News & Analysis as of

Banking Sector Compliance FinCEN

Harris Beach Murtha PLLC

NY Office of Cannabis Management Launches Banking Directory to Support Cannabis Businesses

The New York State Office of Cannabis Management (“OCM”) recently announced it has created a Cannabis Banking Directory (the “Directory”), which currently lists 10 financial institutions servicing cannabis businesses and open...more

Paul Hastings LLP

State-Level Developments: The Regulatory Landscape for Digital Assets

Paul Hastings LLP on

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

Goodwin

FinCEN and Banking Agencies Propose AML Program Rule Updates for Banks and Other Financial Institutions

Goodwin on

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

Mayer Brown

FinCEN Proposes Rule Reinforcing Financial Institutions’ Duty to Design and Maintain Risk-Based AML/CFT Programs

Mayer Brown on

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

ArentFox Schiff

Investigations Newsletter: Deputy Attorney General Monaco Warns Industries: “Fraud Using AI is Still Fraud”

ArentFox Schiff on

On March 7, Deputy Attorney General Lisa Monaco delivered the keynote remarks at the American Bar Association’s (ABA) 39th National Institute on White Collar Crime. She noted that artificial intelligence (AI) “holds great...more

Wilson Sonsini Goodrich & Rosati

FinCEN Proposes Significant Expansion of AML/CFT Obligations to Cover Registered Investment Advisers, Venture Capital Advisers,...

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has proposed a sweeping expansion of the Bank Secrecy Act’s (BSA) affirmative anti-money laundering (AML) and countering the financing of...more

Sheppard Mullin Richter & Hampton LLP

South Dakota Lenders on Tight Deadline for BSA/AML Compliance

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

Farella Braun + Martel LLP

A Simpler Approach To Expanding Banking Access

While the cannabis community anxiously awaits what feels like Congress’ hundredth attempt to pass the SAFE Banking Act, there is one simple step that can be taken today to improve access to banking services for certain...more

A&O Shearman

New York Fines Crypto Trading Platform $30M In First-Ever DFS Crypto Settlement

A&O Shearman on

On August 2, 2022, New York State’s Department of Financial Services (“DFS”) announced that Robinhood Crypto, LLC (“RHC”), a trading platform that allows customers to transact in cryptocurrencies, had agreed to pay a $30...more

Venable LLP

Marijuana Banking in 2022: Lessons Learned and Best Practices

Venable LLP on

​​​​​​​As we pass the halfway mark of 2022, it's a good time to reflect on what has happened, or not happened, with respect to the legal framework for the provision of financial services to marijuana-related businesses...more

Orrick, Herrington & Sutcliffe LLP

FinCEN Pursues Its Next Steps, Posting its Priorities and Pondering a No-Action Process

The Financial Crimes Enforcement Network (FinCEN) has completed two of its early benchmark obligations arising out of the recently passed Anti-Money Laundering Act of 2020 (the “AML Act”)... First, pursuant to the AML Act,...more

WilmerHale

FinCEN Publishes No-Action Letter Analysis and AML/CFT National Priorities

WilmerHale on

The Financial Crimes Enforcement Network (“FinCEN”) has continued a spate of regulatory activity related to financial crimes compliance matters in the first year of the Biden Administration, recapped in its recent report...more

Bradley Arant Boult Cummings LLP

Chambers Global Practice Guide: Fintech 2021 Trends and Developments

Crisis has set the stage for fintech companies in 2021, creating both new opportunities and potentially unprecedented challenges to innovation. While the coronavirus pandemic continues to accelerate the digital transformation...more

Nutter McClennen & Fish LLP

Nutter Bank Report: October 2020

SBA Adopts Streamlined Loan Forgiveness Procedures for PPP Loans of $50,000 or Less - The U.S. Small Business Administration (“SBA”) has adopted an interim final rule to streamline the loan forgiveness application process...more

NAVEX

Clarifying New Customer Due Diligence (CDD) Guidance on PEPs

NAVEX on

Compliance officers in financial services have long struggled with aspects of Customer Due Diligence, better known as the CDD Rule. This fall, compliance professionals are scratching their heads to know exactly how much due...more

Ballard Spahr LLP

Federal banking agencies issue joint statement on enforcement of BSA/AML requirements; FinCEN follows with its own statement

Ballard Spahr LLP on

Regulators Provide Greater Transparency into BSA/AML Enforcement Process. On August 13, 2020, the Federal Reserve System, Federal Deposit Insurance Corporation, National Credit Union Administration, and Office of the...more

Ballard Spahr LLP

Federal Banking Agencies Issue Joint Statement On Enforcement of BSA/AML Requirements; FinCEN Follows With Its Own

Ballard Spahr LLP on

Regulators Provide Greater Transparency into BSA/AML Enforcement Process - On August 13, 2020 the Federal Reserve System, Federal Deposit Insurance Corporation, National Credit Union Administration, and Office of the...more

The Volkov Law Group

FinCEN Issues Guidance for Beneficial Ownership Regulations

The Volkov Law Group on

Financial institutions face an important deadline – May 11, 2018 is the effective date for the new customer due diligence regulations governing beneficial ownership requirements. FinCEN provided financial institutions nearly...more

The Volkov Law Group

The Need for Anti-Money Laundering Regulatory Reform

The Volkov Law Group on

It is rare these days for Republicans and Democrats to agree on political priorities – another profound grasp of the obvious. Recently, on Capitol Hill there appears to be some common ground on the issue of reforming AML...more

The Volkov Law Group

AML Regulation and Compliance Trends

The Volkov Law Group on

Regulators and enforcement agencies continue to pursue aggressive regulations and requirements for financial institutions (a very broad definition under Title 31 of the US Code and regulations). The new administration does...more

The Volkov Law Group

May 2018: D-Day for FinCEN Customer Due Diligence and EU’s General Data Privacy Regulations

The Volkov Law Group on

Chief compliance officers for financial institutions are going to have a rough May 2018. First, on May 11, 2018, the new CDD Rule for beneficial ownership becomes effective. Two weeks later, on May 25, 2018, the EU’s...more

The Volkov Law Group

MoneyGram CCO Pays Civil Penalty

The Volkov Law Group on

Like any other profession, the compliance profession is not immune to bad apples. Lawyers know the law but have been criminally prosecuted for breaking the law. The same goes for compliance professionals....more

The Volkov Law Group

Addressing AML Risks in the Era of Aggressive Enforcement

The Volkov Law Group on

The resurgence in anti-money laundering enforcement in the last few years reflects the overall improvement in the banking industry and recovery from the financial collapse. Federal prosecutors and regulators have renewed...more

K&L Gates LLP

Is Money Being Laundered Through Your Financial Institution Using Daily Fantasy Sports Sites?

K&L Gates LLP on

This alert addresses the explosion in popularity of daily fantasy sports (“DFS”) sites and the money-laundering potential that DFS sites may offer to criminals around the world. It then explains potential legal liability...more

Ballard Spahr LLP

Investment Management Update - October 2015

Ballard Spahr LLP on

Below is a summary of recent investment management developments that affect registered investment companies, private equity funds, hedge funds, investment advisers, and others in the investment management industry. Schwab...more

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