On June 18, 2025, the Financial Action Task Force (“FATF”) revised the Travel Rule requirements for certain funds transfers (the “2025 Revisions”). The 2025 Revisions are intended to adapt anti-money laundering (“AML”)...more
On August 7, 2025, President Donald Trump issued an Executive Order entitled “Guaranteeing Fair Banking for All Americans” (the “Order”). The Order announces the Administration’s plan to address the exclusion of certain...more
On July 31, 2025, the Commodity Futures Trading Commission (“CFTC”) issued no-action relief for certain swap reporting counterparties that fail to submit a swap data error correction notification (“NAL 25-25”). This relief...more
On July 15, 2025, the Federal Deposit Insurance Corporation (“FDIC”) requested comment on its framework for reviewing applications for deposit insurance from industrial loan companies and industrial banks (collectively,...more
OVERVIEW OF THE REMITTANCE TRANSFER EXCISE TAX -
Do you effect transfers of funds for US residents to recipients abroad? If so, you should review the provision of the “One Big Beautiful Bill Act” (“OBBBA”) that imposes a...more
WHAT ARE THE KEY DRIVERS FOR REFORM?
The UK Treasury ("HMT") noted the following as drivers for reform:
A key challenge for private companies is that, at early stages in their growth, there are no standardised ways...more
On July 10, 2025, the Board of Governors of the Federal Reserve System (“Board”) proposed changes to its supervisory rating systems for large financial institutions (“LFIs”) and supervised insurance organizations (the...more
Today, President Donald Trump signs into law the Guiding and Establishing National Innovation for US Stablecoins Act of 2025 (the “GENIUS Act”), establishing the first federal regulatory framework for stablecoins in the...more
7/18/2025
/ Anti-Money Laundering ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Protection Laws ,
Cryptocurrency ,
Digital Assets ,
Federal Reserve ,
Financial Regulatory Reform ,
New Legislation ,
OCC ,
Stablecoins ,
Trump Administration
WHAT ARE THE KEY DRIVERS FOR REFORM?
The UK Treasury ("HMT") noted the following as drivers for reform:
A key challenge for private companies is that, at early stages in their growth, there are no standardised ways...more
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