On September 17, 2020, the Financial Crimes Enforcement Network ("FinCEN") published an Advance Notice of Proposed Rulemaking ("Notice") to obtain public comments on proposed enhancements to anti-money laundering ("AML")...more
On July 22, 2020, the Office of the Comptroller of the Currency (“OCC”) published an Interpretive Letter (the “Letter”) declaring that national banks and federal savings associations (collectively, “national banks”) may...more
7/27/2020
/ Blockchain ,
Cryptoassets ,
Cryptocurrency ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Institutions ,
Financial Services Industry ,
International Banks ,
OCC ,
Recordkeeping Requirements ,
Securities and Exchange Commission (SEC) ,
Securities Regulation
On June 24, 2020, the New York Department of Financial Services (the "NYDFS") announced it is considering a proposal to issue conditional licenses (a "Conditional License") for companies to begin virtual currency activities...more
On March 17, 2020, the governor of Hawaii announced a program between the Hawaii Department of Commerce and Community Affairs, the Division of Financial Institutions (“DFI”) and the Hawaii Technology Development Corporation....more
The FFIEC has updated its BSA/AML manual effective May 5, 2018, to add a section on the new legal entity due diligence requirements and to update the section of the manual on customer due diligence generally. The Fed...more
5/17/2018
/ Anti-Money Laundering ,
Banking Sector ,
Beneficial Owner ,
BSA/AML ,
Customer Due Diligence (CDD) ,
Examination Procedures ,
FFIEC ,
Financial Institutions ,
Policies and Procedures ,
Recordkeeping Requirements ,
Regulatory Requirements ,
Reporting Requirements
On March 5, 2018, the Fed’s new Vice Chairman for Supervision, Randal Quarles, spoke at the Institute of International Bankers annual conference. He wanted to express his thoughts on the appropriate regulatory environment for...more
On February 2, 2018, the Fed announced that it issued a consent Cease and Desist order with Wells Fargo—the bank holding company. The Fed’s press release noted that Wells is replacing 4 directors within this year (out of 17...more
2/6/2018
/ Bank Holding Company ,
Banking Sector ,
Banks ,
Board of Directors ,
Cease and Desist Orders ,
Federal Reserve ,
Financial Institutions ,
Regulation YY ,
Risk Management ,
Senior Managers ,
Wells Fargo
For the first time in my memory, the Congress passed a joint resolution to disapprove a final regulation of a federal agency—in this case the CFPB and the rule was related to arbitration clauses in contracts for consumer...more
12/8/2017
/ Banking Sector ,
Community Reinvestment Act ,
Consumer Financial Protection Bureau (CFPB) ,
CRA ,
Credit Unions ,
Cuba ,
Dodd-Frank ,
EU ,
FDIC ,
Final Rules ,
Financial Institutions ,
Mortgage Servicers ,
NCUA ,
OCC ,
Office of Foreign Assets Control (OFAC) ,
Qualified Financial Contracts (QFC) ,
RESPA ,
Sanctions ,
Truth in Lending Act (TILA)
Yesterday the Fed published a proposed guidance document for its expectations for board of directors of banks. The release only applies to the boards of banks with over $50 billion in consolidated assets, but the intent of...more