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Russia Sanctions Evasion and Commercial Real Estate: An Alert

On January 25, the Financial Crimes Enforcement Network (“FinCEN”) issued an “Alert on Potential U.S. Commercial Real Estate Investments by Sanctioned Russian Elites, Oligarchs, and Their Proxies” (the “Alert”). The Alert...more

Study of Illinois 36% interest rate cap finds reduced access to credit

Over the past few years, numerous states have imposed interest rate caps on  consumer credit.  In recent blog posts, we discussed the efforts of both Michigan and New Mexico to impose a 36% annual interest rate cap.  Last...more

SDNY Sentences Danske Bank in Massive AML Scandal

Factual Statement Is a Tale of Whistleblowing, High-Risk Customers, and Misleading U.S. Banks - Earlier this month, Danske Bank was sentenced in the Southern District of New York to three years of probation and forfeiture...more

FDIC Updates Enforcement Manual for Cease-and-Desist Actions

On July 25, 2022, the FDIC issued Financial Institution Letter (FIL)-34-2022 announcing updates to Chapters 1 and 4 of its Formal and Informal Enforcement Actions Manual (Manual). The Manual includes updates to the minimum...more

FinCEN and Federal Functional Regulators Issue Coded Warnings Against De-Risking

OOn July 6, the Financial Crimes Enforcement Network (“FinCEN”), The Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of the...more

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