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Risk Assessment Financial Services Industry

Ballard Spahr LLP

FinCEN Finalizes Rule Subjecting Investment Advisers to AML/CFT Regulations

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Following up on its Notice of Proposed Rulemaking (“NPR”), which we discussed back in March, the Financial Crimes Enforcement Network (FinCEN) released on August 28th a final rule extending Anti-Money Laundering/Countering...more

Ballard Spahr LLP

FinCEN Issues Final BSA Reporting Requirements for Residential Real Estate Deals

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On August 29, the Financial Crimes Enforcement Center (“FinCEN”) published Anti-Money Laundering Regulations for Residential Real Estate Transfers (“Final Rule”) regarding residential real estate.  The Federal Register...more

Pillsbury - Global Sourcing Practice

U.S. Financial Regulators Continue Focus on Bank-Fintech Partnerships through Guidance and Request for Information

On July 25, 2024, the Board of Governors of the Federal Reserve System (FRB), Federal Deposit Insurance Corporation (FDIC) and Office of the Comptroller of the Currency (OCC) issued a joint statement describing potential...more

Ballard Spahr LLP

Bank’s Digital Assets Business Strategy Draws Federal Reserve Scrutiny

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The Federal Reserve Bank of Philadelphia (the “Philly Fed”) recently executed an agreement (the “Agreement”) with Pennsylvania-based Customers Bank (and its Customers Bancorp, Inc. holding entity) (collectively, “Customers”)....more

Clark Hill PLC

Prudential Regulators Propose Rules Amending Anti-Money Laundering Requirements: Is Your Financial Institution Ready?

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On July 14, the Financial Crimes Enforcement Network (FinCEN) joined the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of...more

K&L Gates LLP

Digital Operational Resilience in the Financial Services Sector: EU and UK Update

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With under six months to go until the European Union Digital Operational Resilience Act (DORA) becomes applicable on 17 January 2025, DORA implementation projects are running full steam ahead. DORA lays down uniform...more

Orrick, Herrington & Sutcliffe LLP

RegFi Episode 42: Beyond the Breach: The CISO’s Role as a Strategic Risk Manager

RegFi co-hosts Jerry Buckley and Sherry Safchuk welcome Orrick partner Aravind Swaminathan for a conversation exploring the critical and evolving role of the Chief Information Security Officer in today’s corporate landscape.....more

Alston & Bird

Navigating AI-Related Disclosure Challenges: Securities Filing, SEC Enforcement, and Shareholder Litigation Trends

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Companies’ accelerating reliance on artificial intelligence (AI) means heightened Securities and Exchange Commission (SEC) and shareholder plaintiff scrutiny. Our Securities Litigation Group underscores what companies need to...more

Ballard Spahr LLP

BSA Filings and Their Utility to Law Enforcement:  An Industry Viewpoint

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In this post, we will once again consider the issue of the utility of Bank Secrecy Act (BSA) filings to the global anti-money laundering/countering the financing of terrorism (AML/CFT) compliance regime....more

Troutman Pepper

Following FinCEN’s Lead, Four Federal Banking Regulators Announce AML/CFT Rulemaking

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As discussed here, on June 28, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) proposed significant amendments to the anti-money laundering and countering the financing of terrorism...more

Cadwalader, Wickersham & Taft LLP

Summer Regulatory Round-Up | July 2024

The banking regulators have not yet gone out on vacation, as demonstrated by this grab-bag of announcements, speeches, rules and guidance: Acting Comptroller of the Office of the Comptroller of the Currency (OCC),...more

Array

This Week in eDiscovery: The Duty to Preserve Ephemeral App Data, Employee Compliance with Electronic Communication Rules

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Every week, the Array team reviews the latest news and analysis about the evolving field of eDiscovery to bring you the topics and trends you need to know. This week’s post covers the week of July 8-14. Here’s what’s...more

Ballard Spahr LLP

FinCEN Issues Proposed Rulemaking Aimed at Strengthening and Modernizing AML Programs Across Multiple Industries

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On July 3, the Financial Crimes Enforcement Network (FinCEN) published a notice of proposed rulemaking (NPRM) as part of a broader initiative to “strengthen, modernize, and improve” financial institutions’ anti-money...more

Mayer Brown

FinCEN Proposes Rule Reinforcing Financial Institutions’ Duty to Design and Maintain Risk-Based AML/CFT Programs

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On June 28, 2024, the US Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking (“June 2024 NPRM”) to crystalize its long-held expectation that financial institutions use...more

Akin Gump Strauss Hauer & Feld LLP

UK Listing Rules Reforms

The UK Financial Conduct Authority (FCA) has today published its long-awaited reforms to the UK’s listing regime (Listing Rules), designed to reinvigorate UK capital markets and make the listing regime more internationally...more

Cadwalader, Wickersham & Taft LLP

FinCEN and Federal Banking Agencies Propose Amendments to Anti-Money Laundering Rules

On June 28, 2024, The U.S. Treasury’s Financial Crimes Enforcement Network (“FinCEN”) released a notice of proposed rulemaking (the “Proposed Rule”) that would amend FinCEN’s anti-money laundering (“AML”) program rules for...more

WilmerHale

Treasury Issues Request for Information on Uses of AI

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On June 6, 2024, the US Department of the Treasury (Treasury) issued a request for information (RFI) on the “uses, opportunities and risks of artificial intelligence (AI) in the financial services sector.” The RFI seeks...more

Troutman Pepper

Treasury Department Issues Request for Information on the Use of AI in Financial Services

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On June 6, the U.S. Department of the Treasury (Treasury) issued a request for information (RFI) seeking public input on the uses, opportunities, and risks presented by the use of artificial intelligence (AI) within the...more

K&L Gates LLP

Brussels Regulatory Brief: May 2024

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Antitrust and Competition - The European Commission Approves Plan to Unwind a Completed Transaction in the Early Cancer Detection Sector - On 12 April 2024, the European Commission (Commission) approved the plan to unwind a...more

A&O Shearman

UK FCA Financial Crime Guide consultation: more obligations, or old news?

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As financial crime compliance pressures grow, the UK Financial Conduct Authority (FCA) continues to emphasise the significance of its Financial Crime Guide (FCG) as part of the overarching regulatory framework for financial...more

Cadwalader, Wickersham & Taft LLP

The UK’s FCA Publishes Webpage on Operational Resilience Requirements

The UK’s Financial Conduct Authority (“FCA”) has published a web page of observations aimed at helping firms prepare for new operational resilience rules due to be inforced by 31 March 2025. The relevant rules apply to banks,...more

Mayer Brown Free Writings + Perspectives

SEC and FinCEN Propose Customer Identification Program Requirements for Certain Investment Advisers

I. INTRODUCTION - On May 13, 2024, the US Securities and Exchange Commission (“SEC”) and the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a joint notice of proposed rulemaking (the...more

Ballard Spahr LLP

Treasury Issues Broad National Strategy for Combatting Illicit Financing

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Strategy Touts Regulations on Beneficial Ownership, Real Estate and Investment Advisers, but Bemoans Lack of Supervisory Resources for Non-Bank Financial Institutions...more

Orrick, Herrington & Sutcliffe LLP

NYDFS releases its Cybersecurity Program Template

On May 13, NYDFS issued a guidance letter informing licensed entities about its Cybersecurity Program Template. NYDFS created the Template to help individual licensees and individually owned businesses licensed by NYDFS to...more

Latham & Watkins LLP

FRB Issues Report on Climate Scenario Analysis Pilot

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With regulators keeping close watch, the results underscore the need for ongoing climate risk management investment and adaptation within the financial sector. On May 9, 2024, the Board of Governors of the Federal...more

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