Dually registered, or “dual hat,” investment advisers are already well aware of the extensive obligations imposed by the Bank Secrecy Act (“BSA”). But for others, the finalization of a Financial Crimes Enforcement Network...more
In a sequel to FinCEN’s proposal earlier this year to extend anti-money laundering and Bank Secrecy Act regulations to investment advisers (AML/BSA Proposal), on May 13, 2024, FinCEN and the SEC jointly issued a new Notice of...more
5/20/2024
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Broker-Dealer ,
Customer Identification Program (CIP) ,
Financial Institutions ,
Financial Regulatory Reform ,
FinCEN ,
Investment Adviser ,
NPRM ,
Popular ,
Reporting Requirements ,
Securities and Exchange Commission (SEC) ,
Suspicious Activity Reports (SARs)
As consumer-facing financial institutions of all types—from well-established banks to newly-launched fintechs—set their 2024 regulatory compliance goals, they may wonder if their New Year’s resolutions align with those that...more
1/12/2024
/ Anti-Money Laundering ,
Beneficial Owner ,
Compliance ,
Consumer Financial Protection Bureau (CFPB) ,
Cybersecurity ,
Due Diligence ,
Enforcement Actions ,
FDIC ,
Federal Reserve ,
Federal Trade Commission (FTC) ,
Financial Institutions ,
FinCEN ,
Governance Standards ,
NYDFS ,
OCC ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Regulatory Agenda ,
Remediation ,
Self-Reporting ,
Third-Party ,
UDAAP
With the start of the new year, FinCEN’s Beneficial Ownership Reporting Rule (BOI Reporting Rule) came into effect, implementing specific transparency requirements relating to corporate ownership. The BOI Reporting Rule...more
In 2017, the New York Department of Financial Services (“NYDFS”) enacted a landmark regulation requiring financial services institutions such as banks and insurance companies in the state to meet substantial cybersecurity...more
11/8/2023
/ Banking Sector ,
Covered Entities ,
Cybersecurity ,
Cybersecurity Framework ,
Data Protection ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
NYDFS ,
Regulatory Agenda ,
Regulatory Reform ,
Regulatory Requirements ,
Risk Management
Last week, the Consumer Financial Protection Bureau issued its long-awaited proposed rule to implement Section 1033 of the 2010 Consumer Financial Protection Act, which has come to be known as the “open banking” provision...more
Shinhan Bank America (“Shinhan”), a New York-based subsidiary of a Korean bank, faced coordinated enforcement actions on September 29 from the Financial Crimes Enforcement Network (“FinCEN”), Federal Deposit Insurance...more
10/12/2023
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Cryptoassets ,
Cryptocurrency ,
Enforcement Actions ,
FDIC ,
Financial Institutions ,
FinCEN ,
FinTech ,
New York ,
NYDFS
On June 6, 2023, federal banking agencies issued final Interagency Guidelines on Third-Party Relationships detailing their expectations for banks in establishing risk management practices with third-parties—including...more
6/16/2023
/ Banking Sector ,
Banks ,
Cryptoassets ,
Cryptocurrency ,
FDIC ,
Financial Institutions ,
Financial Services Industry ,
FinTech ,
New Guidance ,
OCC ,
Servicing Agreements ,
Third-Party