The EU has introduced Delegated Regulation (EU) 2025/1190, establishing the first harmonized standards for threat-led penetration testing ("TLPT") across the financial sector. The regulation aims to strengthen the cyber...more
7/31/2025
/ Credit Institutions ,
Cybersecurity ,
Digital Operational Resilience Act (DORA) ,
Enforcement ,
EU ,
EU Directive ,
Financial Institutions ,
Financial Services Industry ,
G-SII ,
Harmonization Rules ,
Regulatory Requirements ,
Risk Management ,
Technical Standards
The rise of crypto assets and decentralized finance has challenged traditional regulatory frameworks, particularly in the area of anti-money laundering and countering the financing of terrorism ("AML/CFT")....more
7/29/2025
/ AML/CFT ,
Anti-Money Laundering ,
Cooperative Compliance Regime ,
Cryptoassets ,
Cryptocurrency ,
Digital Assets ,
EU ,
Financial Crimes ,
Financial Markets ,
Money Laundering ,
Regulatory Requirements ,
Terrorist Financing Regulations
Following the recent focus on two major regulatory frameworks—the Guiding and Establishing National Innovation for U.S. Stablecoins Act (known as the GENIUS Act) in the United States, and Regulation (EU) 2023/1114 of the...more
7/28/2025
/ Cryptocurrency ,
Digital Assets ,
EU ,
Financial Markets ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinTech ,
New Legislation ,
Regulatory Oversight ,
Regulatory Reform ,
Regulatory Requirements ,
Stablecoins ,
The GENIUS Act
The European Union Anti-Money Laundering ("AML") package includes Regulation (EU) 2024/1620 of the European Parliament and of the Council of May 31, 2024, establishing the Authority for Anti-Money Laundering and Countering...more
7/28/2025
/ AML/CFT ,
Anti-Money Laundering ,
Enforcement ,
EU ,
Financial Crimes ,
Financial Institutions ,
Financial Services Industry ,
Money Laundering ,
New Regulations ,
Regulatory Authority ,
Regulatory Oversight ,
Regulatory Requirements
The European Union ("EU") Anti-Money Laundering ("AML") package adopted by the European Parliament and the Council on May 31, 2024, represents a major shift in the fight against money laundering and terrorist financing at the...more
DORA, the first EU regulation designed to establish a unified and robust digital resilience standard for the financial sector, becomes directly applicable on January 17, 2025, introducing significant penalties and...more
Against the backdrop of the comprehensive recast of European Union ("EU") banking legislation, the EU legislator is increasingly focused on Environmental, Social, and Governance ("ESG") risks. In this context, ad hoc...more
The Situation: Prior to the enactment of Capital Requirements Directive ("CRD") VI, corporate governance rules for the financial services industry were not harmonized across EU Member States....more
The Situation: The European Union ("EU") banking legislation has been substantially reviewed and provides notably for a new regime applicable to cross-border activities from non-EU jurisdictions....more
On May 28, 2024, the Chair of the Supervisory Board of the European Central Bank ("ECB"), Claudia Buch, announced the decision to reform the current process of annual review of credit institutions under direct ECB supervision...more
In Short -
The Situation: France has had a registration and licensing process for digital assets service providers for over three years. The recent crisis with Terra Luna and FTX trading platform has made it clear to...more
In 2022, anti-money laundering ("AML") and sanctions controls were at the center of regulatory and enforcement activities in the United States and abroad. Globally, governments have continued to recognize the impact of AML...more
In Short -
The Situation: Regulatory "sandboxes" are trending. They represent a unique approach to regulation that permits selected companies to test and experiment with new and innovative products and services....more
In Short -
The Situation: The European Union's Fourth Anti-Money Laundering ("AML") Directive (Directive (EU) 2015/849 of May 20, 2015) granted broad access to information relating to the beneficial owners of companies...more
On July 8, 2022, the European Central Bank ("ECB") released the results from its annual stress tests, this year focused on banks' ability to incorporate climate risk stress testing into their risk management frameworks. The...more
On June 29, 2022, the European Parliament, the Commission, and the Council reached a provisional agreement on the European Union proposal to update Regulation 2015/847 on information accompanying the transfer of funds ("TFR")...more
2021 was a precedent-setting year for anti-money laundering (“AML”) enforcement and legislation. The digital assets industry continued to grow exponentially, driving the associated AML risks to the forefront of regulatory...more
3/10/2022
/ AML/CFT ,
Anti-Money Laundering ,
BSA/AML ,
Corruption ,
Cryptoassets ,
Economic Sanctions ,
Financial Crimes ,
FinCEN ,
Justice Against Sponsors of Terrorism Act (JASTA) ,
Terrorist Financing Regulations ,
Virtual Currency
After June 30, 2021, large asset managers will no longer have the option to "explain" noncompliance with Article 4 of EU Regulation (EU) 2019/2088 on sustainability‐related disclosures in the financial services sector...more
An interest group of EU banks that was formed to assist European financial institutions with their use of public cloud technology recently suggested model terms for the compliant use of cloud technology.
On May 17, 2021,...more
More than a year ago the world fell victim to a global pandemic that would change life in ways that could never have been predicted. In the early stages of the pandemic, we published a White Paper directed at financial...more
An order was published on December 23, 2020, amending the order of September 5, 2007, relating to the nonfinancial activities that French investment firms may conduct.
As a matter of principle, and similarly to credit...more
The Situation: On January 4, 2021, the Office of the Comptroller of the Currency ("OCC") issued an Interpretive Letter permitting national banks and federal savings associations ("Banks") to participate in independent node...more
1/19/2021
/ Banking Sector ,
Cryptoassets ,
Cryptocurrency ,
Digital Assets ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Services Industry ,
FinCEN ,
Interpretive Letters ,
OCC ,
Popular ,
Securities and Exchange Commission (SEC) ,
Stablecoins
The Development: New Regulation (EU) 2020/2176 (the "Regulation") provides regulatory capital relief, allowing certain software assets to be considered when calculating Common Equity Tier 1 ("CET1") capital. It entered into...more
The Situation: Although the deadline keeps getting extended, e-commerce merchants and payment processors across the European Union are racing to implement the strong customer authentication ("SCA") requirements of the Revised...more
The Situation: The New York State Department of Financial Services ("DFS") and the European Banking Authority ("EBA") have published guidance relating to Environmental, Social, and Corporate Governance ("ESG")...more