News & Analysis as of

Risk Management Financial Institutions Regulatory Requirements

Katten Muchin Rosenman LLP

CFTC Staff Reminds Registered Exchanges and Clearinghouses to Evaluate and Calibrate Their Volatility Control Mechanisms

The Commodity Futures Training Commission’s (“CFTC”) Division of Market Oversight and Division of Clearing and Risk issued an advisory (the “Staff Advisory”) reminding designated contract markets (“DCMs”) and derivatives...more

A&O Shearman

PRA Phase 1 of Pillar 2A review

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The UK Prudential Regulation Authority (PRA) has published a consultation paper (CP12/25) setting out Phase 1 of its Pillar 2A review. This first phase review seeks to address the consequential impact of the near-final PRA...more

Conyers

Country Update - Bermuda: AML

Conyers on

Bermuda is a leading international financial centre and maintains a comprehensive body of primary legislation relating to money laundering and terrorist financing, supported by a range of general and sector specific guidance...more

Skadden, Arps, Slate, Meagher & Flom LLP

PRA Announces Updates to Approach of Responsible Openness to International Banks

On 20 May 2025, the UK Prudential Regulation Authority (PRA) published a policy statement (PS6/25) on business conducted within branches of international banks operating in the UK, as well as its booking model expectations...more

Orrick, Herrington & Sutcliffe LLP

GAO report focuses on AI use in financial services

On May 19, the GAO published a report discussing the use and oversight of AI in financial services. The report highlighted the benefits of AI, such as improved efficiency, reduced costs, and enhanced customer experience,...more

Ankura

Exam Time: Understanding Exam Ratings

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It is inevitable that your Money Service Business (MSB) will eventually receive a much-anticipated (or in some instances, much-dreaded) Exam Engagement letter from one or more states. MSBs licensed in 40 or more states meet...more

A&O Shearman

Corrigendum to Commission Delegated Regulation on RTS on risk management tools under DORA published in OJ

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A corrigendum to Commission Delegated Regulation (EU) 2024/1774, which supplements the Regulation on digital operational resilience for the financial sector (DORA), was published in the Official Journal of the European Union...more

A&O Shearman

GHOS Meeting: Basel III implementation and climate-related financial risks

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The Group of Central Bank Governors and Heads of Supervision (GHOS), the oversight body of the Basel Committee on Banking Supervision (BIS), met to discuss the implementation of Basel III and its work on climate-related...more

A&O Shearman

CMORG AI Taskforce releases comprehensive AI Baseline Guidance

A&O Shearman on

The Cross Market Operational Resilience Group's (CMORG) AI Taskforce has released its AI Baseline Guidance Review (dated January 2025), accompanied by a press release. The CMORG AI Taskforce conducted a baseline review of...more

Hogan Lovells

Dear CFO: Liquid Assets? We would like to see receipts. Love, PRA.

Hogan Lovells on

Banks relying on back-leveraged SRT trades in the UK now face increased regulatory scrutiny. The PRA's "Dear CFO" letter warns that not all repo financings collateralised by SRT tranches meet the trading book’s liquidity...more

Orrick, Herrington & Sutcliffe LLP

OCC clarifies crypto-asset activities in interpretive letter

On May 7, the OCC clarified permissible activities for national banks and federal savings associations regarding crypto-asset custody and execution services by publishing Interpretive Letter 1184. This letter confirmed...more

Orrick, Herrington & Sutcliffe LLP

OIG makes seven recommendations for CFPB following major incident

On May 5, the OIG for the Fed authored a report with several recommendations for the CFPB following a major security incident regarding confidential supervisory information (CSI). The OIG issued four findings with seven...more

A&O Shearman

EBA updates technical standards on resolution planning reporting

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The European Banking Authority (EBA) has published its final report on the draft implementing technical standards (ITS) on resolution planning reporting, together with a press release. Firms must provide necessary information...more

A&O Shearman

EC adopts delegated regulation amending RTS for market risk under CRR

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The European Commission has adopted Delegated Regulation (EU) 2025/878 amending regulatory technical standards (RTS) on technical details of back-testing and profit and loss attribution requirements, the criteria for...more

Amundsen Davis LLC

5 Reasons Your Bank Needs an AI Policy (Right Now)

Amundsen Davis LLC on

Banks of all sizes must confront the rapid integration of artificial intelligence within their institutions (and everywhere, for that matter). AI tools are already widely used, often without proper oversight, as employees and...more

Ankura

Challenges in Data Sharing between Banking Partners

Ankura on

Life in the United States and most modern industrialized countries is driven primarily by data. Google alone processes 20 Petabytes of data every day (1 petabyte = 1 million gigabytes. Economies are built on data; marketing...more

Latham & Watkins LLP

OCC Affirms Banks Can Engage in Crypto Custody and Execution Activities

Latham & Watkins LLP on

The federal banking agencies continue to open the channels for regulated entities to engage in digital asset activities. On May 7, 2025, the Office of the Comptroller of the Currency (OCC) published Interpretive Letter...more

A&O Shearman

Key elements of the 2025 CCP Stress Test

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The Bank of England (BoE) has published key elements to its 2025 Stress Test of UK Central Counterparties (CCPs), along with a spreadsheet containing the relevant market stress scenarios. This exercise, the fourth of its...more

Orrick, Herrington & Sutcliffe LLP

FDIC releases February 2025 CRA evaluations

On May 5, the FDIC released a list of state non-member banks evaluated for compliance with the CRA during February 2025. Under the CRA, the FDIC assesses how effectively banks meet the credit needs of their entire community,...more

McGuireWoods LLP

Banks May Provide Cryptocurrency Transaction and Custody Services, but OCC Has Yet to Provide Clear Compliance Requirements

McGuireWoods LLP on

On May 7, 2025, the Office of the Comptroller of the Currency (“OCC”) issued a follow up to its July 2020 Interpretative Letter 1170, which allowed national banks to provide cryptocurrency custody services to their customers....more

Hogan Lovells

NYDFS: Penultimate set of cybersecurity requirements under amended Part 500 take effect May 1, 2025

Hogan Lovells on

On May 1, 2025, additional cybersecurity requirements introduced by the Second Amendment to the New York Department of Financial Services (NYDFS) Cybersecurity Regulation (23 NYCRR Part 500) (the “Second Amendment”) took...more

Mayer Brown

Credibly Challenged Podcast: Interview with Ross Delston, Financial Crime Compliance Expert and Former FDIC Attorney

Mayer Brown on

Matt Bisanz interviews Ross Delston, a financial crime compliance expert and former FDIC attorney. They discuss his views on the trends we should expect to see in financial crimefighting and AML compliance over the next few...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Climate Change Financial Risk Act of 2025: U.S. Senate Legislation Introduced Directing the Federal Reserve to Address Financial...

United States Senator Brian Schatz (Hawaii) has introduced legislation titled: Climate Change Financial Risk Act of 2025 (“Act”). The Act directs the United States Federal Reserve to conduct stress tests on large...more

Skadden, Arps, Slate, Meagher & Flom LLP

The Standard Formula: Encyclopaedia of Prudential Solvency – Chapter 3: Prudential Insurance Regulation in Japan

This chapter discusses prudential insurance regulation in Japan. Japan is the fourth-largest insurance market in the world, with a broad customer base and a varied range of offerings. This profile, coupled with ongoing...more

A&O Shearman

FSB Chair Letter to G20 Finance Ministers

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The Financial Stability Board (FSB) has published a letter, along with a press release and webpage, from its Chair, Klaas Knot, to G20 finance ministers and central bank governors ahead of their meeting on 23-24 April. The...more

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