News & Analysis as of

Banks Customer Identification Program (CIP) Bank Secrecy Act

Orrick, Herrington & Sutcliffe LLP

FDIC Approves Use of Pre-Populated Customer Information During Account Opening

On August 5, the FDIC announced that banks it supervises can comply with Bank Secrecy Act (BSA) requirements to obtain identity information from new customers by using a pre-populated form, provided that the person opening...more

Orrick, Herrington & Sutcliffe LLP

Fed joins agencies in allowing banks to access tax ID numbers from third parties

On July 31, the Fed, with the concurrence of FinCEN, issued an order exempting banks supervised by the Fed from a Customer Identification Program (CIP) rule implementing Section 326 of the USA PATRIOT Act. As previously...more

Morrison & Foerster LLP

No Full TIN, No Problem: FinCEN Approves of TIN Verification Through a Third Party

On June 27, 2025, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an order (Order) allowing banks,[1] and their subsidiaries, subject to the jurisdiction of the Office of the Comptroller...more

Troutman Pepper Locke

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

Troutman Pepper Locke on

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

Ballard Spahr LLP

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

Ballard Spahr LLP on

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

Ballard Spahr LLP on

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

McGlinchey Stafford

BSA, OFAC, KYC, and CIP – What do they mean to me? [More with McGlinchey, Ep. 29]

McGlinchey Stafford on

The Bank Secrecy Act (BSA) and parts of the U.S. Patriot Act’s Office of Foreign Asset Control (OFAC) requirements have seemingly similar goals: to prevent money laundering and the funding of terrorist activities. Yet a...more

Cozen O'Connor

New FinCEN Proposal Will Extend AML Rules to Currently Exempt Banks and Other Institutions

Cozen O'Connor on

Seeking to close a perceived “gap” in regulations intended to facilitate the government’s efforts to curb money laundering and the financing of terrorism, the U.S. Department of the Treasury’s Financial Crimes Enforcement...more

Goodwin

FinCEN Issues Final Customer Due Diligence Rule

Goodwin on

The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has expanded the due diligence obligations of certain financial institutions that are subject to a customer identification program requirement under...more

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