On June 25, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued three orders (the “Orders”) pursuant to the Fentanyl Sanctions Act and the FEND Off Fentanyl Act, designating three...more
Last week, the US federal banking regulators proposed changes to the enhanced supplementary leverage ratio (“eSLR”) requirement for US global systemically important bank holding companies (“US GSIBs”) (the “Proposal”)....more
7/1/2025
/ Banking Regulators ,
Banking Sector ,
Basel III ,
Capital Markets ,
Capital Requirements ,
Comment Period ,
FDIC ,
Federal Reserve ,
Financial Regulatory Reform ,
OCC ,
Proposed Rules ,
Regulatory Reform
On June 13, 2025, the Basel Committee on Banking Supervision (“BCBS”) published its framework for the disclosure of climate-related financial risks. The framework is entirely voluntary and has several notable changes from...more
Matt Bisanz interviews Megan Neuburger, the head of US corporate ratings at Fitch Ratings. They discuss how an analyst develops corporate credit ratings and the many elements of that process that banks should understand....more
On May 5, 2025, the Republican committee chairs in the US House of Representatives with jurisdiction over digital asset legislation released a digital asset market structure discussion draft bill (the “Discussion Draft”). The...more
5/28/2025
/ Asset Management ,
Blockchain ,
CFTC ,
Cryptocurrency ,
Decentralized Finance (DeFi) ,
Digital Assets ,
Financial Regulatory Reform ,
New Legislation ,
Proposed Legislation ,
Regulatory Oversight ,
Securities and Exchange Commission (SEC) ,
Stablecoins
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 May 15, 2025, the staff of the Securities and Exchange Commission (“SEC”) Division of Trading and Markets (the “Staff”) published responses to certain frequently asked questions (“FAQs”) relating to crypto asset activities...more
On May 12, 2025, the Securities and Exchange Commission (“SEC”) held a Crypto Task Force roundtable to explore an appropriate regulatory framework for tokenized securities. In the keynote address, Chair Paul Atkins, stated...more
On May 8, 2025, the Securities and Exchange Commission (“SEC”) held the 31st International Institute for Securities Market Growth and Development. Commissioner Peirce used this opportunity to discuss an approach to regulating...more
Matt Bisanz interviews Ross Delston, a financial crime compliance expert and former FDIC attorney. They discuss his views on the trends we should expect to see in financial crimefighting and AML compliance over the next few...more
5/9/2025
/ AML/CFT ,
Anti-Money Laundering ,
Banking Sector ,
FATF ,
FDIC ,
Financial Crimes ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Regulatory Requirements ,
Risk Management
On March 25, 2025, the Securities and Exchange Commission (“SEC”) held a Crypto Task Force roundtable to explore regulatory considerations surrounding custody of crypto assets through broker-dealers and other financial...more
Many US and other non-EU financial institutions which lend or undertake trade finance business on a cross border basis into Europe do so in reliance upon exemptions under local law. These exemptions typically permit these...more
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
On March 31, 2025, the Office of the Comptroller of the Currency withdrew its participation in the interagency principles for climate-related financial risk management for large financial institutions (the “Climate...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
Joe Castelluccio and Matt Bisanz interview Mark Quandahl, the former Director of the Nebraska Department of Banking and Finance. They discuss his role in the implementation of the Nebraska Financial Innovation Act, including...more
4/1/2025
/ Banking Sector ,
Cryptocurrency ,
Depository Institutions ,
Digital Assets ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinTech ,
New Legislation ,
Regulatory Agencies ,
Regulatory Reform
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
Since President Donald Trump took office last month, his actions have marked a significant shift in federal policy, paving the way for the creation of a new regulatory framework impacting banks, financial services, and the...more
FinCEN has confirmed that, since December 7, 2024, reporting companies have not been, and will continue to not be, required to file beneficial ownership reports for as long as an injunction of the CTA remains in effect....more
WHAT THIS MEANS FOR BANKS, FINANCIAL SERVICES AND THE DIGITAL ASSETS SECTOR -
Just four days after his inauguration, President Donald Trump has initiated a fundamental shift in federal policy on digital assets with a...more
1/27/2025
/ Blockchain ,
Cryptoassets ,
Cryptocurrency ,
Digital Assets ,
Executive Orders ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinTech ,
Regulatory Reform ,
Securities and Exchange Commission (SEC) ,
Stablecoins ,
Trump Administration