The override of former President Trump's veto of the National Defense Authorization Act of 2021 resulted in the enactment of broad amendments to the US anti-money laundering regime. Of particular note is the inclusion of the...more
1/28/2021
/ Anti-Money Laundering ,
Beneficial Owner ,
Closely Held Businesses ,
Corporate Transparency Act ,
Covered Entities ,
Customer Due Diligence (CDD) ,
FinCEN ,
Limited Liability Company (LLC) ,
NDAA ,
Shell Corporations ,
Special Purpose Vehicles
The OCC recently finalized two broad updates to its regulations that increase flexibility for regulatory filings, including for corporate transactions such as business combinations, and update and clarify permissible...more
In response to a call for a rulemaking by two leading bank industry trade associations, the federal banking agencies have issued a proposed rule to codify an earlier interagency statement that their supervisory...more
On September 16, the US Financial Crimes Enforcement Network (FinCEN) issued an advance notice of proposed rulemaking (ANPRM) seeking to update the US anti-money laundering (AML) regime. This is an historic opportunity for...more
11/5/2020
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Proposed Amendments ,
Public Comment ,
Risk Assessment ,
Suspicious Activity Reports (SARs)
The US Financial Crimes Enforcement Network (FinCEN) and the federal banking agencies (Agencies)1 issued a joint statement on August 21, 2020, regarding Bank Secrecy Act/anti-money laundering (AML) regulatory requirements for...more
9/24/2020
/ Bank Fraud ,
BSA/AML ,
Corruption ,
Customer Due Diligence (CDD) ,
FATF ,
Federal Bank Regulatory Agencies ,
Financial Institutions ,
FinCEN ,
Joint Statements ,
Money Laundering ,
National Security ,
Politically Exposed Person (PEPs) ,
Risk Assessment ,
Senior Foreign Political Figures (SFPFs)
Section 13(3) of the Federal Reserve Act authorizes the Federal Reserve Board (FRB) in “unusual and exigent circumstances” to establish programs or facilities with “broad-based eligibility” that allow a Federal Reserve Bank...more
In response to the global COVID-19 crisis, US federal financial regulators are taking important actions that affect US and non-US financial institutions, other financial services providers, consumers, and the US and global...more
5/2/2020
/ Banks ,
CFTC ,
Comment Period ,
Coronavirus/COVID-19 ,
FDIC ,
Federal Loans ,
Financial Regulatory Agencies ,
Foreign Banks ,
FRB ,
Midsize and Large Business Loans ,
OCC ,
Paycheck Protection Program (PPP) ,
Popular ,
Public Comment ,
Publicly-Traded Companies ,
Relief Measures ,
SBA ,
Securities and Exchange Commission (SEC) ,
Small Business Loans ,
State of Emergency ,
Volcker Rule
The United States Congress has passed, and continues to consider, legislative measures that, in addition to addressing the public health crisis, include massive fiscal stimulus proposals not seen since the 2008 global...more
In response to the global COVID-19 crisis, US financial regulators at the state level are taking important actions that affect US and non-US financial institutions, other financial services providers, consumers, and the US...more
In response to the global COVID-19 crisis, US federal financial regulators are taking important actions that affect US and non-US financial institutions, other financial services providers, consumers, and the US and global...more
4/28/2020
/ Banks ,
CFTC ,
Coronavirus/COVID-19 ,
DSIO ,
Financial Institutions ,
Financial Regulatory Agencies ,
FRB ,
OCC ,
Regulatory Oversight ,
Relief Measures ,
Securities and Exchange Commission (SEC)
In response to the global COVID-19 crisis, US federal financial regulators are taking important actions that affect US and non-US financial institutions, other financial services providers, consumers, and the US and global...more
The United States Congress has passed, and continues to consider, legislative measures that, in addition to addressing the public health crisis, include massive fiscal stimulus proposals not seen since the 2008 global...more
In response to the global COVID-19 crisis, US federal financial regulators are taking important actions that affect US and non-US financial institutions, other financial services providers, consumers, and the US and global...more
4/22/2020
/ Appraisal ,
Borrower Protection Programs ,
Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
Deferred Action ,
FDIC ,
FHFA ,
Financial Services Industry ,
FRB ,
HMDA ,
NCUA ,
OCC ,
Paycheck Protection Program (PPP) ,
Real Estate Transactions ,
Relief Measures ,
Temporary Regulations
Section 13(3) of the Federal Reserve Act authorizes the Federal Reserve Board (FRB) in “unusual and exigent circumstances” to establish programs or facilities with “broad-based eligibility” that allow a Federal Reserve Bank...more
4/21/2020
/ CARES Act ,
Commercial Paper Funding Facility (CPFF) ,
Coronavirus/COVID-19 ,
Dodd-Frank ,
Federal Reserve ,
Financial Stimulus ,
FRB ,
Lenders ,
Liquidity ,
Main Street Lending Programs ,
Money Market Mutual Fund Liquidity Facility (MMLF) ,
Paycheck Protection Program (PPP) ,
Primary Dealer Credit Facility (PDCF) ,
Primary Market Corporate Credit Facility (PMCCF) ,
Relief Measures ,
Secondary Market Corporate Credit Facility (SMCCF) ,
Term Asset-Backed Securities Loan Facility (TALF)
In response to the global COVID-19 crisis, US federal financial regulators are taking important actions that affect US and non-US financial institutions, other financial services providers, consumers, and the US and global...more
As during the 2008 global financial crisis, the US financial regulators and Congress are taking emergency action to ensure the availability of liquidity and credit to the US financial system in response to the COVID-19...more
4/8/2020
/ Banking Sector ,
Commercial Paper Funding Facility (CPFF) ,
Compliance ,
Coronavirus/COVID-19 ,
Emergency Lending ,
Financial Institutions ,
Liquidity ,
Main Street Expanded Loan Facility ,
Money Market Mutual Fund Liquidity Facility (MMLF) ,
Primary Dealer Credit Facility (PDCF) ,
Term Asset-Backed Securities Loan Facility (TALF) ,
US Branches of Non-US Banks
On January 30, the Federal Reserve released a highly anticipated final rule that substantially updates and clarifies the agency's regulatory framework for determining when an investor exercises a controlling influence over a...more
2/18/2020
/ Bank Holding Company Act ,
Banks ,
Board of Directors ,
Controlling Influence Test ,
Divestiture ,
Federal Reserve ,
Fiduciary Duty ,
Final Rules ,
HOLA ,
Interlocking Directorate ,
Investment Funds ,
Investors ,
Proxy Contests ,
Rebuttable Presumptions ,
Senior Managers ,
Voting Securities
Since the 2008 financial crisis, a non-US bank seeking to establish or maintain a US presence has been required to comply with a set of stringent regulatory requirements, but a recently adopted rule (Final Rule) limits their...more
1/3/2020
/ Banks ,
Capital Requirements ,
FBOs ,
Final Rules ,
Financial Regulatory Agencies ,
Foreign Banks ,
Intermediate Holding Company (IHCs) ,
Liquidity Coverage Ratio ,
Non-US Entities ,
Prudential Standards ,
Stress Tests
On August 5, 2019, the Board of Governors of the Federal Reserve System (“Board”) proposed the development of a real-time gross settlement service (“RTGS”) called “FedNow.” The service, expected to launch in 2023 or 2024,...more
9/5/2019
/ Banks ,
Board of Governors ,
Credit Unions ,
Federal Reserve ,
FedNow ,
Financial Institutions ,
Payment Systems ,
Proposed Rules ,
Public Comment ,
Real Time Payment (RTP) ,
Request For Information