Colorado has passed a law that amends the Colorado Uniform Consumer Credit Code (UCCC) to extend state interest rate limits on certain consumer loans made by out-of-state state-chartered banks, which caps rates at a maximum...more
On March 27, Colorado legislators introduced a bill (H.B. 1229) to opt out of federal banking laws that permit federally insured state chartered banks and credit unions to charge Colorado residents the “interest” permitted...more
The current expectation is that the European Commission will issue the new SCCs in two weeks’ time (though this could be subject to delay). On 12 November 2020, the European Commission published a revised set of draft...more
California has become the latest state to create its own mini Consumer Financial Protection Bureau (CFPB). As part of the 2020-21 budget, Governor Gavin Newsom set in motion a reorganization and significant expansion of the...more
The Treasury Department’s Office of Foreign Asset Control (OFAC) has promised to issue guidance on effective sanctions compliance programs. This is a long-anticipated update to prior information OFAC has released on the same...more
UK-based Standard Chartered Bank (“SCB”) announced the terms of significant settlements last week with various U.S. and U.K. governmental agencies, resolving a series of related investigations into the bank’s alleged...more
Standard Chartered Bank certainly has its troubles. You know a company is in trouble, however, when it breathes a sigh of relief after paying nearly $1.1 billion in fines and penalties and compares itself to BNP Paribas, the...more
Global banks are the poster children of sanctions violations and the importance of trade compliance. At the top of the heap is Standard Chartered Bank....more
Kraft Heinz dropped a double-whammy on investors on Thursday, announcing a $15 billion charge against its Kraft and Oscar Mayer brands and revealing news of an SEC subpoena related to the company’s accounting practices....more
Though expected after its earlier move to cut its revenue forecast, Apple’s official quarterly profits reporting yesterday still disappointed, as the company posted its “first holiday-quarter drop in both revenue and profit...more
I wish I had some better news for you heading into Christmas, but Wall Street was not in the holiday spirit, with all major indices diving another 2% or so on Thursday....more
We learned yesterday that Twitter’s shopping itself around for a buyer. It’s facing one big complication, though—the sizeable amount of stock Twitter has doled out to its employees over the years. Last year, for example,...more
Wyatt Earp died this week. Not the original Wyatt Earp who died in 1929 but the Wyatt Earp of my lifetime, who was actor Hugh O’Brian. O’Brien portrayed Earp in the long running television series Wyatt Earp which ran in the...more
Chen brings important industry experience to the role. The Department of Justice (DOJ) Fraud Section has retained Hui Chen as a “full-time compliance expert.” Ms. Chen comes to the position with compliance counseling...more
For the second time in two years, Benjamin Lawsky, the Superintendent of the New York State Department of Financial Services (DFS), has settled another matter with Standard Chartered Bank for alleged “anti-money laundering...more
The above lyrics are the closing stanza to the song “Ghost Riders in the Sky”. I thought about the advice for the cowboy to change his ways to save his soul from Hell when I read in both the Financial Times (FT) and the Wall...more
What is your compliance process? I thought about that question when I read an article in this month’s National Geographic Magazine entitled “Maxed Out on Everest” by Mark Jenkins....more
Taken to the woodshed or when should a company have to eat its own words? Remember when President Reagan’s Director of the Office of Management and Budget, David Stockman, was ‘taken to the woodshed’ by White House Chief of...more
Recently, Standard Chartered Bank (SCB) was in the news again for stripping original wire details so that payments would go undetected by the U.S. Department of Treasury's Office of Foreign Assets Control (OFAC)....more