On May 7, 2025, the Office of the Comptroller of the Currency (“OCC”) issued Interpretative Letter 1184 (“IL 1184”) confirming that national banks and federal savings associations may provide cryptocurrency custody...more
5/20/2025
/ Banks ,
Cryptocurrency ,
Digital Assets ,
Financial Institutions ,
Financial Regulatory Reform ,
FinTech ,
New Guidance ,
OCC ,
Regulatory Authority ,
Regulatory Requirements ,
Trump Administration
On March 28, 2025, the Internal Revenue Service (“IRS”)’s criminal investigative arm, IRS Criminal Investigation (“IRS-CI”), announced that it would be implementing a new program called CI-FIRST (Feedback in Response to...more
Millions of reporting companies breathed a sigh of relief on March 21, 2025, when the US Financial Crimes Enforcement Network (“FinCEN”) issued an interim final rule (the “IFR”) that exempted all domestic entities from...more
On March 28, 2025, the Federal Deposit Insurance Corporation (FDIC) issued guidance on state nonmember bank and state savings association participation in certain cryptocurrency activities (“FIL-7-2025”). ...more
4/9/2025
/ Banks ,
Cryptocurrency ,
Digital Assets ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Financial Services Industry ,
Investment Products ,
OCC ,
Regulatory Reform ,
Regulatory Requirements ,
Stablecoins
On March 21, 2025, the US Financial Crimes Enforcement Network (“FinCEN”) issued an interim final rule (the “IFR”) that exempts all domestic entities from beneficial ownership information reporting requirements under the...more
On March 13, 2025, the US Senate Banking Committee passed the Guiding and Establishing National Innovation for US Stablecoins Act of 2025 or “GENIUS Act,” out of committee by a vote of 18-6....more
3/20/2025
/ Bankruptcy Code ,
Cryptocurrency ,
Digital Assets ,
Digital Currency ,
Federal Reserve ,
Financial Regulatory Reform ,
FinTech ,
OCC ,
Regulatory Requirements ,
Stablecoins ,
U.S. Treasury
On March 7, 2025, the Office of the Comptroller of the Currency (OCC) issued guidance on national bank and federal savings association participation in certain cryptocurrency activities (“IL 1183”). This guidance is the...more
On February 27, 2025, the US Financial Crimes Enforcement Network (FinCEN) announced that it will not issue fines or penalties or take any other enforcement actions against companies that fail to comply with the March 21,...more
AT A GLANCE -
On February 17, 2025, the US District Court for the Eastern District of Texas stayed its January 7 order, enjoining enforcement of the Corporate Transparency Act and suspending the effectiveness of the...more
2/28/2025
/ Beneficial Owner ,
Business Entities ,
Business Ownership ,
Compliance ,
Corporate Governance ,
Corporate Transparency Act ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Regulatory Requirements ,
Reporting Requirements
AT A GLANCE -
The US Supreme Court has stayed the injunction against the Corporate Transparency Act (CTA), but the requirement for companies to file beneficial ownership information remains suspended, creating ongoing...more
The US Consumer Financial Protection Bureau (CFPB) is giving no-action letters (NALs) a second chance. On January 8, 2025, the CFPB issued a policy statement setting forth new procedures for companies to request supervisory...more
On December 26, 2024, a panel of the US Court of Appeals for the Fifth Circuit vacated an order issued by a different panel just days before that had stayed the nationwide preliminary injunction suspending enforcement of the...more
12/31/2024
/ Beneficial Owner ,
Business Entities ,
Business Ownership ,
Compliance ,
Corporate Transparency Act ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements ,
Stays
On December 23, 2024, the US Court of Appeals for the Fifth Circuit granted an emergency motion by the federal government to stay the nationwide preliminary injunction that had suspended enforcement of the Corporate...more
12/27/2024
/ Beneficial Owner ,
Business Entities ,
Business Ownership ,
Compliance ,
Corporate Transparency Act ,
Deadlines ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements ,
Stays
Join us for a new episode of Financial Services Focus with partners Gina Parlovecchio and Matthew Bisanz, and associate Kelly Truesdale, as they discuss FinCEN’s recent confirmation that reporting companies are not required...more
12/17/2024
/ Beneficial Owner ,
Business Entities ,
Business Ownership ,
Corporate Transparency Act ,
Filing Requirements ,
Financial Services Industry ,
FinCEN ,
Popular ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements
On December 7, 2024, the US Financial Crimes Enforcement Network (FinCEN) confirmed that reporting companies—i.e., companies that would be required to report their beneficial ownership information to FinCEN under the...more
12/11/2024
/ Beneficial Owner ,
Business Entities ,
Business Ownership ,
Compliance ,
Corporate Transparency Act ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements ,
Stays
On December 3, 2024, the US District Court for the Eastern District of Texas entered a preliminary injunction suspending enforcement of the Corporate Transparency Act (CTA) and its implementing regulations nationwide,...more
12/10/2024
/ Beneficial Owner ,
Business Entities ,
Business Ownership ,
Compliance ,
Corporate Transparency Act ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements ,
Stays
On October 22, 2024, the Consumer Financial Protection Bureau (CFPB) finalized a rulemaking on Personal Financial Data Rights (the “Final Rule”). The Final Rule is intended to accelerate a shift towards open banking in the...more
11/6/2024
/ Banks ,
Consumer Data Requests ,
Consumer Financial Protection Bureau (CFPB) ,
Data Management ,
Dodd-Frank ,
Final Rules ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Open Banking ,
Popular
Last month, the FDIC proposed rules related to FDIC pass-through insurance coverage. These rules could have a significant impact on bank-fintech partnerships, including some partnerships for programs that do not promise FDIC...more
On September 17, 2024, the Federal Deposit Insurance Corporation (FDIC) proposed extensive new recordkeeping requirements and other compliance obligations (the “Proposal” ) for certain types of deposit accounts frequently...more
On August 28, 2024, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) finalized a rule to require reporting of certain US residential real estate transactions (“Final Rule”). The Final Rule...more
I. INTRODUCTION -
On May 13, 2024, the US Securities and Exchange Commission (“SEC”) and the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a joint notice of proposed rulemaking (the...more
5/31/2024
/ Anti-Money Laundering ,
Compliance ,
Exempt Reporting Advisers (ERAs) ,
Financial Institutions ,
Financial Markets ,
Financial Services Industry ,
FinCEN ,
Investment Adviser ,
NPRM ,
Recordkeeping Requirements ,
Registered Investment Advisors ,
Risk Assessment ,
Securities and Exchange Commission (SEC)
At the end of March, components of the US Federal Reserve System (“FRS” or the “Fed”) prevailed in two lawsuits brought by depository institutions seeking master accounts.1 These decisions have significant implications for...more
On March 28, 2024, the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”), in consultation with the staffs of the federal banking agencies, issued a request for information and comment (the “RFI”)...more
On Tuesday, September 1, 2020, the US Centers for Disease Control and Prevention (the “CDC”) filed a notice of an agency order in the Federal Register titled Temporary Halt in Residential Evictions to Prevent the Further...more
9/8/2020
/ CARES Act ,
Centers for Disease Control and Prevention (CDC) ,
Coronavirus/COVID-19 ,
Eviction ,
Financial Distress ,
Infectious Diseases ,
Landlords ,
Moratorium ,
Public Health ,
Relief Measures ,
Rent ,
Rental Property ,
Tenants