News & Analysis as of

FinTech FinCEN Bank Secrecy Act

Bradley Arant Boult Cummings LLP

A New Rule Embraces Modernity in the Customer Identification Process

Financial institutions across the United States have grappled with compliance requirements under the Customer Identification Program (CIP) Rule for more than two decades. A new exemption, approved in June 2025, promises...more

Orrick, Herrington & Sutcliffe LLP

FDIC Acting Chairman Hill supports flexibility for customer identification program requirements

On February 7, the FDIC’s Acting Chairman Travis Hill released a letter to FinCEN Director Andrea Gacki conveying support for updates to the Customer Identification Program requirements to align with modern practices. ...more

Troutman Pepper Locke

FDIC Acting Chairman Hill Supports Modernizing Customer Identification Program Requirements

Troutman Pepper Locke on

In a recent letter to Andrea Gacki, Director of the Financial Crimes Enforcement Network (FinCEN), Federal Deposit Insurance Corporation (FDIC) Acting Chairman Travis Hill expressed his support for updating the Customer...more

Paul Hastings LLP

State-Level Developments: The Regulatory Landscape for Digital Assets

Paul Hastings LLP on

As we begin the 119th Congress, the nation is also preparing for the new administration to take office in just a few weeks. While federal action on digital assets remains a key focus, this week’s Crypto Policy Tracker shifts...more

Jenner & Block

FinTech Focus: Investment Advisers Join Ranks of Financial Institutions Subject to the Bank Secrecy Act

Jenner & Block on

Dually registered, or “dual hat,” investment advisers are already well aware of the extensive obligations imposed by the Bank Secrecy Act (“BSA”). But for others, the finalization of a Financial Crimes Enforcement Network...more

DLA Piper

Blockchain and Digital Assets News and Trends - August 2024

DLA Piper on

This monthly bulletin is designed to help companies identify important legal developments governing the use and acceptance of blockchain technology, smart contracts, and digital assets....more

Sheppard Mullin Richter & Hampton LLP

South Dakota Lenders on Tight Deadline for BSA/AML Compliance

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

WilmerHale

“Decentralized Finance (DeFi),” Fintech, Regtech, and the Financial Services Industry (Ch. 8A)

WilmerHale on

Decentralized Finance (DeFi) is an umbrella term used to describe financial services provided outside of the traditional markets, that rely on blockchain technologies to create innovative products instead of relying on...more

Jenner & Block

Client Alert: New multi-front Enforcement Action Emphasizes Key AML Compliance Requirements

Jenner & Block on

Shinhan Bank America (“Shinhan”), a New York-based subsidiary of a Korean bank, faced coordinated enforcement actions on September 29 from the Financial Crimes Enforcement Network (“FinCEN”), Federal Deposit Insurance...more

Morrison & Foerster LLP

FinCEN Weighs Path to a No-Action Letter Process

On Friday, FinCEN published an Advance Notice of Proposed Rulemaking (ANPRM) as it further considers implementing a no-action letter process related to anti-money laundering compliance. The ANPRM follows a 2021 FinCEN...more

Orrick, Herrington & Sutcliffe LLP

Off‐Shore Crypto Exchange to Pay Up to $100 Million to Resolve Enforcement Action with U.S. Regulators

The Financial Crimes Enforcement Network (FinCEN) and the Commodity Futures Trading Commission (CFTC) reached one of the largest-ever resolutions with a cryptocurrency exchange on August 10, 2021. BitMEX is virtual currency...more

Nutter McClennen & Fish LLP

Nutter Bank Report: December 2020

FDIC Modernizes Brokered Deposit Rule and Amends Interest Rate Restrictions - The FDIC has adopted a final rule that establishes new standards for determining whether deposits made through certain kinds of arrangements...more

Goodwin

OCC Finalizes “True Lender” Rule

Goodwin on

In the News. The Office of the Comptroller of the Currency (OCC) finalized its “true lender” rule, which establishes that a national bank or federal savings association (bank) is the “true lender” of a loan if, as of the...more

Nutter McClennen & Fish LLP

Bank Report: December 2019

FDIC and OCC Propose CRA Modernization Rule with Opt-Out for Small Banks The FDIC and the OCC have jointly proposed amendments to modernize the agencies’ Community Reinvestment Act (“CRA”) regulations, which are intended...more

Perkins Coie

Blockchain Week in Review - October 2019

Perkins Coie on

U.S. Developments - U.S. Federal Regulatory Developments - CFTC, FinCEN, and SEC Leaders Release a Join Statement on Digital Assets - On October 11, 2019, the heads of the Commodity Futures Trading Commission (“CFTC”),...more

Morrison & Foerster LLP

Nevada Resident Sentenced for Fraud and Unlicensed Money Transmission in Case Involving Bitcoin

On May 28, 2019, a Nevada resident, Morgan Rockcoons, was sentenced in the U.S. District Court for the Southern District of California to 21 months in prison for wire fraud and unlicensed money transmission. In connection...more

Morgan Lewis

FinCEN Issues Guidance on Cryptos

Morgan Lewis on

The Financial Crimes Enforcement Network (FinCEN) recently issued guidance consolidating current FinCEN regulations, rulings, and guidance about cryptocurrencies and money services businesses (MSBs) under the Bank Secrecy Act...more

Goodwin

Financial Services Weekly News - October 2016 #3

Goodwin on

Editor's Note - Another Cybersecurity Proposal. On the heels of the New York State Department of Financial Services (NYDFS) issuing its proposed regulation that would require banks and insurance companies to institute...more

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