News & Analysis as of

Banks AML/CFT

Alston & Bird

Financial Institutions Permitted to Use Third Parties to Collect Customers’ Taxpayer Identification Numbers for Identity...

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Our Financial Services and White Collar, Government & Internal Investigations Teams examine the Financial Crimes Enforcement Network’s new customer identification program (CIP) exemption that allows banks and credit unions to...more

Vedder Price

The GENIUS Act: Stablecoin Regulation Enters the Federal Framework

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On July 18, 2025, President Trump signed the Guaranteed Essential National Infrastructure for U.S. Act (the “GENIUS Act”) into law, marking the first comprehensive U.S. federal regulatory framework for payment stablecoins. ...more

Thomas Fox - Compliance Evangelist

Compliance Tip of the Day: Citibank and Continuous Monitoring

Welcome to “Compliance Tip of the Day,” the podcast that brings you daily insights and practical advice on navigating the ever-evolving landscape of compliance and regulatory requirements. Whether you’re a seasoned compliance...more

Morrison & Foerster LLP

FinCEN Postpones Effective Date of AML/CFT Rule for Investment Advisers

On July 21, 2025, the U.S. Department of the Treasury’s (“Treasury”) Financial Crimes Enforcement Network (FinCEN) announced it will delay the effective date of the final rule establishing anti-money laundering/countering the...more

Secretariat

Guardians of Finance Integrity, How the NY Fed’s Oversight in Iraq and Libya Could Hold a Blueprint for Post-Conflict...

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The Federal Reserve Bank of New York (FRBNY) has cemented its role as a global financial watchdog, using its influence to safeguard the integrity of the U.S. dollar and the broader international financial system. Recent...more

Ballard Spahr LLP

FinCEN Withdraws Designation of ABLV Bank as Foreign Financial Institution “Of Primary Money Laundering Concern”

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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

Bradley Arant Boult Cummings LLP

New FDIC Recordkeeping Requirements: Director Chopra Cautions Against a New Form of “Rent-a-Bank”

On September 17, 2024, the Federal Deposit Insurance Corporation (FDIC) rulemaking board proposed new recordkeeping rules intended to bolster the FDIC’s ability to make deposit insurance determinations for accounts that are...more

Perkins Coie

What Is an “Effective AML/CFT Compliance Program”?

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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

Latham & Watkins LLP

Agencies Issue Joint Proposal to Amend Bank Secrecy Act Compliance Programs for Banks

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On July 19, 2024, the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), and the National Credit Union Administration...more

Ballard Spahr LLP

Three Members of Congress and U.S. Treasury Express Concerns that Florida Law Prohibiting Banks from Considering Customers’...

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As we previously blogged, a Florida law (Fla. Stat. § 655.0323, entitled “Unsafe and unsound practices”) which became effective July 1, 2024 prohibits federal and state depository institutions conducting business in the state...more

Troutman Pepper Locke

Federal Banking Agencies Reiterate Guidance on Managing Risks Posed By Fintech Partnerships and Other Third Party Relationships

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Last week, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (collectively, the agencies) issued a joint statement highlighting...more

Ballard Spahr LLP

FinCEN Issues Proposed Rulemaking Aimed at Strengthening and Modernizing AML Programs Across Multiple Industries

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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

Jones Day

Australian Financial Services Regulatory Update | January-June 2024

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Recent legal and regulatory developments, including the joint release of APRA and ASIC guidance concerning the new Financial Accountability Regime, APRA's announcement that it will publish superannuation expense data to...more

Ballard Spahr LLP

Federal Banking Agencies Issue Guide to Third-Party Risk Management Practices for Community Banks

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On May 3, 2024, the Board of Governors of the Federal Reserve System (the “Federal Reserve”), the Federal Deposit Insurance Corporation (“FDIC”), and the Office of the Comptroller of the Currency (“OCC”) jointly released the...more

Ballard Spahr LLP

Recent FDIC Consent Orders Reflect Ongoing Scrutiny of Bank Relationships with Fintechs

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In February 2024, the Federal Deposit Insurance Corporation (FDIC) entered into consent orders with two banks who partner with fintechs to offer “banking as a service” (BaaS) related to safety and soundness concerns relating...more

Ballard Spahr LLP

Recent FDIC consent orders show increased regulation scrutiny of bank relationships with fintech partners

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In February 2024, the Federal Deposit Insurance Corporation (FDIC) entered into consent orders with two banks who partner with fintechs to offer “banking as a service” (BaaS) related to safety and soundness, compliance with...more

Latham & Watkins LLP

FDIC Proposes Revisions to Policy on Bank Merger Transactions

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The Proposal clarifies the FDIC’s bank merger approval process but may prove challenging for new large bank consolidations with the FDIC as the primary regulator. On March 21, 2024, the Board of Directors of the Federal...more

A&O Shearman

Key Regulatory Topics: Weekly Update 8 - 14 Mar 2024

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There were some key publications this week in relation to financial crime, including a Commission request for the EBA to advise on standards and guidelines under the future AML/CFT framework in Europe and, in the UK, an HMT...more

Cadwalader, Wickersham & Taft LLP

FinCEN’s Proposed Rulemaking: Enhancing Transparency in Residential Real Estate

While many Americans are struggling to achieve the dream of homeownership, there are criminals that abuse the housing market for financial gain. To avoid the scrutiny of financial institutions that have anti-money laundering...more

Orrick, Herrington & Sutcliffe LLP

FDIC releases November enforcement actions

On December 29, the FDIC released a list of administrative enforcement actions taken against banks and individuals in November. The FDIC made 12 orders public including, “five consent orders, three prohibition orders, two...more

Ballard Spahr LLP

Bipartisan Group of Senators Re-Introduce the Digital Asset Money Laundering Act

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Legislation Targets Unhosted Wallets, Validators and Digital Asset ATMs - On July 28th, Senators Elizabeth Warren (D-Mass), Roger Marshall (R-Kan.), Joe Manchin (D-W.Va.) and Lindsey Graham (R-S.C.), reintroduced the...more

Walkers

What can we learn from recent enforcement actions in the Cayman Islands?

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Walkers' regulatory partners Lucy Frew and Ian Mason consider the learning points for financial services providers (FSPs) from recent enforcement actions by Cayman regulatory bodies. While financial services and related...more

Davis Wright Tremaine LLP

The Digital Pound: "More Likely Than Not"

On February 7, 2023, the Bank of England (BoE) released two documents concerning a central bank digital currency (CBDC), a prospective government-backed digital form of U.K. currency also known as the "digital pound." ...more

BakerHostetler

CBDC Pilot Announced; Ethereum Upgrade Completed; U.S. Treasury Department Addresses DeFi Risks; Studies Analyze Crypto Taxation,...

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Montenegro Announces CBDC Pilot, BIS Compares CBDCs to Stablecoins - According to a recent press release, “The Central Bank of Montenegro (CBCG) has agreed to collaborate with the enterprise crypto and blockchain solutions...more

K2 Integrity

One Year Later Implementing Sanctions Against Russia

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Approximately one year ago, in the immediate wake of Russia’s full-scale invasion of Ukraine, the United States (U.S.), United Kingdom (UK), and European Union (EU) launched a global sanctions campaign against Russia that...more

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