Regulatory Ramblings: Episode 76 - The Digital Future: The US GENIUS Act and Hong Kong Stablecoins Ordinance / The Hong Kong Web3 Blueprint: Building a Web 3 International Financial Hub Report
Compliance Tip of the Day: Citibank and Continuous Monitoring
Compliance into the Weeds: Sanctions Compliance Failures: Lessons from Harman International and Interactive Brokers
Episode 377 -- Refocusing Due Diligence on Cartels and TCOs
Upping Your Game: Continuous Monitoring with AI
Daily Compliance News: May 19, 2025, The Definition of Corruption Edition
2 Gurus Talk Compliance: Episode 51 – The Compliance Week at 20 Edition
Navigating the Future of Payment Stablecoins: Legislative Updates and Market Implications — The Crypto Exchange Podcast
10 For 10: Top Compliance Stories For the Week Ending April 12, 2025
Daily Compliance News: April 7, 2025, The Whistleblowers Awarded Edition
Strengthening Compliance: Lessons From the OCC's Consent Order With Patriot Bank — Payments Pros – The Payments Law Podcast
Great Women in Compliance: Roundtable on The Future of Financial Crime Prevention
The Presumption of Innocence Podcast: Episode 50 - Hidden in Plain Sight: How Kleptocrats Exploit U.S. Financial Systems
Corruption, Crime & Compliance: TD Bank Agrees to Pay Over $3 Billion for Systemic Violations of Bank Secrecy Act and Money Laundering Violations
Episode 343 -- TD Bank Agrees to Pay Over $3 Billion for Systemic Violations of Bank Secrecy Act and Money Laundering Violations
The Consumer Financial Protection Bureau vs. the Video Game Industry
Business Better Podcast Episode: FinCEN’s Notice of Proposed Regulations to Strengthen and Modernize AML/CFT Compliance Programs
Cannabis Law Now Podcast: Cannabis Companies and the Corporate Transparency Act
Examining FinCEN FAQs, Proposed Legislation and Other CTA Developments
Practical Lessons Learned Regarding the Bank Secrecy Act and Anti-Money Laundering for Financial Institutions - The Consumer Finance Podcast
Federal banking regulators have issued a joint statement in an effort to provide clarity on banks’ engagement in crypto-asset related activities....more
President Donald Trump on Aug. 7, 2025, signed an executive order (EO or order) titled "Guaranteeing Fair Banking for All Americans," which declares that no American should be denied access to financial services based on...more
On July 31, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an exemptive order in coordination with the Board of Governors of the Federal Reserve System (the “Fed”) that allows...more
Federal banking regulators continue to promote a more "crypto-positive" regulatory environment through recent joint guidance issued to clarify risk management and compliance expectations for banks providing crypto-asset...more
A Gesture Providing Limited Solace to a Now-Defunct Bank - Six years ago, in early 2018, we blogged about the U.S. Department of the Treasury’s Financial Crimes Enforcement Network’s (“FinCEN’s”) designation of ABLV Bank, AS...more
The U.S. Drug Enforcement Agency’s proposal to reschedule cannabis from a Schedule I to a Schedule III drug under the Controlled Substances Act (CSA) has generated considerable buzz across business sectors, including for the...more
The Financial Crimes Enforcement Network (FinCEN) and the federal banking agencies recently published the long-awaited notice of proposed rulemaking for the anti-money laundering/countering the financing of terrorism...more
On July 3, the Financial Crimes Enforcement Network (FinCEN) published a notice of proposed rulemaking (NPRM) as part of a broader initiative to “strengthen, modernize, and improve” financial institutions’ anti-money...more
Introduction - On 13 May 2024, the Securities and Exchange Commission (SEC) and the US Department of Treasury’s (DoT) Financial Crimes Enforcement Network (FinCEN) jointly proposed rulemaking to implement Section 326 of the...more
In its Fall 2023 Semiannual Risk Perspective, published on December 7, the Office of the Comptroller of the Currency (“OCC”) reported on key issues facing the federal banking system. In evaluating the overall soundness of...more
How much is an effective Anti-Money Laundering (“AML”) Compliance Program Worth? For Toronto-Dominion Bank (“TD”), the answer is at least $225 million––the amount that TD must now pay to First Horizon Bank, after backing...more
This Article discusses the recent plea agreement between the United States and Danske Bank. It argues that the Department of Justice has advanced a new and evolving theory of liability for foreign banks that access the U.S....more
In 2020, we wrote about the increased regulatory attention on financial institutions’ obligations to detect and respond to human trafficking. In 2021, we wrote about how anti-human trafficking programs fit squarely in banks’...more
This edition of the Update covers: - Recent legal and regulatory developments, including the commencement of cyber security incident notification obligations for critical financial market infrastructure assets, AUSTRAC's...more
For all of its upheaval, cryptocurrency seems like it is here to stay. This presents virtual currency businesses and institutional bankers with a dilemma: Do they capitalize on the increasingly powerful trend, or do they wait...more
On December 6, FinCEN announced that it was issuing an Advanced Notice of Proposed Rulemaking (“AMPRM”) to solicit public comment on potential requirements under the Bank Secrecy Act (“BSA”) for certain persons involved in...more
The Federal Reserve Board, FDIC, and OCC (collectively, the “Agencies”) issued on November 23 a short Joint Statement on Crypto-Asset Policy Sprint Initiative and Next Steps (“Joint Statement”), which announced – without...more
Agencies Issue “Crypto Asset Roadmap” for 2022 Guidance, and OCC Confirms Prior Interpretive Letters on Crypto – So Long as Supervisory Regulators Do Not Object - The Board of Governors of the Federal Reserve System...more
Summary - On August 25, 2021, the Second Circuit unanimously affirmed the lower court’s dismissal of a securities class action accusing Danske Bank and several of its former executives of downplaying a money-laundering...more
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
Banking regulators, the Office of Comptroller of the Currency and the Federal Reserve, recently collected a $400 million civil penalty against Citigroup for long-standing deficiencies in its enterprise risk management,...more
When assessing anti-money laundering risk and exposure, global financial institutions should be mindful of the complex landscape and assertions of broad authority by U.S. authorities and banking regulators. A multinational...more
The Head of the Financial Crime Department at the UK Financial Conduct Authority (the FCA), Rob Gruppetta, gave a speech on "Using artificial intelligence to keep criminal funds out of the financial system" in December 2017....more
There is much for authorised firms to consider in the year ahead. Firms have been through the intensive period of the enactment of the second Markets in Financial Instruments Directive (MiFID II), but must now step up their...more
We discuss two recent federal court opinions addressing two issues of increasing frequency and importance: (i) the potential civil liability of financial institutions to non-customers and other third-parties for alleged...more