The FDIC proposed revisions last month to its existing policy on how it evaluates merger transactions that require the FDIC's approval under the Bank Merger Act (BMA). ...more
The OCC recently released a proposed rule and policy statement on business combinations involving national banks and federal savings associations (banks), which includes mergers, acquisitions of assets, and assumptions of...more
The FDIC has proposed guidelines that would establish corporate governance and risk management expectations for FDIC-regulated banks with $10 billion or more in total assets. The FDIC is doing so in a rulemaking under its...more
On August 8, 2023, the Federal Reserve released new guidance for supervised banking organizations on how they can engage in certain crypto-asset-related activities. With the release of the guidance, the Federal Reserve...more
On June 16, 2023, the Federal Deposit Insurance Corporation (FDIC) released an update to its Supervisory Guidance on Multiple Re-Presentment NSF Fees (FIL-40-2022) (the "Guidance"), to provide additional guidance for...more
A recent action by the Office of the Comptroller of the Currency (OCC) highlights how banks need to ensure that they have robust compliance programs for managing risks posed by their banking as a service (BaaS)...more
The California Department of Financial Protection and Innovation (DFPI) recently issued an invitation for comments on a proposed second rulemaking to implement aspects of California's Debt Collection Licensing Act (DCLA)...more
The Consumer Finance Protection Bureau ("CFPB") issued an advisory opinion warning debt collectors that they may be collecting illegal fees from consumer-borrowers. Specifically, the Bureau has interpreted Section 808(1) of...more
The Consumer Finance Protection Bureau ("CFPB") announced that it will examine nonbank financial companies that pose risks to consumers, using statutory authority that until now had gone unused. Additional examinations would...more
The week ending Saturday, April 9, 2022, witnessed a ramping up of U.S. and allied sanctions against Russia and the continuing evolution of U.S. enforcement activities against Russia in response to its invasion of Ukraine....more
4/13/2022
/ Asset Seizure ,
Biden Administration ,
Bureau of Industry and Security (BIS) ,
Darknet ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Executive Orders ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Ukraine ,
US State Departments
Over the past week, the international community's economic sanctions strategy - and enforcement of that strategy - has been taking shape. This strategy will continue to evolve as events dictate, and as illustrated by the...more
Now that the United States and its allies have deployed many of their available financial and trade weapons in support of Ukraine against Russia's invasion, what happens next? Perhaps more than any other U.S. sanctions...more
3/15/2022
/ Belarus ,
Bureau of Industry and Security (BIS) ,
CAATSA ,
Economic Sanctions ,
Enforcement ,
Enforcement Authority ,
Foreign Relations ,
Magnitsky Act ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Ukraine
This alert provides an overview of the general licenses and FAQs issued by the Office of Foreign Assets Control (OFAC) through March 4, 2022, and the expansion of the Specially Designated Nationals List on March 3, 2022....more
This alert provides an overview of U.S. sanctions imposed against Russia in response to its invasion of Ukraine up to and including the issuance of Directive 4 and General License 8A on Monday morning, February 28, 2022, and...more