On July 22, 2019, the five federal agencies tasked with the supervision, examination, and enforcement of Bank Secrecy Act (BSA) and anti-money laundering (AML) requirements for banks (the “Agencies”) issued a joint statement...more
The fireworks have started early this year. On May 2, a federal court in New York rejected the OCC’s motion to dismiss the lawsuit brought by the NY DFS challenging the OCC’s fintech charter. The decision has something for...more
6/18/2019
/ Appeals ,
Arbitration ,
BSA/AML ,
Consumer Financial Protection Bureau (CFPB) ,
Fair Lending ,
Financial Institutions ,
Financial Services Industry ,
FinTech ,
OCC ,
TCPA ,
UDAP
On May 9, 2019, the Financial Crimes Enforcement Network (“FinCEN”) issued a guidance, Application of FinCEN’s Regulations to Certain Business Models Involving Convertible Virtual Currencies (CVC) (“Guidance”), together with...more
On April 23, 2019, the Board of Governors of the Federal Reserve System (“Federal Reserve”) released a proposed rule (“Proposed Rule”) to revise regulations related to the determination of “control” under the Bank Holding...more
On April 18, 2019, the Financial Crimes Enforcement Network (“FinCEN”) issued a press release announcing a civil money penalty for violations of the Bank Secrecy Act’s (“BSA”) anti-money laundering (“AML”) compliance program...more
On April 8, 2019, the federal banking agencies (the “Agencies”) released two proposals (the “Tailoring Proposals”) which, if adopted, would further tailor the approach to supervision of large foreign banking organizations...more
The Federal Reserve and the FDIC published proposed changes to resolution plan (or “living will”) requirements applicable to U.S. and foreign banking organizations. The regulatory changes are necessary because the 2018...more
On December 3, 2018, the Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, Financial Crimes Enforcement Network (“FinCEN”), National Credit Union Administration, and Office of the...more
On October 31, 2018, the federal banking agencies released two separate proposals that, if adopted, would create a more consistent tiered approach to large bank supervision – in other words, supervision of banking...more
May 11, 2018 was the applicability date for FinCEN’s new “Customer Due Diligence Requirements for Financial Institutions” (the “CDD Rule”). FinCEN noted the occasion by issuing a press release to remind covered financial...more
On January 18, 2018, the Board of Governors of the Federal Reserve System (the “Federal Reserve Board”) announced the approval of proposed revisions to the Annual Report of Foreign Banking Organizations (“FR Y-7”). The...more