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Risk Management Internal Controls Financial Institutions

K&L Gates LLP

Lessons From 2024 Anti-Money Laundering Enforcement Actions

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In 2024, FinCEN and the federal bank regulators announced more than three dozen enforcement actions against banks and individuals arising from alleged Bank Secrecy Act (BSA), anti-money laundering (AML), and countering the...more

K2 Integrity

Fiat Ramps Unlocked: Practical Tips For Banks And Crypto Firms

K2 Integrity on

Ask any centralized cryptocurrency firm to name one of their biggest priorities or challenges—and then count the number of times they mention bank partnerships. For crypto firms, the loss of, or failure to acquire, a bank...more

Venable LLP

DOJ Revises Its Evaluation of Corporate Compliance Policy to Consider How Companies Address Risks Posed by AI

Venable LLP on

The Department of Justice's Criminal Division is "using more tools than ever before to identify corporate misconduct and to encourage companies to be good corporate citizens," according to Nicole Argentieri, Principal Deputy...more

Conyers

The Importance of Sound Corporate Governance for Virtual Asset Service Providers: Lessons from Past Failures

Conyers on

In recent years, the virtual asset industry has experienced exponential growth, bringing about innovations in digital payments, tokenisation and decentralised finance (Defi). While highly innovative, the volatile nature of...more

J.S. Held

INDEPTH FEATURE: Anti-Money Laundering 2024

J.S. Held on

Could you provide an insight into recent trends shaping financial crime in your country of focus? How great a risk does money laundering in particular now pose to companies? One would likely never imagine compliance as...more

Mayer Brown

NYDFS Finalizes Climate Risk Management Guidance

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On December 21, 2023, the New York Department of Financial Services (“NYDFS”) finalized guidance on how the banks and mortgage institutions it regulates (“New York Institutions”) should manage climate-related financial and...more

Walkers

Director exemptions: changes to AML obligations

Walkers on

Introduction - Further to a recent update, in which the Government, in consultation with the Jersey Financial Services Commission ("JFSC"), announced its intention to make legislative changes to the anti-money laundering,...more

Cadwalader, Wickersham & Taft LLP

Basel Committee Issues Guidance on Core Principles for Effective Banking Supervision

In April 2022, the Basel Committee on Banking Supervision (the Basel Committee) began a review of “the core principles for effective banking supervision” (Core Principles or CP). Last month, the Basel Committee published...more

Latham & Watkins LLP

Acting Comptroller Confronts “Too Big to Manage” Issue

Latham & Watkins LLP on

The Acting Comptroller of the OCC discussed the limits of large bank manageability and the steps that regulators can take to address the risks posed by size and complexity. On January 17, 2023, Acting Comptroller of the...more

Latham & Watkins LLP

NYDFS Proposes Guidance on Climate Change Risk Management

Latham & Watkins LLP on

The Guidance would increase expectations for regulated financial institutions to identify, measure, monitor, and control climate-related financial risks. For the past few years, the New York State Department of Financial...more

Holland & Knight LLP

NYDFS Proposes Amendments to Cybersecurity Regulation

Holland & Knight LLP on

The New York Department of Financial Services (NYDFS) on Nov. 9, 2022, released Proposed Amendments to its Cybersecurity Regulation. The NYDFS Cybersecurity Regulation was one of the first laws requiring companies to comply...more

K2 Integrity

Using Sanctions Screening and List Management to Support a Stable Sanctions Compliance Framework

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A robust sanctions compliance program is a key part of financial crimes compliance programs for financial institutions as well as businesses engaged in global commerce. Failure to establish or effectively implement such a...more

Ballard Spahr LLP

FFIEC Issues Joint Statement on Additional Loan Accommodations Related to COVID-19

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On August 3, 2020, the Federal Financial Institutions Examination Council (“FFIEC”) issued a joint statement to provide prudent risk management and consumer protection principles for financial institutions to consider when...more

Morgan Lewis - All Things FinReg

Financial Institutions Encouraged to Consider Additional Options for Consumer and Commercial Borrower Accommodations

The Federal Financial Institutions Examination Council (FFIEC) on behalf of its members issued a statement on August 3 setting forth prudent risk management and consumer protection principles for financial institutions as...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

Moore & Van Allen PLLC

OCC Releases Bulletin on Fraud Risk Management Principles

In the aftermath of sales practices, the Office of the Comptroller of the Currency (OCC) recently published a bulletin on fraud risk management principles that are applicable to all federally chartered financial institutions....more

Orrick, Herrington & Sutcliffe LLP

Antiriciclaggio: Banca d'Italia emana le nuove disposizioni su organizzazione, procedure e controlli interni

Banca d'Italia, con il Provvedimento del 26 marzo 2019, ha emanato le nuove "Disposizioni in materia di organizzazione, procedure e controlli interni volti a prevenire l'utilizzo degli intermediari a fini di riciclaggio e di...more

Ballard Spahr LLP

Practical Tips for Ensuring Your AML Program Withstands the Scrutiny of Regulators

Ballard Spahr LLP on

First Post in a Two-Part Series - How do financial institutions get in trouble with their regulators? Recent AML enforcement actions suggest that the following two failures are at the heart of most of these actions: (1)...more

Ballard Spahr LLP

Ninth Circuit Court of Appeals Outlines BSA Compliance Obligations and How One Small Bank Failed to Meet Them

Ballard Spahr LLP on

The Tale of an AML BSA Exam Gone Wrong - As we have blogged, the Ninth Circuit Court of Appeals recently upheld the decision of the Board of Directors of the Federal Deposit Insurance Corporation (“FDIC”) to issue a cease...more

Patterson Belknap Webb & Tyler LLP

The DFS Effect: Cyber Meets Sarbanes Oxley

Financial institutions with ties to New York spent their Valentine’s Day learning how to use the New York State Department of Financial Services (DFS) web portal....more

Ruder Ware

Examiners are Carefully Scrutinizing Financial Institutions’ Compensation Arrangements

Ruder Ware on

It has come to our attention that some examiners have recently been carefully scrutinizing financial institutions’ employee compensation arrangements. Although it now appears unlikely that the proposed Dodd-Frank rules on...more

Proskauer - Corporate Defense and Disputes

Proposed AML Regulations for Registered Investment Advisers Released by FinCEN

On August 25, 2015, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) released proposed rules that would require investment advisers that are registered or required to be registered (RIAs)...more

Latham & Watkins LLP

Financial Industry Compliance: Enforcement Challenges in the US and Europe

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“If you look at the landscape pre-financial crisis, i.e. in 2006-2007, compliance looked very different than it does now,” said Latham & Watkins partner Dr. Finn Zeidler. “In the meantime, compliance in the financial services...more

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