News & Analysis as of

Financial Institutions BSA/AML

Ballard Spahr LLP

32 Attorneys General call for enactment of marijuana banking legislation

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Thirty-two attorneys general representing states, territories and Washington, D.C. are asking Congress to pass legislation to provide financial institutions a safe harbor if they provide services to marijuana-related...more

Morgan Lewis

Financial Institutions Face Investigations and Possible Referral to DOJ Based on Past ‘Debanking’ Practices

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An executive order signed by the US president on August 7, 2025, titled Guaranteeing Fair Banking for All Americans, seeks to prohibit financial institutions from engaging in “debanking” practices, such as denying services or...more

A&O Shearman

Wolfsberg Group issues statement on the RBA for financial crime risk management

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The Wolfsberg Group (the Group) has released a statement reaffirming its commitment to the risk-based approach (RBA) for financial crime risk management. Further to its 2006 RBA guidance, and in line with the Financial Action...more

Ballard Spahr LLP

FDIC clarifies that CIP Rule does not preclude using pre-populated customer information

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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

Bradley Arant Boult Cummings LLP

How Banks Can Harness New Customer ID Rule's Flexibility

Financial institutions across the U.S. have grappled with compliance requirements under the Customer Identification Program, or CIP, rule for more than two decades. On June 27, the Federal Deposit Insurance Corp., the...more

Womble Bond Dickinson

Update on 2025 U.S. Stablecoin Legislation

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In July 2025, the U.S. Congress advanced a landmark package of legislative measures aimed at establishing a comprehensive federal framework for the regulation of cryptocurrencies and stablecoins. ...more

BCLP

The GENIUS Act Ushers in a New Era for Stablecoin Regulation

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On July 17, 2025, Congress passed the Guiding and Establishing National Innovation for U.S Stablecoins Act (“GENIUS Act” or “Act”) – a landmark piece of legislation that received bipartisan support and was signed into law by...more

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

Ballard Spahr LLP

FinCEN Delays And Intends To Revisit Investment Adviser Final Rule

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We blogged last year about the Final Rule issued by the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) extending Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT)...more

Latham & Watkins LLP

Banking Agencies Issue Joint Statement on Risk-Management Considerations for Cryptoasset Safekeeping

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Banking organizations safekeeping digital assets for customers must do so in a safe and sound manner and in compliance with applicable laws and regulations....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

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

Skadden, Arps, Slate, Meagher & Flom LLP

The CIP Rule Gets an Upgrade: What Banks and Fintechs Need to Know About the New Exemption

Key Points - On June 27, 2025, the Federal Deposit Insurance Corporation (FDIC), the Office of Comptroller of the Currency (OCC) and the National Credit Union Administration (NCUA) exempted supervised banks and credit...more

Troutman Pepper Locke

Recent SEC AML Enforcement Actions’ Impact on Compliance Efforts in the Cannabis Sector

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Investing in the cannabis industry is not without its risks, given the evolving regulatory landscape and the varying state and federal statuses of the product itself. The Financial Crimes Enforcement Network (FinCEN) has...more

Gordon Rees Scully Mansukhani

Recent SEC AML Enforcement Against Securities Firms Engaged in Cannabis Sector

The evolving regulatory landscape for marijuana-related businesses poses unique compliance challenges for firms in the securities industry. The Financial Crimes Enforcement Network (“FinCEN”) continues to enforce its 2014...more

Ankura

Challenges in Data Sharing between Banking Partners

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Life in the United States and most modern industrialized countries is driven primarily by data. Google alone processes 20 Petabytes of data every day (1 petabyte = 1 million gigabytes. Economies are built on data; marketing...more

Carlton Fields

Recent SEC AML Enforcement Actions and Likely Continued AML Emphasis Under New Administration

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Registered investment advisers have until January 1, 2026, to comply with the anti-money laundering (AML) compliance provisions of the Bank Secrecy Act (BSA). However, the SEC has recently charged two investment advisers with...more

Troutman Pepper Locke

OFAC Recordkeeping Requirement Extended to 10 Years

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On March 20, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a final rule extending the recordkeeping requirements under OFAC’s regulations from five years to 10 years. This change...more

Orrick, Herrington & Sutcliffe LLP

OCC releases March 2025 enforcement actions

On March 20, the OCC released a list of recent enforcement actions taken against national banks, federal savings associations, and individuals affiliated with supervised banks. Among the actions taken, the OCC issued a cease...more

Orrick, Herrington & Sutcliffe LLP

RegFi Episode 59: Don’t Sleep on the States: Financial Regulatory, Compliance & Enforcement Trends

RegFi co-hosts Jerry Buckley and Sherry Safchuk welcome fellow Orrick partner Katy Ryan to discuss the state financial regulatory landscape. Katy provides an overview of how federal agencies and states interact in our...more

Troutman Pepper Locke

Patriot Bank and OCC Sign Agreement to Strengthen Oversight and Payment Activities

Troutman Pepper Locke on

On January 14, Patriot Bank, N.A. entered into an agreement with the Office of the Comptroller of the Currency (OCC) to address and rectify several unsafe or unsound practices and violations of law. This agreement follows the...more

Ballard Spahr LLP

Patriot Bank Enters Agreement with OCC to Address Regulatory Concerns

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On February 20, 2025, the Office of the Comptroller of the Currency (“OCC”) announced that they had entered into a formal agreement with Patriot Bank, National Association (“Patriot Bank”), following a comprehensive...more

K&L Gates LLP

Lessons From 2024 Anti-Money Laundering Enforcement Actions

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In 2024, FinCEN and the federal bank regulators announced more than three dozen enforcement actions against banks and individuals arising from alleged Bank Secrecy Act (BSA), anti-money laundering (AML), and countering the...more

Ankura

Quality Control Unveiled: Insights from Transaction Monitoring

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Ensuring high-quality standards in any organization is an essential ingredient that must be rooted within a company’s Quality Management Program (QMP) – a program that creates a framework to ensure quality....more

Orrick, Herrington & Sutcliffe LLP

Congressional Research Service report highlights de-banking risks

On January 29, the Congressional Research Service (CRS) released a report on the challenges banks may face in providing services to certain individuals and businesses. The CRS’s report was based on the perception that an...more

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