

FinCEN analysis of BSA filings in 2021 reveals increased number and severity of ransomware attacks

Hogan Lovells on 11/8/2022

The Financial Crimes Enforcement Network’s most recent financial trend analysis report on ransomware-related Bank Secrecy Act filings for 2021 reveals an increased number of ransomware attacks and that a substantial number of...more

CFPB Launches New Initiative Focused on Rural Communities

Goodwin on 3/18/2022

In This Issue. The Consumer Financial Protection Bureau (CFPB) announced a new initiative focused on financial issues faced by rural communities and also updated its examination procedures to cover unfair discrimination; the...more

If You See Something, Say Something: FinCEN Updates Advisory on Managing Ransomware Attacks

Farrell Fritz, P.C. on 11/24/2021

In a few short weeks, the global loss attributable to cybercrime is expected to surpass $6 trillion.* Therefore, in an effort to protect financial institutions and consumers from further loss, agencies including the United...more

FinCEN Reports Spiraling SARs Relating to Ransomware

Ballard Spahr LLP on 10/22/2021

On October 15, 2021, the Financial Crimes Enforcement Network (“FinCEN”) issued a financial trend analysis on ransomware relating to Suspicious Activity Reports (“SARs”) filed in the first half of this year (“Analysis”). ...more

Treasury FinCEN Releases Financial Trend Analysis of Ransomware Trends in 2021

Alston & Bird on 10/20/2021

On October 15, 2021 the Financial Crimes Enforcement Network (FinCen) of the Treasury Department issued a financial trend analysis on ransomware relating to Bank Secrecy Act (BSA) reporting filed in the first half of this...more

Ransomware sanctions and the U.S. Government's latest strategy to address cyber threats

Hogan Lovells on 9/24/2021

The decision to pay millions to a cyber criminal has never been easy, but it is now even more complex. The U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) issued an updated advisory on September 21,...more

FinCEN on fire: Rapid release of AML Act updates

Eversheds Sutherland (US) LLP on 7/9/2021

On June 30, 2021, the Financial Crimes Enforcement Network (FinCEN) provided an update on implementation of the Anti-Money Laundering Act of 2020 (AML Act) and issued the first government-wide priorities for anti-money...more

Privacy Report: Senators Introduce Bipartisan Bill to Update Children’s Online Privacy Rules

ArentFox Schiff on 6/9/2021

The legislation updates the Children’s Online Privacy Protection Act (COPPA) by prohibiting internet companies from collecting personal information from anyone 13- to 15-years old without the user’s consent Senators...more

SEC and FINRA Emphasize Cybersecurity, AML, and Reg BI as Key Areas of Focus for Broker-Dealer Examinations in 2021

King & Spalding on 4/9/2021

The U.S. Securities and Exchange Commission (SEC) and Financial Industry Regulatory Authority (FINRA) have each published their annual examination priorities for 2021, signaling areas of scrutiny that broker-dealers should...more

FinCEN Warns Financial Institutions About Scams and Cyber-Attacks Relating to COVID-19 Vaccines

Ballard Spahr LLP on 12/30/2020

Providing yet more proof that anything positive can be twisted into something negative, the Financial Crimes Enforcement Network (“FinCEN”) released a Notice yesterday “to alert financial institutions about the potential for...more

Federal Financial Regulators Propose Requiring Banks Report Cyber Incidents Within 36 Hours

WilmerHale on 12/22/2020

On December 17, 2020, the Office of the Comptroller of the Currency, Treasury (OCC); the Federal Reserve; and the Federal Deposit Insurance Corporation (FDIC) issued a Notice of Proposed Rulemaking that would require...more

FDIC Finalizes Brokered Deposits and ILC Rules Ahead of the Holidays

Goodwin on 12/17/2020

In this Issue. The Federal Deposit Insurance Corporation (FDIC) was busy this week, finalizing rules that modernize brokered deposits regulations, establish new standards for parent companies of industrial loan companies and...more

FinCEN Issues Guidance on Ransomware Attacks

Jones Day on 10/23/2020

The prevalence, sophistication, and severity of ransomware attacks have increased anti-money laundering risks faced by financial institutions both as targets of ransomware attacks and as potential intermediaries in...more

FinCEN and OFAC Advisories Aim to Increase Cybersecurity Awareness and Thwart Ransomware Attacks in the Financial Sector

Ballard Spahr LLP on 10/8/2020

October is National Cybersecurity Awareness Month, and the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) and Office of Foreign Assets Control (“OFAC”) kicked off the month by issuing two...more

Ransomware Payments May Violate Sanctions Laws, U.S. Treasury Department Warns

Faegre Drinker Biddle & Reath LLP on 10/7/2020

On October 1, 2020, the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued an advisory to companies that pay a ransom in the wake of a cyberattack. Specifically, the advisory warned that...more

Treasury Department issues ransomware guidance in response to significant uptick in ransomware attacks

Hogan Lovells on 10/6/2020

In response to the significant rise in ransomware attacks since the start of the COVID-19 pandemic and just in time for Cybersecurity Awareness Month, the Department of the Treasury’s Financial Crimes Enforcement Network...more

Cyber-Enabled Financial Crime and Money Laundering

Ballard Spahr LLP on 7/29/2020

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

FINRA Again Reminds Firms to Beware of Fraud during COVID-19 Pandemic

Mintz - Privacy & Cybersecurity Viewpoints on 5/7/2020

As we previously discussed, FINRA issued guidance to member firms and their associated persons in April 2020 to remain “vigilant in their surveillance against cyber threats and take steps to reduce the risk of cyber events.”...more

SEC Exam Priorities For RIAs and ICs

Dorsey & Whitney LLP on 1/15/2020

The Exam Priorities of the SEC’s Office of Inspections and Compliance or OCIE, announced on January 7, 2020 (the “Exam Priorities”), should be a key area of focus for every investment advisor and investment company. The Exam...more

Lessons from FINRA’s 2019 Report on Examination Findings and Observations

Dechert LLP on 11/18/2019

The Financial Industry Regulatory Authority published its 2019 Report on Examination Findings and Observations (2019 Report) on October 16, 2019. This marks the third annual report of FINRA findings, but in a departure from...more

FinCEN Director Blanco Addresses “Cyber Hygiene”

Ballard Spahr LLP on 9/27/2019

FinCEN Director Kenneth A. Blanco delivered prepared remarks on September 24 at the 2019 Federal Identity (FedID) Forum and Exposition in Tampa, Florida. Director Blanco summarized the topics of his remarks by stating the...more

FinCEN Unveils New Efforts To Combat Widespread Business Email Compromise Fraud Scams As Losses Reach $300 Million Per Month

Fox Rothschild LLP on 7/17/2019

The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has announced new efforts to crack down on Business Email Compromise (BEC) schemes and those who profit from such scams. BEC fraud schemes generally...more

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Cybersecurity › Suspicious Activity Reports (SARs)

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