News & Analysis as of July 30, 2025

National Credit Union Administration

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The Financial Crimes Enforcement Network (FinCEN) is a bureau of the U.S. Department of the Treasury charged with detecting and combatting illegal activity within the financial system. FinCEN detects evidence of money laundering, terrorist financing and other financial crimes by collecting, monitoring, and analyzing financial transaction data. Such data is disseminated to both domestic and international law enforcement agencies. less -

The GENIUS Act Ushers in a New Era for Stablecoin Regulation

BCLP on 7/30/2025

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

Agencies allow banks to access tax ID numbers from third parties

Orrick, Herrington & Sutcliffe LLP on 7/7/2025

On June 27, the OCC, FDIC and NCUA, with the concurrence of FinCEN, granted an exemption allowing banks to use a third party source to obtain customer tax identification numbers (TIN) for customers before opening an account....more

Financial institutions may rely on third parties for Social Security, Taxpayer Identification Numbers

Ballard Spahr LLP on 7/1/2025

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

Federal Agencies Issue Order Granting Exemption for Financial Institutions on TIN Collection

Troutman Pepper Locke on 6/30/2025

The Office of the Comptroller of the Currency (OCC), alongside the Federal Deposit Insurance Corporation (FDIC) and the National Credit Union Administration (NCUA) (collectively, the agencies), with concurrence from the...more

Interagency Statement on Elder Financial Exploitation

Bressler, Amery & Ross, P.C. on 12/18/2024

On December 4, an Interagency Statement on Elder Financial Exploitation (the “Interagency Statement”) was issued by the Board of Governors of the Federal Reserve System (FRB), Consumer Financial Protection Bureau (CFPB),...more

Agencies issue guidance on elder financial exploitation

Orrick, Herrington & Sutcliffe LLP on 12/12/2024

On December 4, the CFPB, the FDIC, the Fed, FINCEN, the NCUA, the OCC and state financial regulators issued a statement titled the “Interagency Statement on Elder Financial Exploitation” to provide supervised financial...more

Federal and State Financial Agencies Issue Guidance on Elder Financial Exploitation

Troutman Pepper Locke on 12/6/2024

Earlier this week, the Board of Governors of the Federal Reserve System (FRB), Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Financial Crimes Enforcement Network (FinCEN), National...more

Daily Financial Regulation Update -- Thursday December 5

Paul Hastings LLP on 12/5/2024

December 4, 2024- The U.S. House Committee on Financial Services held a hearing entitled “Innovation Revolution: How Technology is Shaping the Future of Finance.”...more

Daily Financial Regulation Update -- Wednesday October 16

Paul Hastings LLP on 10/16/2024

October 15, 2024 - The Federal Reserve Board released the minutes from its recent meetings to review and determine the discount rates provided to depository institutions through the discount window. The minutes cover the...more

FinCEN’s Proposed AML/CFT Program Rule Potentially Heralds a Change in Approach

WilmerHale on 7/25/2024

On June 28, 2024, the US Department of the Treasury’s Financial Crimes Enforcement Network announced long-anticipated proposed rules on anti-money laundering and countering the financing of terrorism program effectiveness;...more

South Dakota Lenders on Tight Deadline for BSA/AML Compliance

Sheppard Mullin Richter & Hampton LLP on 2/19/2024

On January 12, South Dakota’s Division of Banking issued a mandate setting March 31, 2024 as the deadline for all South Dakota licensed money lenders and non-residential mortgage brokers to comply with their Bank Secrecy...more

Daily Financial Regulation Update -- Friday, December 22 2023

Paul Hastings LLP on 12/22/2023

December 21, 2023- The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) took another major step in support of U.S. Government efforts to crack down on illicit finance and enhance corporate...more

Daily Financial Regulation Update -- Thursday, December 21 2023

Paul Hastings LLP on 12/22/2023

December 20, 2023- U.S. House Committee on Financial Services Chair Patrick McHenry (NC-10) and Congressman Mike Flood (NE-01) led 18 of their colleagues on a letter to Consumer Financial Protection Bureau Director Rohit...more

Daily Financial Regulation Update -- Friday, November 17, 2023

Paul Hastings LLP on 11/17/2023

November 16, 2023- The Financial Crimes Enforcement Network (FinCEN) has updated its Beneficial Ownership Information FAQs to include new questions about the reporting process, reporting companies, beneficial owners,...more

Banking and Consumer Regulatory Digest - October 2023

Davis Wright Tremaine LLP on 10/16/2023

The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically focusing on:...more

Daily Financial Regulation Update -- Friday, September 29, 2023

Paul Hastings LLP on 9/29/2023

September 28, 2023- The U.S. House Committee on Small Business Subcommittee on Rural Development, Energy, and Supply Chains held a hearing titled "Energy Independence: How Burdensome Energy Regulations are Crushing Small...more

Daily Financial Regulation Update -- Friday, June 30, 2023

Paul Hastings LLP on 7/3/2023

June 29, 2023- Federal financial institution regulatory agencies today jointly issued a final policy statement on commercial real estate loan accommodations and workouts....more

Daily Financial Regulation Update -- Saturday, April 22, 2023

Paul Hastings LLP on 4/24/2023

April 21, 2023- The Financial Stability Oversight Council (Council) voted unanimously to issue for public comment a proposed analytic framework for financial stability risks. The Council also voted unanimously to issue for...more

Top PHive Crypto Enforcement Notes: November Edition

Paul Hastings LLP on 11/4/2022

It certainly feels like a race between innovation and enforcement these days, with regulators and law enforcement stepping up the cautionary rhetoric and promising broader enforcement aimed at corporate actors....more

Daily Financial Regulation Update -- Friday, September 9, 2022

Paul Hastings LLP on 9/9/2022

Hearing: Current Issues in Insurance- September 8, 2022- The U.S. Senate Committee on Banking, Housing, and Urban Affairs held a hearing entitled, "Current Issues in Insurance."...more

Five Federal Agencies Issue Joint Statement on Approach to Customer Due Diligence

Cadwalader, Wickersham & Taft LLP on 7/8/2022

On July 6, five federal agencies − the Board of Governors of the Federal Reserve System (“FRB”), Federal Deposit Insurance Corporation (“FDIC”), Financial Crimes Enforcement Network (“FinCEN”), National Credit Union...more

Agencies Request Information To Assist With BSA Laws And Regulations Compliance

Foodman CPAs & Advisors on 5/6/2021

On April 9, 2021, the federal banking regulatory agencies (the Federal Reserve, FDIC and OCC) together with FinCEN and the National Credit Union Administration issued a joint statement addressing how risk management...more

Agencies Emphasize Risk-Based Due Diligence Approach for Charities and Nonprofits

Morgan Lewis - All Things FinReg on 11/23/2020

The Agencies issued a joint Fact Sheet that lists considerations for a risk-based approach when it comes to charities and nonprofits. While the Fact Sheet purports to not impose additional obligations on banks, it is hard to...more

While FinCEN lacks Independent Litigating Authority, it is the Regulator for the BSA and is responsible for the administration of...

Foodman CPAs & Advisors on 11/4/2020

FinCEN issues implementing regulations that “ensure” compliance with the BSA. FinCEN delegates its examination authority to federal agencies. These federal agencies are the “Federal Functional Regulators” who supervise...more

Federal Banking Agencies Exempt Premium Finance Lending from BSA/AML Customer Identification Program Requirements

Orrick - Finance 20/20 on 10/28/2020

On October 9, the Office of the Comptroller of the Currency (OCC), Board of Governors of the Federal Reserve System (Federal Reserve), Federal Deposit Insurance Corporation (FDIC), and National Credit Union Administration...more

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