News & Analysis as of

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

Troutman Pepper

Federal Banking Agencies Reiterate Guidance on Managing Risks Posed By Fintech Partnerships and Other Third Party Relationships

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Last week, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (collectively, the agencies) issued a joint statement highlighting...more

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

Ballard Spahr LLP

OCC Risk Perspective Report Focuses on Third-Party Relationships with Fintechs

Ballard Spahr LLP on

In its Fall 2023 Semiannual Risk Perspective, published on December 7, the Office of the Comptroller of the Currency (“OCC”) reported on key issues facing the federal banking system. In evaluating the overall soundness of...more

Troutman Pepper

OCC’s Semiannual Report Highlights Emerging Risk of AI in Banking

Troutman Pepper on

On December 7, the Office of the Comptroller of the Currency (OCC) published the fall edition of its Semiannual Risk Perspective, which discusses key issues facing banks. From the OCC’s perspective, the overall strength of...more

Goodwin

CFPB Launches New Initiative Focused on Rural Communities

Goodwin on

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

Miller Nash LLP

I Just Wanna Know—Federal Bank Regulators to Require Notice of Major Cyber Security Events

Miller Nash LLP on

Hardly a day goes by without news of a new cybercrime hobbling a major business.1 The grand scope of the SolarWinds hack, which went undetected for many months, underscored that even the most sophisticated technology...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

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

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

Perkins Coie

Fintech Week in Review - January 2021 #3

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...

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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

Goodwin

FDIC Finalizes Brokered Deposits and ILC Rules Ahead of the Holidays

Goodwin on

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

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

Nelson Mullins Riley & Scarborough LLP

DOJ ‘Reminds’ Banking Industry of the Significant Risks Created by an Inadequate BSA/AML Program

Last week the Department of Justice (DOJ) announced criminal charges against U.S. Bancorp “consisting of two felony violations of the Bank Secrecy Act (‘BSA’) by its subsidiary, U.S. Bank National Association (the ‘Bank’),...more

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