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In June 2025, the ABA held its annual Risk and Compliance Conference. The conference heavily focused on how banks are leveraging AI to support front-, middle-, and back-office functions. Conference participants noted that...more
In an era of stringent regulations and increasing legal risks, it has become essential for organizations to implement internal enforcement programs. However, in order for such programs to provide legal protection, they must...more
The UK Prudential Regulation Authority (PRA) has published a policy statement on the identification and management of step-in risk (PS5/25). The policy statement provides feedback on responses to consultation paper (CP) 23/23...more
The UK Financial Conduct Authority (FCA) has published a webpage summarising the findings of its multi-firm review on retail banks' treatment of customers in vulnerable circumstances involving bereavement and power of...more
On April 15, the FDIC announced updated guidance on sending official correspondence related to supervisory matters. The FDIC’s guidance made permanent those temporary, previous measures for electronically sending and...more
Outcomes testing and monitoring under the Consumer Duty, and senior management engagement with these areas, remain key focus areas for the FCA. Whilst the review in question focuses specifically on the treatment of customers...more
As we have previously noted, we expect that the second Trump Administration will be significantly more favorable to crypto than the Biden Administration, especially with the recent appointment of David Sacks as the...more
The Bank of England has published a policy statement on its approach to enforcement and an updated Statement of Policy And Procedure on its approach to enforcement. The update follows the Financial Services and Markets Act...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 Digital Operational Resilience Act EU 2022/2554 (DORA) constitutes a groundbreaking EU regulation designed to establish a unified framework for bolstering cybersecurity and operational resilience within the financial...more
This article identifies themes we have observed in recent public formal enforcement actions issued to institutions by the US federal bank regulatory agencies (Agencies) — the Board of Governors of the Federal Reserve System...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
Editor's Note: 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...more
Since December 2021, the U.S. Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) have levied almost $3.0 billion in penalties for longstanding failures by 39 broker-dealers, swap dealers,...more
Am 15. Januar 2024 wurde die Wertpapierinstituts-Inhaberkontrollverordnung im Bundesgesetzblatt verkündet, die Verordnung ist am heutigen Tage in Kraft getreten. Inhaberkontrollverfahren bei Wertpapierinstituten - Die...more
Despite bank policies, training, computer warning banners, governing laws and banking regulations, bank employees still take bank or customer data as their employment ends. They take potential or current customer lists,...more
The latest proposals for improving diversity and inclusion in the UK financial services sector, published by the Financial Conduct Authority and Prudential Regulation Authority, include changes that will impact Senior Manager...more
The Financial Conduct Authority (FCA) and Prudential Regulation Authority’s (PRA) recent proposals demonstrate a divergence in approach when it comes to individual accountability and expectations of senior management in...more
Guidance for the largest US financial institutions is intended to promote climate risk management consistent with general safety and soundness practices. On October 30, 2023, the three US federal bank regulatory agencies...more
Last week, the Consumer Financial Protection Bureau issued its long-awaited proposed rule to implement Section 1033 of the 2010 Consumer Financial Protection Act, which has come to be known as the “open banking” provision...more
On June 14, 2023, the Office of the Comptroller of the Currency (OCC) published its Semiannual Risk Perspective which identifies key issues facing the federal banking system. This highly anticipated report comes in the wake...more
Agencies Issue Final Guidance on Third-Party Risk Management - On June 6, the Federal Reserve, FDIC, and OCC issued final joint guidance (the Guidance) pertaining to banking organizations’ risk management of third-party...more
On May 9, New York State Department of Financial Services (DFS or the Department) Superintendent Adrienne A. Harris issued proposed guidance to clarify the DFS’s updated expectations regarding the review and assessment of the...more
Competent management of business information is a challenge for organizations across industries, but banking and financial services organizations face heightened information governance challenges that require dedicated...more
In Philipp v Barclays Bank UK PLC, the Court of Appeal held that the Quincecare duty may apply to direct customer instructions (not just those through an agent), such that banks may be liable for failing to protect against...more