On September 29, the Financial Crimes Enforcement Network (“FinCEN”) entered into a consent order with Shinhan Bank America (“SHBA”), which imposed a $15 million dollar civil penalty against SHBA for allegedly willfully...more
10/10/2023
/ Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Consent Order ,
Enforcement Actions ,
Failure To Implement ,
Failure-to-File ,
FDIC ,
Financial Crimes ,
Financial Institutions ,
FinCEN ,
Money Laundering ,
Public Corruption ,
Suspicious Activity Reports (SARs) ,
Transaction Monitoring
California continues to be at vanguard of data privacy rights. The latest effort by California legislators to protect consumer privacy rights focuses on data brokers, who under the proposed California Senate Bill 362, aka...more
8/23/2023
/ California ,
California Consumer Privacy Act (CCPA) ,
California Privacy Protection Agency (CPPA) ,
Consumer Privacy Rights ,
Data Brokers ,
Data Privacy ,
Do Not Sell ,
Fair Credit Reporting Act (FCRA) ,
Opt-Outs ,
Personal Information ,
Right to Delete ,
Third-Party
On July 26, the Department of Commerce, the Department of the Treasury, and the Department of Justice released a joint compliance notice (the “Compliance Notice”) updating and summarizing each agency’s position regarding the...more
8/3/2023
/ Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Department of Justice (DOJ) ,
Departments of Commerce ,
Economic Sanctions ,
Export Controls ,
FinCEN ,
National Security ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
Self-Disclosure Requirements ,
U.S. Treasury ,
Voluntary Disclosure ,
Whistleblowers
On April 24, the Governor of Kansas signed into law Kansas Senate Bill 44, which enacts the Financial Institutions Information Security Act (the “Act”). The Act requires credit services organizations, mortgage companies,...more
On April 12, North Dakota Governor Doug Burgum signed into law House Bill 1068, which creates a new statutory licensing scheme in North Dakota covering residential mortgage loan servicing activities. This follows on the heels...more
First of Two Blog Posts in a Series Pertaining to Attorneys Convicted of Money Laundering -
In February, we blogged on the indictment of Vladimir Voronchenko (“Voronchenko”) in the Southern District of New York (“SDNY”),...more
On April 12, North Dakota Governor Doug Burgum signed into law House Bill 1068, which creates a new statutory licensing scheme in North Dakota covering residential mortgage loan servicing activities. This follows on the...more
On April 17, the NYDFS announced the adoption of final regulations intended to shift the cost of supervision and examination of BitLicensees from the NYDFS via the implementation of direct assessments to licensees. The new...more
On April 6, 2023, the U.S. Department of the Treasury released a report examining vulnerabilities in decentralized finance (“DeFi”), including potential gaps in the United States’ anti-money laundering (“AML”) and countering...more
On April 3, 2023, the Conference of State Bank Supervisors (CSBS) released an update on the status of its State Examination System (SES). The SES is an examination system that is intended, in part, to foster standardization...more
On April 11, 2023, the Consumer Financial Protection Bureau Director Rohit Chopra spoke with the Washington Post regarding the banking industry after the failure of Silicon Valley Bank. Director Chopra, who is also a board...more
On March 29th, Iowa Governor Kim Reynolds signed Senate Bill 262 into law, making Iowa only the 6th U.S. state to enact a Consumer Data Privacy Rights Law. ...more
4/3/2023
/ Consumer Privacy Rights ,
Cybersecurity ,
Data Collection ,
Data Privacy ,
Data Protection ,
Data Security ,
New Legislation ,
Personal Information ,
Regulatory Reform ,
State Data Breach Notification Statutes ,
State Data Privacy Laws
On March 15, 2023, the Iowa House passed Senate Bill 262 on a 97-0 vote. The Bill had previously passed the Iowa Senate on March 6, 2023. If ultimately signed by Iowa Governor Kim Reynolds, Iowa would join California,...more
On March 8, 2023, the U.K. Secretary of State for Science for Innovation and Technology announced the publication of the Data Protection and Digital Information (No.2) Bill. This new version of the Data Protection and Digital...more
On February 24, 2023, the California Department of Financial Protection and Innovation (“DFPI”) released a Notice containing modifications to previously proposed regulations addressing the Consumer Financial Protection Law...more
Alleged Evasion Through a Law Firm Account and High-End Real Estate -
On February 7, 2023, the U.S. Attorney’s Office for the Southern District of New York announced the unsealing of an indictment charging Vladimir...more
Many privacy professional may have missed it, but In the run-up to the New Year — while many U.S. companies were focused on complying with the California Privacy Rights Act (CPRA) — Congress passed an appropriations bill that...more
On January 23, 2023, the New York Department of Financial Services released guidance with the stated goal of helping to protect customers of virtual currency businesses in the event of an insolvency or similar proceeding by...more
2022 proved to be an historic year for privacy and data security. Connecticut and Utah joined the list of states that have now passed comprehensive data privacy laws, bringing the total to five (5) states. For the first...more
On September 9, 2022, the California Department of Financial Protection and Innovation (DFPI) proposed to amend its student loan servicing regulations, which we previously covered here. After reviewing public comments, on...more
On December 22, 2022, France’s National Commission for Technology and Freedoms (“CNIL”) fined Microsoft’s Irish subsidiary 60 million euro for failure to comply with Article 82 of the French Data Protection Law (known as the...more
On December 15, 2022, the New York Department of Financial Services (“NYDFS”) published an Industry Letter detailing the Department’s guidance regarding banking organizations that wish to engage in virtual currency-related...more
The New York state legislature is currently considering a pair of companion bills which would impose detailed notice and records requirements upon student loan servicers. New York Senate bill S5136B, which was passed by the...more
On December 12, 2022, the CFPB released a proposed rule that would require certain “covered nonbanks” to register with and submit information to the CFPB when they become subject to certain orders from local, state, or...more
On December 22, 2021, New York State Senate Bill 2767A was signed into law. The Bill establishes the Private Student Loan Refinancing Task Force (the “Task Force”), which was charged with “study[ing] and analyz[ing] ways...more