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Amundsen Davis LLC

President Trump Takes Action to Ensure Fair Banking for All Americans

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On August 7, 2025, President Donald J. Trump signed an executive order titled “Guaranteeing Fair Banking for All Americans.” The order asserts that financial institutions have restricted the access of individuals and...more

Morrison & Foerster LLP

Crypto-Asset Safekeeping: What’s Involved If You’re a Bank (or if You Want to Be One)

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

Latham & Watkins LLP

Banking Agencies Issue Joint Statement on Risk-Management Considerations for Cryptoasset Safekeeping

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Banking organizations safekeeping digital assets for customers must do so in a safe and sound manner and in compliance with applicable laws and regulations....more

Bradley Arant Boult Cummings LLP

A New Rule Embraces Modernity in the Customer Identification Process

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

Bradley Arant Boult Cummings LLP

Kansas Bank's Suit Could Upend FDIC Enforcement Authority

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

Orrick, Herrington & Sutcliffe LLP

FDIC Acting Chairman Hill outlines his agenda

On January 20, the FDIC appointed Travis Hill as Acting Chairman. In a prepared statement the next day, Hill outlined his agenda to address changes at the Corporation. Among other efforts, he announced a wholesale review of...more

Orrick, Herrington & Sutcliffe LLP

OCC discusses key risks in federal banking system

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

Orrick, Herrington & Sutcliffe LLP

Fed issues two cease and desist orders against banks

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

Bradley Arant Boult Cummings LLP

$3B TD Bank AML Settlement Is A Wake-Up Call For All Banks

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

Troutman Pepper Locke

Navigating Regulatory Waters: Recent Enforcement Actions in BaaS — Payments Pros – The Payments Law Podcast

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In the latest episode of Payments Pros, hosts Carlin McCrory and Keith Barnett are joined by James Stevens to discuss recent enforcement actions in the banking as a service (BaaS) space. They delve into regulatory trends,...more

Orrick, Herrington & Sutcliffe LLP

OCC releases FY 2025 bank supervision operating plan

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

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

Orrick, Herrington & Sutcliffe LLP

FDIC releases seven enforcement actions for June and July 2024

On August 30, the FDIC released a list of seven administrative enforcement actions taken against banks and individuals in June and July. The public orders comprised six safety and soundness orders, two of which were consent...more

Orrick, Herrington & Sutcliffe LLP

FinCEN Proposes Changes to Anti-Money Laundering Program Requirements for Financial Institutions: 5 Things to Know

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

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

Cadwalader, Wickersham & Taft LLP

FinCEN and Federal Banking Agencies Propose Amendments to Anti-Money Laundering Rules

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

Sheppard Mullin Richter & Hampton LLP

Federal Reserve Board Issues Cease and Desist Order Against Banking-As-A-Service Provider

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

Skadden, Arps, Slate, Meagher & Flom LLP

FinCEN Seeks To Expand Reach of the BSA and Modernize Customer Identification Regulations

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

Jenner & Block

Client Alert: A Second Wave: FinCEN and SEC Further Extend Investment Advisers’ AML Obligations with New CIP Requirements

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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

Orrick, Herrington & Sutcliffe LLP

House Committee report finds broad financial surveillance by federal government using financial institutions data following...

On March 5, the Committee on the Judiciary and its Select Subcommittee on the Weaponization of the Federal Government released an interim staff report on how federal law enforcement agencies, in the wake of the events of...more

Womble Bond Dickinson

Navigating the Labyrinth: Artificial Intelligence in the Battle Against Trade-Based Money Laundering

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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

Morgan Lewis - All Things FinReg

OCC Proposes Substantive and Procedural Revisions for Bank Mergers

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

Nutter McClennen & Fish LLP

Nutter Bank Report: December 2023

A recent OCC report identified key issues facing the federal banking system, including increasing credit risk due to higher interest rates, increasing risk in commercial real estate lending, prolonged inflation, declining...more

Cranfill Sumner LLP

FinCEN Issues Updated Geographic Targeting Order Expanding the List of High-Risk Jurisdictions in Which Title Insurers Must Report...

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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

Davis Wright Tremaine LLP

Banking and Consumer Regulatory Digest - October 2023

The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically focusing on:...more

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