News & Analysis as of

Office of the Comptroller of the Currency FinCEN Suspicious Activity Reports (SARs)

WilmerHale

FinCEN’s Proposed AML/CFT Program Rule Potentially Heralds a Change in Approach

WilmerHale on

On June 28, 2024, the US Department of the Treasury’s Financial Crimes Enforcement Network announced long-anticipated proposed rules on anti-money laundering and countering the financing of terrorism program effectiveness;...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

Goodwin

Federal Agencies Issue Joint Statement on Management of LIBOR Transition

Goodwin on

In This Issue. Federal agencies issued a joint statement regarding an orderly transition away from the London Interbank Offered Rate (LIBOR); the Office of the Comptroller of the Currency (OCC) issued an updated...more

Goodwin

Biden Administration Issues Regulatory Freeze On New Agency Rules

Goodwin on

In this Issue. In one of its first acts after being installed on January 20, the Biden Administration issued a regulatory freeze on new agency rules that have been adopted but are not yet effective; in one of its final acts...more

Perkins Coie

Blockchain Week in Review - January 2021

Perkins Coie on

Federal Regulation Actions Frozen Pending Review from New Administration - On January 20, 2021, newly inaugurated President Joe Biden issued a memorandum to the Heads of Executive Departments and Agencies asking current...more

Ballard Spahr LLP

The OCC Embraces Technology, Proposes Exemption to SAR Requirements and Announces Acceptance of Distributed Ledgers and...

Ballard Spahr LLP on

The Comptroller of the Currency (the “OCC”) has been busy, and focused on technology. We discuss two recent developments: proposed regulations that would allow the OCC to grant exemptions relating to Suspicious Acivity...more

Kelley Drye & Warren LLP

Former US Bank Exec Held Individually Liable for Anti-Money Laundering

Compliance Failures - On March 4, 2020, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a consent order assessing a $450,000 civil money penalty against Michael LaFontaine, former Chief...more

The Volkov Law Group

United Bank Risk Officer Agrees to $450k Penalty for AML Compliance Failures

The Volkov Law Group on

Compliance professionals face extraordinary risks – not just for the enterprise but personal risks.  CCOs should not panic or overreact when the government brings an enforcement action against a compliance officer for a...more

Morrison & Foerster LLP

FinCEN Penalizes Individual Banker For Anti-Money Laundering Compliance Program Failures

For what appears to be only the second time, the Financial Crimes Enforcement Network (“FinCEN”) has assessed a civil money penalty (“CMP”) against an individual for Bank Secrecy Act (“BSA”) violations based on alleged...more

Eversheds Sutherland (US) LLP

The OCC’s 2019 annual report addresses anti-money laundering risks for financial institutions

The Office of Comptroller of the Currency (the OCC) has published its 2019 annual report (the Annual Report), which summarized the OCC’s strategic priorities for 2019. The Annual Report also highlighted the OCC’s key...more

Nutter McClennen & Fish LLP

Bank Report: December 2019

FDIC and OCC Propose CRA Modernization Rule with Opt-Out for Small Banks The FDIC and the OCC have jointly proposed amendments to modernize the agencies’ Community Reinvestment Act (“CRA”) regulations, which are intended...more

Eversheds Sutherland (US) LLP

Federal agencies clarify SAR filing requirements for financial services provided to hemp-related businesses

On December 3, 2019, four federal agencies, in consultation with state banking regulators, clarified the legal status of hemp growth and production under the Bank Secrecy Act (BSA) for banks providing financial services to...more

Dorsey & Whitney LLP

Banking Services for Hemp Growers – FinCEN Makes a Statement

Dorsey & Whitney LLP on

On December 3, 2019, FinCEN, along with the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency, in consultation with the Conference of...more

Bradley Arant Boult Cummings LLP

Is the Bank Open? Federal Agencies Clarify Regulatory Requirements for Banking Hemp

On December 3, several federal agencies issued guidance (Guidance) that, by its terms, “provide[s] clarity” regarding “the regulatory requirements under the Bank Secrecy Act (BSA) for banks providing services to hemp-related...more

Ballard Spahr LLP

Banking Regulators Ease SAR Reporting Requirements Applied to Hemp-Related Businesses

Ballard Spahr LLP on

On December 3, 2019, four federal agencies – the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation (“FDIC”), the Financial Crimes Enforcement Network (“FinCEN”), and the Office of the...more

White & Case LLP

Review of Anti-Money Laundering and Sanctions Policy and Enforcement

White & Case LLP on

TABLE OF CONTENTS: Executive Summary - Developments and Trends in Policy and Enforcement - US Department of the Treasury - The Office of Foreign Assets Control - Treasury's Financial Crimes Enforcement Network -...more

Carlton Fields

Banks to Broaden Reporting of Suspicious Cyber Activity; Regulators Propose “Enhanced” Cybersecurity Standards

Carlton Fields on

The fourth quarter of 2016 has seen an uptick in regulatory activity respecting the financial services sector in the cybersecurity space, both at the state level as previously discussed (here) and on the federal level....more

A&O Shearman

Financial Regulatory Developments Focus - November 2016

A&O Shearman on

In this newsletter, we provide a snapshot of the principal US, European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset managers and...more

Carlton Fields

Anti-Money Laundering Trends: Facts, Findings, and Lessons Learned

Carlton Fields on

Increased anti-money laundering (AML) regulation enforcement by federal and state agencies in recent months should have financial institutions across the country reviewing and strengthening their in-house AML policies and...more

Goodwin

JPMorgan Chase & Co. and its Affiliates Agree to Pay the DOJ, OCC and FinCEN an Aggregate of $2.05 Billion to Resolve Violations...

Goodwin on

JPMorgan Chase & Co. and its affiliates (collectively, “JPMorgan”) agreed to pay an aggregate of $2.05 billion to resolve civil and criminal claims generally related to JPMorgan’s Bank Secrecy Act (“BSA”) compliance program...more

The Volkov Law Group

FinCEN Joins The Enforcement Party

The Volkov Law Group on

FinCEN’s new Enforcement Division, which was created in June of 2013, is already making its mark in the financial enforcement world. Federal regulators are focusing on compliance with Bank Secrecy Act (“BSA”) and...more

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