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FinCEN Postpones Effective Date of AML/CFT Rule for Investment Advisers

On July 21, 2025, the U.S. Department of the Treasury’s (“Treasury”) Financial Crimes Enforcement Network (FinCEN) announced it will delay the effective date of the final rule establishing anti-money laundering/countering the...more

No Full TIN, No Problem: FinCEN Approves of TIN Verification Through a Third Party

On June 27, 2025, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an order (Order) allowing banks,[1] and their subsidiaries, subject to the jurisdiction of the Office of the Comptroller...more

Banking Agencies Issue Joint Third-Party Risk Management Guidance

On June 9, 2023, the Federal Reserve Board, the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, the “Agencies”) published final joint guidance on managing...more

OCC Permits National Banks And Federal Savings Associations To Use Independent Node Verification Networks And Stablecoins For...

As part of the Office of the Comptroller of the Currency’s (OCC) declared effort to keep pace with a mounting demand for faster, cheaper, and more efficient payments, and the widespread adoption of new technologies, the...more

Agencies Finalize Amendments To Volcker Rule Covered Fund Provisions

On June 25, 2020, five federal agencies (the “Agencies”) finalized amendments to the rules implementing section 13 of the Bank Holding Company Act of 1956 (the “Volcker Rule”) related to the prohibition on investing,...more

Banking Agencies Propose a More Tiered Approach to Large Foreign Bank Supervision

On April 8, 2019, the federal banking agencies (the “Agencies”) released two proposals (the “Tailoring Proposals”) which, if adopted, would further tailor the approach to supervision of large foreign banking organizations...more

Agencies Propose a More Tiered Approach to Large Bank Supervision

On October 31, 2018, the federal banking agencies released two separate proposals that, if adopted, would create a more consistent tiered approach to large bank supervision – in other words, supervision of banking...more

Agencies Release Interagency Statement on Sharing Bank Secrecy Act Resources

On October 3, 2018, the five federal agencies tasked with the supervision, examination, and enforcement of Bank Secrecy Act (BSA) and anti-money laundering (AML) requirements for banks (the “Agencies”), issued an interagency...more

Federal Reserve Board Revises FR Y-7 and Provides Guidance on Enhanced Prudential Standards for Foreign Banking Organizations

On January 18, 2018, the Board of Governors of the Federal Reserve System (the “Federal Reserve Board”) announced the approval of proposed revisions to the Annual Report of Foreign Banking Organizations (“FR Y-7”). The...more

House Financial Services Committee Holds Hearing on the Financial CHOICE Act of 2017

On April 26, 2017, the Financial Services Committee of the U.S. House of Representatives held a hearing entitled "A Legislative Proposal to Create Hope and Opportunity for Investors, Consumers, and Entrepreneurs." The purpose...more

OCC’s Interim Volcker Rule Examination Procedures Provide Much-Needed Guidance to Banks Seeking to Comply

On June 12, 2014, the Office of the Comptroller of the Currency (OCC) issued interim procedures for examiners to assess banks’ progress in developing a framework to comply with the requirements of what is commonly known as...more

Summary of Final Rule Imposing Enhanced Prudential Standards on FBOs

Last week, the Federal Reserve Board (the “Board”) issued its long-awaited final enhanced prudential rule (Regulation YY) under Section 165 of the Dodd-Frank Act (the “Final Rule”) for bank holding companies and foreign...more

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