News & Analysis as of

Financial Institutions Policies and Procedures Enforcement Actions

Cozen O'Connor

Debanking: August 2025 Federal Crackdown Signals New Compliance Imperative

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The rules around account closures and denials of banking services are shifting quickly. Earlier this month, President Trump issued an executive order taking aim at what he describes as “politicized or unlawful debanking.” The...more

Holland & Knight LLP

Will Mariner Finance Decision Lead State Regulators to Bring CFPA Claims?

Holland & Knight LLP on

A lengthy decision recently issued by the U.S. District Court for the Eastern District of Pennsylvania, Pennsylvania by Shapiro v. Mariner Fin., LLC, No. CV 22-3253, 2024 WL 169654 (E.D. Pa. Jan. 12, 2024) (Hodge, J.), may...more

Oberheiden P.C.

OFAC Compliance: Developing and Implementing an Effective Sanctions Compliance Program

Oberheiden P.C. on

Financial institutions and companies that are subject to oversight from the Office of Foreign Assets Control (OFAC) need to prioritize compliance. OFAC has become increasingly active in recent years, and it is devoting...more

Oberheiden P.C.

OFAC Compliance: Avoiding Common Root Causes of Compliance Policy Breakdowns and Deficiencies

Oberheiden P.C. on

For financial institutions and businesses that are subject to the oversight of the Office of Foreign Assets Control (OFAC), compliance needs to be a priority in 2023. OFAC is playing an increasingly active role in overseeing...more

Jenner & Block

Client Alert: SEC’s Approach to Enforcement After Cyber Incidents: Key Takeaways for Public Companies from a Recent Speech

Jenner & Block on

Last month, Gurbir Grewal, the Director of the SEC’s Division of Enforcement, spoke at the Financial Times Cyber Resilience Summit. During the remarks, he outlined the importance of cybersecurity and signaled that the SEC is...more

Sheppard Mullin Richter & Hampton LLP

OCC Revises Policies and Procedures for Civil Money Penalties

On November 29, the OCC released a revised Policies and Procedures Manual relating to the assessment of civil money penalties (“CMP Matrix”), which will be effective as of January 1, 2023. The CMP Matrix is a reference guide...more

American Conference Institute (ACI)

[Event] European Flagship Conference on Anti-Corruption - September 20th - 21st, London, United Kingdom

C5’s 16th International Conference on Anti-Corruption London is taking place on 20–21 September! With so much anticipation to reunite face-to-face and compare notes, don’t miss out on re-connecting with the “who’s who” of the...more

McDermott Will & Schulte

NYDFS—First Enforcement Action under Cybersecurity Regulation

On July 21, 2020, the New York Department of Financial Services (NYDFS) announced that it had filed its first enforcement action under 23 NYCRR 500 (the “Cybersecurity Regulation”) against First American Title Insurance (the...more

Foodman CPAs & Advisors

Instituciones Financieras y el FCPA

La Ley de Prácticas Corruptas en el Extranjero (“Foreign Corrupt Practices Act – FCPA”) prohíbe el pago de sobornos a funcionarios extranjeros para ayudar a obtener o retener negocios.  Exige que las empresas cuyos valores se...more

Foodman CPAs & Advisors

Financial Institutions and the FCPA

The Foreign Corrupt Practices Act (FCPA) prohibits payment of bribes to foreign officials to assist with obtaining or retaining business.  It requires companies whose securities are listed in the US to maintain books and...more

Ballard Spahr LLP

The EU’s Efforts to Combat Money Laundering, the Financing of Terrorism and Corruption Seem to Overlook a Very American Approach:...

Ballard Spahr LLP on

The European Union (“EU”) recently has grappled with a series of massive money laundering scandals and strategized about how to more effectively combat international money laundering and corruption. Generally, the EU has...more

Moore & Van Allen PLLC

SEC Issues Disclosure Guidance as Part of Continued Focus on Cybersecurity

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As cybersecurity attacks have continued to gain prominence as a threat posing critical risk management and compliance challenges for financial institutions, the Securities and Exchange Commission (SEC) has emerged as an...more

Pillsbury Winthrop Shaw Pittman LLP

Beyond BSA Compliance: Human Trafficking Corporate Liability for Small Banks and MSBs

Smaller banks and money services businesses should expand their AML compliance to mitigate human trafficking corporate liability. Aside from the Bank Secrecy Act, federal law creates corporate liability for financial...more

Dorsey & Whitney LLP

SEC Targets Advisers With New Cooperation Initiative

Dorsey & Whitney LLP on

The SEC’s Division of Enforcement announced a new cooperation initiative addressed to investment advisers who have failed to disclose conflicts arising from the receipt of 12b-1 fees from mutual funds. In essence, the...more

Ballard Spahr LLP

OCC Revises its Enforcement Policies and Procedures Manual

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In an update to its Policies and Procedures Manual (PPM), the Office of the Comptroller of the Currency (OCC) has revised PPM 5310-3, “Enforcement Action Policy,” dated September 9, 2011. The PPM sets forth the OCC’s policies...more

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