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Internal Controls Financial Institutions

BCLP

Personal Matters - How will the risks to firms from individuals’ behaviour increase in 2024?

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Financial regulators in the UK have been interested for some years in the question of how personal behaviour can affect the risk profile of a financial institution. A recent SEC case suggests that US regulators may now be...more

J.S. Held

INDEPTH FEATURE: Anti-Money Laundering 2024

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Could you provide an insight into recent trends shaping financial crime in your country of focus? How great a risk does money laundering in particular now pose to companies? One would likely never imagine compliance as...more

Womble Bond Dickinson

Navigating the Labyrinth: Artificial Intelligence in the Battle Against Trade-Based Money Laundering

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In the rapidly evolving financial landscape, governments worldwide are intensifying their focus on compliance in Know Your Customer (KYC) and Anti-Money Laundering (AML) efforts for financial institutions. Trade-Based Money...more

Mayer Brown

NYDFS Finalizes Climate Risk Management Guidance

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On December 21, 2023, the New York Department of Financial Services (“NYDFS”) finalized guidance on how the banks and mortgage institutions it regulates (“New York Institutions”) should manage climate-related financial and...more

Hudson Cook, LLP

New York DFS Finalizes Amendments to Cybersecurity Regulations

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On November 1, 2023 the New York Department of Financial Services ("DFS") released amended cybersecurity regulations ("Regulations"). These changes will impose additional controls, demand more frequent risk assessments, and...more

BakerHostetler

NYDFS Issues Revised Proposed Second Amendment to Its Cybersecurity Regulation

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The New York State Department of Financial Services (NYDFS) recently published a revised proposed second amendment to its cybersecurity regulation, 23 NYCRR 500. ...more

Walkers

Director exemptions: changes to AML obligations

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Introduction - Further to a recent update, in which the Government, in consultation with the Jersey Financial Services Commission ("JFSC"), announced its intention to make legislative changes to the anti-money laundering,...more

Cadwalader, Wickersham & Taft LLP

Basel Committee Issues Guidance on Core Principles for Effective Banking Supervision

In April 2022, the Basel Committee on Banking Supervision (the Basel Committee) began a review of “the core principles for effective banking supervision” (Core Principles or CP). Last month, the Basel Committee published...more

Latham & Watkins LLP

Acting Comptroller Confronts “Too Big to Manage” Issue

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The Acting Comptroller of the OCC discussed the limits of large bank manageability and the steps that regulators can take to address the risks posed by size and complexity. On January 17, 2023, Acting Comptroller of the...more

Latham & Watkins LLP

NYDFS Proposes Guidance on Climate Change Risk Management

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The Guidance would increase expectations for regulated financial institutions to identify, measure, monitor, and control climate-related financial risks. For the past few years, the New York State Department of Financial...more

Latham & Watkins LLP

FCA Issues Final Notice to Former Banking CEO Over Anti-Money Laundering Failures

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The case provides instructive practical examples of the “reasonable steps” companies can take according to the FCA and a reminder of the FCA’s cultural expectations of CEOs. On 16 November 2022, the FCA issued a final...more

Holland & Knight LLP

NYDFS Proposes Amendments to Cybersecurity Regulation

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The New York Department of Financial Services (NYDFS) on Nov. 9, 2022, released Proposed Amendments to its Cybersecurity Regulation. The NYDFS Cybersecurity Regulation was one of the first laws requiring companies to comply...more

Epiq

Planning for a Remediation: Proactive Considerations for Financial Institutions

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Financial institutions are more regularly dealing with voluntary remediations and public consent order activity due to heightened scrutiny by regulators and changing internal policies. These events can be complex and also...more

BCLP

NY DFS Cybersecurity Symposium: More Rigorous Rules, Exams and Enforcement Ahead

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The New York Department of Financial Services (“DFS”) is turning up the heat on cybersecurity once again. During its first-ever Cybersecurity Symposium on March 29, DFS announced a series of new measures that will require...more

Morgan Lewis - Tech & Sourcing

Sanctions Apply to Cryptoasset Sector Confirm UK Financial Regulatory

On March 11, 2022, the UK Financial Conduct Authority (FCA), the Bank of England, and the Office of Financial Sanctions Implementation (OFSI) released a joint statement reiterating that all UK financial services firms,...more

Orrick, Herrington & Sutcliffe LLP

Six Things to Know About FinCEN’s Proposed SAR Sharing Pilot Program

The Financial Crimes Enforcement Network (“FinCEN”) published a notice of proposed rulemaking (the “Proposed Rule”) in late January seeking public comment on a proposed pilot program that would expand financial institutions’...more

Holland & Knight LLP

FinCEN Announces Proposed Regulations for Sharing of Suspicious Activity Reports

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The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) released proposed regulations on Jan. 24, 2022, for implementing a pilot program allowing financial institutions to share suspicious activity...more

K2 Integrity

Treasury Releases Guidance for the Virtual Currency Industry and Analysis on Ransomware Trends

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Office of Foreign Assets Control (OFAC) released detailed sanctions compliance guidance for the virtual currency industry (the Guidance). The Guidance provides an overview of OFAC sanctions requirements and lists several best...more

Kaufman & Canoles

Credit Union Client Alert – Wells Fargo Must Pay $250 Million Fine

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The Office of the Comptroller of the Currency (OCC) issued a $250 million civil penalty against Wells Fargo Bank, NA for flaws in the bank’s home loan loss mitigation program. In addition, the OCC issued a cease-and-desist...more

Skadden, Arps, Slate, Meagher & Flom LLP

FinCEN Sets Out Anti-Money Laundering Priorities, With Implementing Regulations To Follow

On June 30, 2021, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued its first government-wide priorities (Priorities) for combatting money laundering and the financing of terrorism.1...more

K2 Integrity

Using Sanctions Screening and List Management to Support a Stable Sanctions Compliance Framework

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A robust sanctions compliance program is a key part of financial crimes compliance programs for financial institutions as well as businesses engaged in global commerce. Failure to establish or effectively implement such a...more

Foodman CPAs & Advisors

Forensic Accountants augment a Financial Institution’s Corporate Governance Program

A financial institution’s understanding and management of financial crimes and their genesis would enhance and strengthen its Corporate Governance programs and internal controls.  ...more

Goodwin

CFPB To Revisit Trump-Era QM Final Rules

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In this Issue. The Consumer Financial Protection Bureau (CFPB) issued a statement announcing its intention to revisit Trump-era qualified mortgage (QM) final rules; the Biden Administration announced changes to the Small...more

White & Case LLP

Spain to tax acquisitions of shares of major Spanish listed companies

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The Spanish Official Gazette published last October 16th legislation enacting a new indirect Tax on Financial Transactions levied, at 0.2%, on the acquisition of shares of major Spanish listed companies irrespective of the...more

Ballard Spahr LLP

Federal banking agencies issue joint statement on enforcement of BSA/AML requirements; FinCEN follows with its own statement

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Regulators Provide Greater Transparency into BSA/AML Enforcement Process. On August 13, 2020, the Federal Reserve System, Federal Deposit Insurance Corporation, National Credit Union Administration, and Office of the...more

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