On August 5, 2025, the Federal Deposit Insurance Corporation (FDIC) issued FIL-39-2025 to state that an FDIC-supervised institution can use pre-populated customer information to satisfy the requirements of the Customer...more
On July 23, 2025, Senators John Fetterman (D-PA), Chuck Grassley (R-IA), Sheldon Whitehouse (D-RI), Bill Cassidy (R-LA), Andy Kim (D-NJ), and David McCormick (R-PA), introduced the federal Art Market Integrity Act (the...more
8/6/2025
/ AML/CFT ,
Anti-Money Laundering ,
Art Auctions ,
Art Dealers ,
Bank Secrecy Act ,
BSA/AML ,
FinCEN ,
Fine Art ,
Money Laundering ,
Office of Foreign Assets Control (OFAC) ,
Proposed Legislation ,
Regulatory Agenda ,
U.S. Treasury
The Financial Crimes Enforcement Network (“FinCEN”) issued last month an in-depth report on check fraud stemming from mail theft (“Report”). This is a pernicious and expanding problem. The Report follows upon a joint alert...more
10/8/2024
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Financial Crimes ,
Financial Fraud ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Money Laundering ,
Popular ,
Reporting Requirements ,
Suspicious Activity Reports (SARs) ,
Theft ,
USPS
On August 15, 2024, the Illinois Bankers Association, American Bankers Association, America’s Credit Unions, and Illinois Credit Union League filed a complaint for declaratory and injunctive relief against the Illinois...more
8/21/2024
/ Anti-Money Laundering ,
Banks ,
BSA/AML ,
Credit Cards ,
Debit Cards ,
Declaratory Relief ,
Electronic Fund Transfer Act ,
Final Rules ,
Financial Institutions ,
Financial Services Industry ,
Injunctive Relief ,
Interchange Fees ,
Late Fees ,
National Bank Act ,
Preemption ,
Regulation II
As we previously blogged, a Florida law (Fla. Stat. § 655.0323, entitled “Unsafe and unsound practices”) which became effective July 1, 2024 prohibits federal and state depository institutions conducting business in the state...more
7/30/2024
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Banks ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Florida ,
Money Laundering ,
Preemption ,
Religious Beliefs ,
Religious Discrimination ,
Suspicious Activity Reports (SARs) ,
U.S. Treasury ,
Unfair or Deceptive Trade Practices
On July 1, 2024, the Supreme Court issued its opinion in Corner Post, Inc. v Board of Governors of the Federal Reserve System in which the Court determined when a Section 702 claim under the Administrative Procedure Act (APA)...more
7/5/2024
/ Administrative Procedure Act ,
Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Corner Post Inc v Board of Governors of the Federal Reserve System ,
Debit Cards ,
Federal Reserve ,
Final Rules ,
Financial Crimes ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Services Industry ,
FinCEN ,
Interchange Fees ,
Regulation II ,
SCOTUS ,
Securities and Exchange Commission (SEC) ,
Statute of Limitations
In February 2024, the Federal Deposit Insurance Corporation (FDIC) entered into consent orders with two banks who partner with fintechs to offer “banking as a service” (BaaS) related to safety and soundness concerns relating...more
4/12/2024
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Banks ,
Consent Order ,
Customer Identification Program (CIP) ,
Enforcement Actions ,
FDIC ,
Financial Institutions ,
Financial Services Industry ,
FinTech ,
Money Laundering ,
Risk Management ,
Terrorist Financing ,
Third-Party ,
True Lender
In February 2024, the Federal Deposit Insurance Corporation (FDIC) entered into consent orders with two banks who partner with fintechs to offer “banking as a service” (BaaS) related to safety and soundness, compliance with...more
4/10/2024
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Banks ,
Consent Order ,
Customer Due Diligence (CDD) ,
Customer Identification Program (CIP) ,
FDIC ,
Financial Institutions ,
Financial Services Industry ,
FinTech ,
Regulation E ,
Risk Assessment ,
Terrorist Financing Regulations ,
True Lender
The Chairman of the House Financial Services Committee, Patrick McHenry (R-NC), sent a comment letter to CFPB Director Rohit Chopra in response to the CFPB’s notice of proposed rulemaking that would implement Section 1033 of...more
12/27/2023
/ Anti-Money Laundering ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Data Management ,
Data Protection ,
Dodd-Frank ,
Financial Services Committee ,
Financial Services Industry ,
Fraud ,
Innovation ,
Notice of Proposed Rulemaking (NOPR)
A group of five Democratic Senators have sent a letter to the Federal Reserve, OCC, FDIC, and NCUA asking them to take several steps to protect consumers from scams when using Zelle to transfer money....more