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Financial Services Industry Bank Secrecy Act AML/CFT

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

Ballard Spahr LLP

Bank Policy Institute Critiques Notice of Proposed Rulemaking to Modernize AML/CFT Programs

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The Bank Policy Institute (“BPI”) has issued its comment on the Federal Functional Regulators’ (the OCC, the Board of Governors of the Federal Reserve System, the FDIC, and the National Credit Union Administration) notice of...more

Ballard Spahr LLP

FinCEN Finalizes Rule Subjecting Investment Advisers to AML/CFT Regulations

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Following up on its Notice of Proposed Rulemaking (“NPR”), which we discussed back in March, the Financial Crimes Enforcement Network (FinCEN) released on August 28th a final rule extending Anti-Money Laundering/Countering...more

Clark Hill PLC

Prudential Regulators Propose Rules Amending Anti-Money Laundering Requirements: Is Your Financial Institution Ready?

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On July 14, the Financial Crimes Enforcement Network (FinCEN) joined the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of...more

Ballard Spahr LLP

DOJ Unveils Corporate Whistleblower Awards Pilot Program – With Implications for Financial Institutions and AML/CFT Compliance...

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On August 1, 2024, the Department of Justice launched its Corporate Whistleblower Awards Pilot Program (the “Pilot Program”). Under this 3-year initiative managed by DOJ’s Criminal Division, a whistleblower may be eligible...more

Troutman Pepper Locke

Troutman Pepper Weekly Consumer Financial Services Newsletter - August 2024

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To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more

Ballard Spahr LLP

Three Members of Congress and U.S. Treasury Express Concerns that Florida Law Prohibiting Banks from Considering Customers’...

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As we previously blogged, a Florida law (Fla. Stat. § 655.0323, entitled “Unsafe and unsound practices”) which became effective July 1, 2024 prohibits federal and state depository institutions conducting business in the state...more

Ballard Spahr LLP

BSA Filings and Their Utility to Law Enforcement:  An Industry Viewpoint

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In this post, we will once again consider the issue of the utility of Bank Secrecy Act (BSA) filings to the global anti-money laundering/countering the financing of terrorism (AML/CFT) compliance regime....more

Troutman Pepper Locke

Following FinCEN’s Lead, Four Federal Banking Regulators Announce AML/CFT Rulemaking

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As discussed here, on June 28, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) proposed significant amendments to the anti-money laundering and countering the financing of terrorism...more

Ballard Spahr LLP

FinCEN Issues Proposed Rulemaking Aimed at Strengthening and Modernizing AML Programs Across Multiple Industries

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On July 3, the Financial Crimes Enforcement Network (FinCEN) published a notice of proposed rulemaking (NPRM) as part of a broader initiative to “strengthen, modernize, and improve” financial institutions’ anti-money...more

Ballard Spahr LLP

Treasury Issues Request for Information on Use of AI in Financial Services

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The U.S. Department of the Treasury (“Treasury”) has released a Request for Information on the Uses, Opportunities, and Risks of Artificial Intelligence (“AI”) in the Financial Services Sector (“RFI”).  Written comments are...more

Ballard Spahr LLP

Treasury Issues Broad National Strategy for Combatting Illicit Financing

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Strategy Touts Regulations on Beneficial Ownership, Real Estate and Investment Advisers, but Bemoans Lack of Supervisory Resources for Non-Bank Financial Institutions...more

Ballard Spahr LLP

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

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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

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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

Seward & Kissel LLP

FinCEN Proposes New Rule to Subject Advisers to AML Requirements

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Who may be interested: Investment Advisers; Closed-End Funds; and Directors of Closed-End Funds - Quick Take: The U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) recently issued a notice of...more

BCLP

FinCEN Proposes AML/CFT Rules for Investment Advisers

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On February 13, 2024, the U.S. Treasury Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking regarding a new proposed rule that would require certain investment advisers to apply anti-money...more

Troutman Pepper Locke

Well, California Has Decided to Regulate Crypto

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On October 13, California Governor Gavin Newsom (D) signed Assembly Bill 39 (Digital Financial Assets Law). This new law broadly empowers the California Department of Financial Protection and Innovation (DFPI) to govern...more

Troutman Pepper Locke

FFIEC Updates Bank Secrecy Act/Anti-Money Laundering Examination Manual

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On August 2, the Federal Financial Institutions Examination Council (FFIEC) announced updates to certain sections and examination procedures in the FFIEC Bank Secrecy Act/Anti-Money Laundering Examination Manual (Manual). The...more

Goodwin

SEC Proposes New Round of Money Market Fund Reforms

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In This Issue. The U.S. Securities and Exchange Commission (SEC) voted to propose money market fund reforms; the SEC also proposed amendments to Rule 10b5-1 trading plans and to modernize and improve share repurchase...more

Goodwin

House Votes to Repeal OCC True Lender Rule

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In This Issue. The House of Representatives voted to pass a Congressional Review Act resolution repealing the Office of the Comptroller of the Currency’s (OCC) “true lender” rule; the Consumer Financial Protection Bureau...more

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