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Risk-Based Approaches Financial Institutions

Troutman Pepper Locke

NAIC Establishes the Risk-Based Capital Model Governance (EX) Task Force in 2025

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The 2025 National Association of Insurance Commissioners (NAIC) President and North Dakota Insurance Commissioner Jon Godfread has stated that...more

Latham & Watkins LLP

FRB Clarifies Supervision of Digital Assets and Bank-Fintech Partnerships

Latham & Watkins LLP on

A new program addresses innovative banking activities such as bank-fintech partnerships and digital assets while reinforcing guardrails around stablecoin activity. On August 8, 2023, the Board of Governors of the Federal...more

Latham & Watkins LLP

Federal Reserve Proposes Climate Risk Guidance for Large Financial Institutions

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The guiding principles are similar to related proposals from other banking regulators, but will require further clarification through the comment process. On December 2, 2022, the Board of Governors of the Federal...more

Hogan Lovells

World Bank investigations spike and highlight integrity risks in private sector development finance

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Ignoring integrity risks in emerging markets when receiving financing from the World Bank Group (WBG) is about to become much riskier, as the WBG Sanctions System Annual Report for Fiscal Year 2022 (FY22) indicates. The...more

Akerman LLP

New OFAC Advisory Offers Steps to Reduce Sanctions Risks for Entities Facilitating Ransomware Payments

Akerman LLP on

Companies that make ransomware payments, whether they be the victim of a ransomware attack or entities that facilitate such payments, should review the updated advisory issued by U.S. Department of the Treasury's Office of...more

Bilzin Sumberg

OFAC Warns Companies Again Not to Pay Ransomware Demands and Offers Helpful Hints for Mitigating Risks

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On September 21, 2021, The Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued an Updated Advisory “to highlight the sanctions risks associated with ransomware payments in connection with malicious...more

Hogan Lovells

Global Payments Newsletter, April 2021

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United Kingdom: FCA publishes feedback statement on Open Finance On 26 March 2021, the FCA published a Feedback Statement on Open Finance (FS21/7) following its December 2019 Call for Input....more

Akin Gump Strauss Hauer & Feld LLP

OFAC Releases Advisory on Sanctions Risk Involving Ransomware Payments

In early October, the United States Department of Treasury’s Office of Foreign Assets Control (OFAC) issued an advisory, warning of the potential risk of sanctions to companies and individuals who pay ransomware payments. The...more

Robinson+Cole Data Privacy + Security Insider

OFAC Issues Advisory on Sanctions for Facilitating Ransomware Payments

On October 1, 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued an advisory “to highlight the sanctions risks associated with ransomware payments related to malicious cyber-enabled...more

Orrick, Herrington & Sutcliffe LLP

FinCEN and Banking Regulators Clarify Due Diligence Requirements for Politically Exposed Persons

The Financial Crimes Enforcement Network (FinCEN) and federal banking regulators recently issued a Joint Statement intended to clarify the due diligence obligations of banks under the Bank Secrecy Act (BSA) regarding...more

Ballard Spahr LLP

Joint Statement Clarifies Due Diligence Expectations for Politically Exposed Persons

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Regulators’ Joint Statement Attempts to Clarify AML Expectations Regarding Potential Corrupt Actors - On August 21, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) and other banking regulators –...more

Orrick, Herrington & Sutcliffe LLP

COVID-19 Creates Increased Risk of Financial Crimes and AML Exposure; FATF and FinCEN Provide Guidance

Earlier this month, senior officials of the global money laundering and terrorist financing watchdog—the Financial Action Task Force (FATF)—issued a paper identifying challenges, good practices, and policy responses to new...more

Foodman CPAs & Advisors

Who are you partnering with for your Financial Institution’s BSA/AML Independent Testing?

Financial Institutions ought to design and evaluate compliance programs to meet BSA/AML requirements and to satisfy Bank Examiner expectations. A Financial Institution’s Compliance Programs must comply with the requirements...more

Foodman CPAs & Advisors

¿Su institución financiera utiliza un “Matrix” de enfoque basado en el riesgo de la OFAC?

El perfil de riesgo de la OFAC de una Institución Financiera se determina basado sus productos, servicios, clientes y ubicaciones geográficas.  Se requiere que un programa de cumplimiento OFAC de una Institución Financiera...more

Foodman CPAs & Advisors

Does your Financial Institution utilize OFAC’s Risk Based Approach Matrix?

A Financial Institution’s OFAC risk profile is determined based on its products, services, customers and geographic locations.  A Financial Institution’s OFAC compliance program is required to...more

Ballard Spahr LLP

FinCEN Issues Advisory on Foreign Jurisdictions with AML Deficiencies

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On November 12, 2019, FinCEN issued its latest Advisory on the Financial Action Task Force-Identified Jurisdictions with Anti-Money Laundering and Combatting the Financing of Terrorism Deficiencies and Relevant Actions by the...more

A&O Shearman

Financial Action Task Force Consults on Digital Identity in Customer Due Diligence Guidance

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The Financial Action Task Force is seeking feedback from private sector stakeholders on its draft guidance on the use of digital identity systems in customer due diligence. The guidance will supplement Recommendation 10 of...more

Ballard Spahr LLP

Federal banking agencies release tailoring rules

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On October 10, 2019, the Board of Governors of the Federal Reserve System (Board), together with the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation, adopted a final rule to revise the...more

Ballard Spahr LLP

What the Basel AML Index Reveals About Global Money Laundering Risks

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Established in 2003, the Basel Institute is a not-for-profit Swiss foundation dedicated to working with public and private partners around the world to prevent and combat corruption, and is an Associated Institute of the...more

A&O Shearman

Basel Committee on Banking Supervision Publishes Overview of Pillar 2 Practices and Approaches

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The Basel Committee on Banking Supervision has published an overview report on the Pillar 2 supervisory review process and on the different practices that regulators and legislators in Basel member jurisdictions have adopted...more

Jones Day

Bank of England Publishes Discussion Paper on Risk Management Systems for Collateral Referencing LIBOR

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The Situation: The LIBOR manipulation scandal and vanishing liquidity in the London inter-bank market for time deposits led the Financial Conduct Authority ("FCA") to announce that at the end of 2021, banks would no longer be...more

A&O Shearman

Financial Action Task Force Publishes Guidance for a Risk-Based Approach to Virtual Assets and Virtual Asset Service Providers

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The Financial Action Task Force has published the outcomes of its third and last Plenary meeting under the U.S. Presidency in Orlando on June 19-21, 2019. The FATF considered key issues such as strategic initiatives, mutual...more

K2 Integrity

April 15 Isn’t Just Tax Day—It’s Also AML Certification Compliance Day

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It’s not just your taxes that are due each year on April 15. For financial institutions, this coming April 15 is the date the New York Department of Financial Services’ (NYDFS’s ) new Anti-Money Laundering (AML) Part 504...more

Morrison & Foerster LLP

FinCEN Proposes Anti-Money Laundering and Suspicious Reporting Rules for Registered Investment Advisers

On August 25, 2015, the US Treasury Department’s Financial Crimes Enforcement Network (FinCEN) proposed rules that would require registered investment advisers to adopt anti-money laundering (AML) programs and report...more

Orrick - Finance 20/20

Joint Committee of ESAs Consults on Risk-Based Supervision and Risk Factors Guidelines

Orrick - Finance 20/20 on

On October 21, 2015, the Joint Committee of the European Securities and Markets Authority, the European Banking Authority and the European Insurance and Occupational Pensions Authority (together, the European Supervisory...more

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