News & Analysis as of

BSA/AML Suspicious Activity Reports (SARs) Federal Deposit Insurance Corporation

Orrick, Herrington & Sutcliffe LLP

FinCEN issues guidance on cross-border information sharing for financial institutions

On September 5, FinCEN, in consultation with the FDIC, NCUA and the OCC, issued guidance to encourage the voluntarily cross-border sharing of information among financial institutions. ...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

Ballard Spahr LLP

FinCEN Issues $15 Million Dollar Civil Penalty Against Shinhan Bank America for Alleged Failure to Implement and Maintain...

Ballard Spahr LLP on

On September 29, the Financial Crimes Enforcement Network (“FinCEN”) entered into a consent order with Shinhan Bank America (“SHBA”), which imposed a $15 million dollar civil penalty against SHBA for allegedly willfully...more

Nutter McClennen & Fish LLP

Nutter Bank Report: January 2021

Updated Annual Meeting Guidance for Mutual Banks and Mutual Holding Companies - The Massachusetts Division of Banks has issued new guidance to mutual banks and mutual holding companies that have not yet held their 2020...more

Ballard Spahr LLP

Banking Regulators Ease SAR Reporting Requirements Applied to Hemp-Related Businesses

Ballard Spahr LLP on

On December 3, 2019, four federal agencies – the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation (“FDIC”), the Financial Crimes Enforcement Network (“FinCEN”), and the Office of the...more

Ballard Spahr LLP

Should the Financial Industry Be Detecting Future Mass Shooters?

Ballard Spahr LLP on

The United States continues to be plagued by mass shootings, which appear to be increasing in both frequency and lethality.  Certain businesses have reacted by adjusting their business models, such as the recent decision by...more

White & Case LLP

Review of Anti-Money Laundering and Sanctions Policy and Enforcement

White & Case LLP on

TABLE OF CONTENTS: Executive Summary - Developments and Trends in Policy and Enforcement - US Department of the Treasury - The Office of Foreign Assets Control - Treasury's Financial Crimes Enforcement Network -...more

Bradley Arant Boult Cummings LLP

Providing Banking Services to the Legal Marijuana Industry: Mitigating Risks to Maximize Potential Rewards

Since 1996, when California became the first state to legalize marijuana (at the time, for medicinal purposes only), 28 additional states and the District of Columbia have legalized marijuana to some extent. Public support...more

Ballard Spahr LLP

Ninth Circuit Court of Appeals Outlines BSA Compliance Obligations and How One Small Bank Failed to Meet Them

Ballard Spahr LLP on

The Tale of an AML BSA Exam Gone Wrong - As we have blogged, the Ninth Circuit Court of Appeals recently upheld the decision of the Board of Directors of the Federal Deposit Insurance Corporation (“FDIC”) to issue a cease...more

Ballard Spahr LLP

Ninth Circuit Court of Appeals Rejects Constitutional Challenge to AML Compliance Program Regulation

Ballard Spahr LLP on

The Ninth Circuit Court of Appeals recently upheld the decision of the Board of Directors of the Federal Deposit Insurance Corporation (“FDIC”) to issue a cease and desist order against California Pacific Bank (the “Bank”)...more

Ballard Spahr LLP

FDIC Provides Some Statistics on Violations Found During BSA/AML Exams: One Percent of Exams Lead to Formal Enforcement Actions

Ballard Spahr LLP on

In its Summer 2017 issue of Supervisory Insights, published last week, the Federal Deposit Insurance Corporation (“FDIC”) provides some insight into its examination process and outcomes for Bank Secrecy Act (“BSA”)/Anti-Money...more

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