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On July 14, 2025, the federal banking agencies issued a joint statement to clarify regulatory expectations for banking organizations that provide or are considering providing safekeeping for crypto-assets (“Joint Statement”)....more
Financial institutions across the United States have grappled with compliance requirements under the Customer Identification Program (CIP) Rule for more than two decades. A new exemption, approved in June 2025, promises...more
On Nov. 19, 2024, the Federal Deposit Insurance Corp. issued a notice of assessment finding that between December 2018 and August 2020, CBW Bank — a single-branch bank in Weir, Kansas — failed to maintain an adequate...more
The OCC released the “OCC Semiannual Risk Perspective for Fall 2024,” which analyzes key risks facing the federal banking system as of mid-2024. Overall, “[t]he OCC reported that the strength of the federal banking system...more
As we begin the 119th Congress, the nation is also preparing for the new administration to take office in just a few weeks. While federal action on digital assets remains a key focus, this week’s Crypto Policy Tracker shifts...more
On November 13, the Fed issued a cease and desist order against a state-chartered bank (respondent), due to alleged deficiencies in its operations and risk management practices related to Bank Secrecy Act (BSA) and anti-money...more
On Oct. 10, Attorney General Merrick Garland announced that TD Bank pled guilty to conspiracy to commit money laundering and agreed to pay over $1.8 billion in penalties to resolve the U.S. Department of Justice's...more
On October 17, the OCC released a list of recent enforcement actions taken against banks and individuals affiliated with national banks, federal savings associations and institution-affiliated parties, or IAPs. The OCC issued...more
On October 1, the OCC released its bank supervision operating plan for fiscal year (FY) 2025. The OCC outlined its supervision priorities and objectives which will guide the implementation of supervisory strategies for...more
Earlier this summer, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Proposed Rule revising its regulations under the Bank Secrecy Act (BSA) requiring financial institutions to...more
The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has proposed a rule to counter money laundering and the financing of terrorism that would add significant compliance requirements for financial...more
On June 28, 2024, the US Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking (“June 2024 NPRM”) to crystalize its long-held expectation that financial institutions use...more
On June 28, 2024, The U.S. Treasury’s Financial Crimes Enforcement Network (“FinCEN”) released a notice of proposed rulemaking (the “Proposed Rule”) that would amend FinCEN’s anti-money laundering (“AML”) program rules for...more
On June 14, the Federal Reserve Board (Fed) released a cease and desist order against an Arkansas-based banking-as-a-service (BaaS) provider for compliance and risk management failures. As part of the order, the bank is...more
The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has recently taken steps to expand the reach of the Bank Secrecy Act (BSA) and related customer identification regulations. These steps build on...more
In a sequel to FinCEN’s proposal earlier this year to extend anti-money laundering and Bank Secrecy Act regulations to investment advisers (AML/BSA Proposal), on May 13, 2024, FinCEN and the SEC jointly issued a new Notice of...more
On January 12, South Dakota’s Division of Banking issued a mandate setting March 31, 2024 as the deadline for all South Dakota licensed money lenders and non-residential mortgage brokers to comply with their Bank Secrecy...more
In the rapidly evolving financial landscape, governments worldwide are intensifying their focus on compliance in Know Your Customer (KYC) and Anti-Money Laundering (AML) efforts for financial institutions. Trade-Based Money...more
The US Office of the Comptroller of the Currency (OCC) on January 29 proposed meaningful revisions to its rules and processes for reviewing proposed transactions involving national banks under the Bank Merger Act. The...more
On January 19, the Federal Reserve Board and NYDFS each issued separate enforcement actions against one of the largest banks in the world for alleged compliance deficiencies and violations under BSA/AML. The Fed issued its...more
Please join Holland & Knight's Financial Services Regulatory Team for a roundtable discussion on what to expect on the financial services landscape in 2024. Our attorneys will present on a wide range of topics in a "3-Minute...more
The Financial Crimes Enforcement Network (“FinCEN”) is statutorily entitled to impose recordkeeping and reporting requirements on domestic financial institutions or nonfinancial trades or business groups when it deems such...more
Shinhan Bank America (“Shinhan”), a New York-based subsidiary of a Korean bank, faced coordinated enforcement actions on September 29 from the Financial Crimes Enforcement Network (“FinCEN”), Federal Deposit Insurance...more
Join Troutman Pepper Partner Chris Willis and fellow Partner Matthew Orso as they discuss the Bank Secrecy Act, anti-money laundering, and countering the financing of terrorism rules, as they pertain to financial institutions...more
On August 2, the Federal Financial Institutions Examination Council (FFIEC) updated its Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual, which provides examiners with instructions for assessing a bank or...more