Strengthening Compliance: Lessons From the OCC's Consent Order With Patriot Bank — Payments Pros – The Payments Law Podcast
BSA, OFAC, KYC, and CIP – What do they mean to me? [More with McGlinchey, Ep. 29]
After a long weekend, Finance Manager Joe sits at his desk to read his emails. One of the emails is from a trusted vendor with whom the Joe communicates on a regular basis, regarding an unpaid invoice that is due immediately....more
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
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
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
On August 5, 2025, the Federal Deposit Insurance Corporation (FDIC) issued FIL-39-2025 to state that an FDIC-supervised institution can use pre-populated customer information to satisfy the requirements of the Customer...more
In a significant move, on June 27, 2025 the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an order granting banks and their subsidiaries an exemption from the Customer Identification...more
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
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
Introduction - On 13 May 2024, the Securities and Exchange Commission (SEC) and the US Department of Treasury’s (DoT) Financial Crimes Enforcement Network (FinCEN) jointly proposed rulemaking to implement Section 326 of the...more
On March 28, 2024, the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”), in consultation with the staffs of the federal banking agencies, issued a request for information and comment (the “RFI”)...more
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
Long awaited rules for “Customer Due Diligence Requirements for Financial Institutions” (the CDD Rules) went into effect on May 11, 2018. FinCEN has taken steps to clarify and refine implementation of the CDD Rules, issuing...more
Effective May 11, 2018, covered financial institutions are required to comply with the customer due diligence rule (the Rule) that the Financial Crimes Enforcement Network (FinCEN) finalized in May 2016. The Rule mandates the...more
Editor's Note - Investment Advisers Breathe a Sigh of Relief. On Thursday, August 25, the federal district court in New Jersey ruled after a 26-day trial in favor of AXA Equitable Insurance Company and against the...more
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
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