Making Cents of Your Cash Management Agreements
Day 17 of One Month to More Effective Compliance for Business Ventures- Corporate Controller and Business Ventures
On April 6, 2026, the United States Court of Appeals for the Second Circuit will hear oral argument in The People of the State of New York v. Citibank, N.A., Case No. 25-2105 (the “New York Case”), which presents a question...more
On March 10th, the FBI issued an alert warning of an emerging scheme whereby criminals impersonating city and county officials solicit fraudulent payments for city / county planning and zoning permits....more
The latest edition of the Payments Docket, our roundup of key litigation and enforcement involving the payments industry, features the CFPB proposing to limit its own authority, one bank with two interest rates, and fraud...more
For years, courts faced with the question of who is liable for unauthorized wire transfers have turned to the familiar provisions of Article 4A of the Uniform Commercial Code (“UCC”)....more
October is Cybersecurity Awareness Month, the perfect time to provide some common-sense tips to avoid a common risk facing businesses: business email compromise and wire fraud. Businesses of all shapes and sizes use email,...more
On September 17, the U.S. Court of Appeals for the 2nd Circuit granted a national bank’s request for interlocutory appeal in a case brought by the New York attorney general regarding the bank’s response to incidents of online...more
After a long weekend, Finance Manager Joe sits at his desk to read his emails. One of the emails is from a trusted vendor with whom the Joe communicates on a regular basis, regarding an unpaid invoice that is due immediately....more
Due to the Federal Reserve’s imminent shift to a new funds wiring system (known as ISO 20022), if you have upcoming plans to transfer any amount of funds via wire transfer, confirm with your bank and anyone else handling your...more
On March 26, 2025, the U.S. Court of Appeals for the Fourth Circuit issued an important decision addressing a depository institution’s liability for wire transfer losses resulting from a business email compromise scam....more
The explosive finale of White Lotus Season 3 left fans with more than just plot twists—it raised fascinating legal and tax questions. Chief among them: what are the implications of Greg’s $5 million wire transfer to Belinda,...more
On April 22, the U.S. SDNY granted a bank’s motion for interlocutory appeal and stay pending appeal to the U.S. Court of Appeals for the Second Circuit in a case involving alleged violations of the EFTA. The case stemmed from...more
Following a brief pause under new leadership, the Consumer Financial Protection Bureau (CFPB) has resumed activities, albeit significantly in retreat from the positions taken by the prior administration. In a case involving...more
On Tuesday, March 25, 2025, the Consumer Financial Protection Bureau (CFPB or Bureau) filed a motion in a suit brought by the New York attorney general against a major national bank seeking to withdraw a Statement of Interest...more
On March 26, the U.S. Court of Appeals for the Fourth Circuit reversed a district court’s decision holding a credit union liable for a wire transfer in a business email compromise scam case where the credit union lacked...more
Back The Blue Act - This week, the Alabama House of Representatives passed the Back the Blue Protection Act, sponsored by Representative Rex Reynolds and Senator Lance Bell, which aims to expand legal immunity for law...more
As anticipated, 2025 is already shaping up to be a busy year in consumer financial services, with a federal district court expanding the application of a strict consumer protection law to wire transfers. The potential for a...more
In an apparent departure from decades of jurisprudence acknowledging the exemption of wire transfers from the ambit of the Electronic Funds Transfer Act (EFTA or the Act), one federal district court recently found that a bank...more
A recent cyberattack on a Michigan township has exposed weaknesses in the bond-closing process. In this incident, hackers stole over $25 million in bond proceeds by using spoofed email addresses to provide fraudulent wire...more
A recent court order issued in New York should concern any financial institutions that allow consumers to initiate wire transfers online. Financial institutions that allow consumers to execute wire transfers online should...more
On November 27, 2023, the U.S. Court of Appeals for the Second Circuit revived some of a bankruptcy litigation trustee’s fraudulent transfer claims stemming from the leveraged buyout of apparel retailer Nine West. The lawsuit...more
On November 12, the Fed’s Christopher Waller addressed a conference in New York City, discussing the roles of the private sector and the Fed in the payments ecosystem. Waller emphasized that while the private sector is...more
On November 8, 2024, the California Privacy Protection Agency (CPPA) Board voted to adopt new regulations for data broker registration requirements. The CPPA Board also voted to advance proposed rules for insurance companies,...more
North Korea Sanctions Violations - In a recent enforcement action, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) imposed an $860,000 penalty on Vietnam Beverage Company Limited (“VBCL”), a...more
Business email compromise (“BEC”) occurs when a payee’s business email account is compromised or impersonated. The threat actor, posing as the payee or its representative (e.g., the head of the accounting department), sends...more
On 4 July 2024, the European Banking Authority (EBA) published new guidelines on information requirements in relation to transfers of funds and certain cryptoasset transfers under Regulation (EU) 2023/1113 (the recast,...more