On September 17, 2024, the Federal Deposit Insurance Corporation (FDIC) issued a proposed rule (the “Proposed Rule”) intended to strengthen recordkeeping for banks that partner with third-party, non-bank companies to accept...more
On July 25, 2024, the Federal Reserve Board, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation (collectively, the “Agencies”) issued a joint statement to banks regarding risks...more
8/6/2024
/ AML/CFT ,
Bank Deposits ,
Deposit Insurance ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Financial Services Industry ,
FinTech ,
Joint Statements ,
OCC ,
Request For Information ,
Risk Management ,
Third-Party Relationships
On July 18, 2024, the Consumer Financial Protection Bureau (CFPB) issued a proposed interpretive rule on earned wage access (EWA) products (“Proposed Interpretive Rule”) that, if finalized, would clarify that EWA products are...more
On May 16, 2024, the U.S. Department of Justice (DOJ) announced a plan to reschedule marijuana under the Controlled Substances Act (CSA) from a schedule I to a schedule III controlled substance. The Attorney General and the...more
7/24/2024
/ Anti-Money Laundering ,
Banking Acts ,
Controlled Substances Act ,
DEA ,
Decriminalization of Marijuana ,
Department of Health and Human Services (HHS) ,
Department of Justice (DOJ) ,
FinCEN ,
Internal Revenue Code (IRC) ,
Marijuana ,
Proposed Rules
The digital age has ushered in innovative forms of entertainment and commerce, including through the development of in-game economies. In recent years, the digital landscape of gaming has expanded beyond mere entertainment,...more
7/10/2024
/ Anti-Money Laundering ,
App Developers ,
Bank Secrecy Act ,
Consumer Financial Protection Bureau (CFPB) ,
Contractual Safeguards ,
Convertible Virtual Currencies (CVCs) ,
Digital Media ,
EULA ,
FinCEN ,
In-Game Purchases ,
Intellectual Property Protection ,
Limitation of Liability Clause ,
Money Transmission Act ,
Non-Fungible Tokens (NFTs) ,
Online Gaming ,
Terms of Service ,
Virtual Currency ,
Virtual Goods
On April 4, 2024, the Consumer Financial Protection Bureau (CFPB) issued a report on “Banking in video games and virtual worlds” (Report). The Report focuses on the movement of money in virtual worlds and how gamer data is...more
4/15/2024
/ AML/CFT ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
FinCEN ,
Fraud ,
Online Gaming ,
Online Marketplace ,
Scams ,
Third-Party ,
Video Games ,
Virtual Reality