In recent guidance, the Financial Industry Regulatory Authority (FINRA) published the results of its targeted examination or “sweep” of crypto assets retail communications distributed or issued by its member firms, finding...more
I. Introduction: EWA on the Precipice -
The increasing use of earned wage access (“EWA”) by workers in the United States and around the world has helped to bring financial flexibility to many previously constrained by the...more
11/14/2023
/ Advisory Opinions ,
Consumer Financial Protection Bureau (CFPB) ,
Cryptoassets ,
Cryptocurrency ,
Employer Liability Issues ,
FinTech ,
Labor Regulations ,
Regulation Z ,
Regulatory Requirements ,
Wage and Hour ,
Wages
Shinhan Bank America (“Shinhan”), a New York-based subsidiary of a Korean bank, faced coordinated enforcement actions on September 29 from the Financial Crimes Enforcement Network (“FinCEN”), Federal Deposit Insurance...more
10/12/2023
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Cryptoassets ,
Cryptocurrency ,
Enforcement Actions ,
FDIC ,
Financial Institutions ,
FinCEN ,
FinTech ,
New York ,
NYDFS
The New York Department of Financial Services (NYDFS) proudly announced an “update on [its] two-year transformational initiative to strengthen NYDFS’ nation-leading virtual currency oversight” on September 18, 2023. Although...more
10/9/2023
/ Bitcoin ,
Comment Period ,
Corporate Governance ,
Cryptoassets ,
Cryptocurrency ,
New Guidance ,
NYDFS ,
Public Comment ,
Regulatory Agenda ,
Regulatory Requirements ,
Virtual Currency
On June 6, 2023, federal banking agencies issued final Interagency Guidelines on Third-Party Relationships detailing their expectations for banks in establishing risk management practices with third-parties—including...more
6/16/2023
/ Banking Sector ,
Banks ,
Cryptoassets ,
Cryptocurrency ,
FDIC ,
Financial Institutions ,
Financial Services Industry ,
FinTech ,
New Guidance ,
OCC ,
Servicing Agreements ,
Third-Party