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Banks Anti-Money Laundering Office of the Comptroller of the Currency

Holland & Knight LLP

Executive Order Briefing: Guaranteeing Fair Banking for All Americans

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President Donald Trump on Aug. 7, 2025, signed an executive order (EO or order) titled "Guaranteeing Fair Banking for All Americans," which declares that no American should be denied access to financial services based on...more

King & Spalding

Fed Follows Earlier OCC, FDIC, and NCUA Orders Allowing Banks to Collect TIN Information from Third Parties

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On July 31, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an exemptive order in coordination with the Board of Governors of the Federal Reserve System (the “Fed”) that allows...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

Troutman Pepper Locke

Federal Agencies Release Guidance on Crypto-Asset Safekeeping for Banks

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On July 14, the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (the Board), and the Federal Deposit Insurance Corporation (FDIC) jointly issued a statement addressing the...more

Jones Day

Banking on Crypto: Regulators Clarify Rules for Digital Asset Safekeeping

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Federal banking regulators continue to promote a more "crypto-positive" regulatory environment through recent joint guidance issued to clarify risk management and compliance expectations for banks providing crypto-asset...more

Troutman Pepper Locke

OCC Patriot Bank Order Spotlights AML Issues For Managers

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On Jan. 14, Patriot Bank, based in Stamford, Connecticut, entered into an agreement with the Office of the Comptroller of the Currency to address and rectify several alleged unsafe or unsound practices and violations of law....more

Ballard Spahr LLP

Financial institutions may rely on third parties for Social Security, Taxpayer Identification Numbers

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Banks and credit unions may now rely on third parties to provide a consumer’s Social Security or Taxpayer Identification Number, according to an order issued by the FDIC, OCC and the NCUA with the consent of the Financial...more

Fenwick & West LLP

Bank-Fintech Partnerships Under Scrutiny: What Fintechs Need to Know About AML Expectations

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Bank-fintech partnerships have transformed the financial services landscape, creating new opportunities and challenges for traditional banking institutions and innovative technology companies alike. In a typical arrangement,...more

Troutman Pepper Locke

Strengthening Compliance: Lessons From the OCC's Consent Order With Patriot Bank — Payments Pros – The Payments Law Podcast

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In this episode of Payments Pros, host Carlin McCrory discusses a recent consent order between Patriot Bank and the Office of the Comptroller of the Currency (OCC) following a $27 million loss. The order addresses unsafe...more

Davis Wright Tremaine LLP

Bank Regulatory Considerations in a Second Trump Administration – What Could Change, What Could Stay the Same

While the coming weeks and months will provide more clarity, we already can anticipate some indications of what is in store for bank regulation, supervision, and enforcement in a second Trump Administration. To help navigate...more

Orrick, Herrington & Sutcliffe LLP

OCC releases enforcement actions for October 2024

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

Latham & Watkins LLP

Landmark Bank Secrecy Act Resolution Signals Increasing Focus on Banks’ Anti-Money Laundering Compliance

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Enforcement agencies urge investment in compliance programs. On October 10, 2024, the Department of Justice (DOJ) announced plea agreements with TD Bank N.A. (TDBNA) and its parent company, TD Bank US Holding Company...more

Thomas Fox - Compliance Evangelist

TD Bank: Part 5- The Reckoning

Today, I want to review the OCC Consent Order to see the bank’s requirements. This is separate from the DOJ requirements under the Bank’s Plea Agreement(s) and the FinCEN Consent. Further, the DOJ and OCC have mandated...more

Thomas Fox - Compliance Evangelist

TD Bank: Part 4- Watergate, Actual Knowledge and Conscious Indifference

Mike Volkov often told the story of watching the Watergate Hearings as a teenager and being a seminal influence on his later professional life in the legal profession and government service. It was my first exposure to...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

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

Orrick, Herrington & Sutcliffe LLP

OCC announces enforcement actions for June 2024

On June 17, the OCC released a list of recent enforcement actions against national banks, federal savings associations, and individuals affiliated with such entities (defined as institution-affiliated parties, or IAPs). In...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

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

Ballard Spahr LLP

OCC Risk Perspective Report Focuses on Third-Party Relationships with Fintechs

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In its Fall 2023 Semiannual Risk Perspective, published on December 7, the Office of the Comptroller of the Currency (“OCC”) reported on key issues facing the federal banking system. In evaluating the overall soundness of...more

The Volkov Law Group

TD Bank Eats $225 Million Termination Fee After AML Failures Doom Merger

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How much is an effective Anti-Money Laundering (“AML”) Compliance Program Worth? For Toronto-Dominion Bank (“TD”), the answer is at least $225 million––the amount that TD must now pay to First Horizon Bank, after backing...more

Orrick, Herrington & Sutcliffe LLP

OCC releases enforcement actions

On March 17, the OCC released a list of recent enforcement actions taken against national banks, federal savings associations, and individuals currently and formerly affiliated with such entities. ...more

Ballard Spahr LLP

Democratic Senators send letter to federal banking agencies raising concerns about fraudulent transactions

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A group of five Democratic Senators have sent a letter to the Federal Reserve, OCC, FDIC, and NCUA asking them to take several steps to protect consumers from scams when using Zelle to transfer money....more

McGuireWoods LLP

Bank Regulators Remind Financial Institutions Not to Take a One-Size Fits All Approach to Assessing AML Risks from Customer...

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The Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Financial Crimes Enforcement Network, the National Credit Union Administration, and the Office of the Comptroller of the...more

Sheppard Mullin Richter & Hampton LLP

OCC and FinCEN Issue $200 Million in Penalties for BSA-AML Violations

On March 17, the OCC and FinCEN issued civil monetary penalties against a federal savings bank for “willfully” failing to meet minimum compliance program requirements and shoddy suspicious transaction reporting. The consent...more

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