Consumer Finance Monitor Podcast Episode: Regulators Escalate Focus on the Risks of Bank Relationships with Fintechs and Other Third Parties
2024 State Legislative Review: Key Payment Laws and Their Impacts — Payments Pros – The Payments Law Podcast
First Republic Executives Fail in Attempt to Recover Nonqualified Deferred Compensation Plan Assets
The Future of Bank-Fintech Partnerships and Banking as a Service — The Consumer Finance Podcast
In That Case: Cantero v. Bank of America
Navigating Bank-Fintech Partnerships: Avoiding Common Pitfalls — The Consumer Finance Podcast
Revisiting Financial Institution Incentive Compensation Rules Under Dodd-Frank — The Consumer Finance Podcast
Redlining Complications Caused by Implementation of 2020 Census Tracts
U.S. District Court Addresses Federal Preemption for State Credit Reporting Laws
How to estimate how your performance will look under the new CRA
Instant Decline, Instant Relief? Unpacking the CFPB's Proposed Rule on NSF Fees — Payments Pros: The Payments Law Podcast
Fintech Focus Podcast | Are Regulators Dictating Fintech Deal Terms?
The Coming Perfect Storm
2023 Payments Year in Review: CFPB and FTC Regulatory Trends — Payments Pros – The Payments Law Podcast
Year in Review and a Look Ahead: Fintech Developments — The Consumer Finance Podcast
The CFPB Targets Data Brokers with Latest Proposed Rule
State Laws on Screening and Federal Preemption – Where Are We Now and Where Are We Heading? — FCRA Focus Podcast
Redefining Banking: A Conversation on the CFPB's Proposed 1033 Rule — Payments Pros: The Payments Law Podcast
Garnishment Practices: Has the Dust Settled or Is It Still Flying? — The Consumer Finance Podcast
The Importance of Assessment Areas
Das Europäische Parlament hat am 24. April 2024 ein neues Gesetzespaket zur Geldwäschebekämpfung verabschiedet, welches das Instrumentarium der EU zur Bekämpfung von Geldwäsche und Terrorismusfinanzierung stärken soll....more
Hosted by the Canadian Institute, the 23rd Annual Canadian Forum on Anti-Money Laundering and Financial Crime returns for another exciting year. The event features carefully curated programming providing practical guidance...more
Most privately held domestic and foreign companies doing business in the United States must now report beneficial ownership information (BOI) to the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN)...more
On December 21, 2023, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule (Access Rule) regarding access to the beneficial ownership information (BOI) reported to FinCEN...more
As described in DWT's October 2021 post, the Corporate Transparency Act ("CTA"), enacted as part of the Anti-Money Laundering Act of 2020, establishes beneficial ownership reporting requirements for a broad range of entities...more
On December 1, 2021, we issued a client alert summarizing the Corporate Transparency Act (CTA), a federal law passed to fight “shell company” money laundering, tax fraud, and other financial crimes. The CTA provides for rules...more
In This Issue. The Federal Reserve Board of Governors (Federal Reserve), the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) released stress test scenarios to assess...more
In This Issue. The U.S. Securities and Exchange Commission (SEC) proposed changes to private fund regulation; the Office of the Comptroller of the Currency (OCC) succeeded in validating its “valid-when-made” rulemaking; the...more
In this Issue. The Office of the Comptroller of the Currency (OCC) is seeking feedback on principles for climate-related financial risk management for large banks; the Department of Justice’s Antitrust Division is seeking...more
In January of 2021, the Anti-Money Laundering Act of 2020 (AMLA) went into effect, marking the most significant changes to federal anti-money laundering laws since the USA Patriot Act of 2001. The AMLA represents an attempt...more
In This Issue. The Financial Crimes Enforcement Network (FinCEN) announced (1) a notice of proposed rulemaking for beneficial ownership information reporting requirements and (2) a regulatory process for new real estate...more
The Corporate Transparency Act (“CTA”) was enacted as part of the Anti-Money Laundering Act of 2020. The purpose of the CTA is to deter anonymous owners of corporations, limited liability companies, and other entities from...more
2020 witnessed a flurry of anti-money laundering activity, with the issues and developments continuing to be global in scope. In the United States, suspicious activity reports, outlining transactions involving terrorism...more
On 1 January 2021, Congress overrode President Trump’s veto of the National Defense Authorization Act (the NDAA). As part of the NDAA, Congress included long-considered provisions with the potential to revolutionize...more
A bipartisan group of Senators, with the support of the American Bankers Association, recently introduced bill S.2563, known as the ILLICIT Cash Act. The acronym “ILLICIT” stands for “Improving Laundering Laws and Increasing...more
The Department of Justice (“DOJ”) has secured its first conviction ever under the Foreign Account Tax Compliance Act, or FATCA, through the guilty plea of Adrian Baron, a former executive of Loyal Bank Ltd., a bank with...more
A GTO is a Geographic Targeting Order issued by the Financial Crimes Enforcement Network (FinCEN) under the Bank secrecy Act (BSA) for a specific geographic area. ...more
The U.S. Financial Crimes Enforcement Network announced that it was granting a 90-day exception from compliance with the beneficial ownership requirements under its Customer Due Diligence Requirements for Financial...more
The U.S. Board of Governors of the Federal Reserve System, U.S. Office of the Comptroller of the Currency, and U.S. Federal Deposit Insurance Corporation published the customer due diligence and beneficial ownership...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
Covered Financial Institutions (CFI) have until May 11, 2018 to implement and comply with the Financial Crimes Enforcement Network (FinCEN) Final Customer Due Diligence Rule (the CDD Rule). The CDD Rule imposes a new...more
Financial institutions face an important deadline – May 11, 2018 is the effective date for the new customer due diligence regulations governing beneficial ownership requirements. FinCEN provided financial institutions nearly...more
There is a new Bill drafted on November 14, 2017 called the Counter Terrorism and Illicit Finance Act (CTIFA). The Bill is currently in a committee in the Senate and it proposes a substantial overhaul to the Bank Secrecy Act...more
There seems to be a convergence by the Financial Crimes Enforcement Networks (FinCEN), the Treasury Department and the IRS for determining “who is the UBO” of entities. The U.S. Government is determined to enforce financial...more
Second of a Two-Part Blog: Anti-Money Laundering Programs Coming to the Legal Profession? Earlier this week, we began our discussion of the proposed Corporate Transparency Act of 2017 (the “Act”), and observed that, if...more