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Internal Controls Financial Institutions

Stankie Law

Important Sanctions Compliance Lessons from OFAC’s $11.8m Settlement with Interactive Brokers

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On July 15, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a settlement agreement with Interactive Brokers LLC (“Interactive Brokers”) violations of multiple U.S. sanctions...more

Foodman CPAs & Advisors

Tres formas en que la auditoría forense fortalece la integridad institucional

En el entorno actual de cumplimiento de alto riesgo, se espera que las instituciones financieras entreguen más que resultados. Deben demostrar una rendición de cuentas que sea verificable y lista para auditorías. Esto es...more

Foodman CPAs & Advisors

Three Ways Forensic Reporting Builds Institutional Integrity

In today’s high-stakes compliance environment, financial institutions are expected to deliver more than results. They must demonstrate accountability that is both verifiable and audit-ready. This is especially critical for...more

Nutter McClennen & Fish LLP

Nutter Bank Report: June 2025

The Federal Reserve has announced that the agency will no longer assess reputational risk when examining banks’ risk management processes. According to the June 23 announcement, the Federal Reserve has already begun reviewing...more

K2 Integrity

So You’ve Received A Consent Order—Now What?

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If your firm has been subject to a regulatory enforcement action or received a consent order, responding to a consent order swiftly and strategically is essential. Regulators expect a clear plan that shows your firm...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

K2 Integrity

Fiat Ramps Unlocked: Practical Tips For Banks And Crypto Firms

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Ask any centralized cryptocurrency firm to name one of their biggest priorities or challenges—and then count the number of times they mention bank partnerships. For crypto firms, the loss of, or failure to acquire, a bank...more

ArentFox Schiff

FinCEN Releases Final Anti-Money Laundering Rule for Investment Advisers

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On August 28, the Financial Crimes Enforcement Network (FinCEN) issued a final rule establishing anti-money laundering and countering the financing of terrorism (AML/CFT) compliance obligations for US Securities and Exchange...more

Venable LLP

DOJ Revises Its Evaluation of Corporate Compliance Policy to Consider How Companies Address Risks Posed by AI

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The Department of Justice's Criminal Division is "using more tools than ever before to identify corporate misconduct and to encourage companies to be good corporate citizens," according to Nicole Argentieri, Principal Deputy...more

Conyers

The Importance of Sound Corporate Governance for Virtual Asset Service Providers: Lessons from Past Failures

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In recent years, the virtual asset industry has experienced exponential growth, bringing about innovations in digital payments, tokenisation and decentralised finance (Defi). While highly innovative, the volatile nature of...more

Perkins Coie

FDIC’s Proposed Changes to Custodial Deposit Accounts: Practical Implications for Fintechs and Their Banks

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The Federal Deposit Insurance Corporation (FDIC) issued a Notice of Proposed Rulemaking (the Proposal) on September 17, 2024, that seeks to strengthen recordkeeping for bank deposits held by nonbank companies on behalf of...more

Goodwin

FinCEN and Banking Agencies Propose AML Program Rule Updates for Banks and Other Financial Institutions

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Earlier this summer, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Proposed Rule revising its regulations under the Bank Secrecy Act (BSA) requiring financial institutions to...more

BCLP

Personal Matters - How will the risks to firms from individuals’ behaviour increase in 2024?

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Financial regulators in the UK have been interested for some years in the question of how personal behaviour can affect the risk profile of a financial institution. A recent SEC case suggests that US regulators may now be...more

J.S. Held

INDEPTH FEATURE: Anti-Money Laundering 2024

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Could you provide an insight into recent trends shaping financial crime in your country of focus? How great a risk does money laundering in particular now pose to companies? One would likely never imagine compliance as...more

Womble Bond Dickinson

Navigating the Labyrinth: Artificial Intelligence in the Battle Against Trade-Based Money Laundering

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In the rapidly evolving financial landscape, governments worldwide are intensifying their focus on compliance in Know Your Customer (KYC) and Anti-Money Laundering (AML) efforts for financial institutions. Trade-Based Money...more

Mayer Brown

NYDFS Finalizes Climate Risk Management Guidance

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On December 21, 2023, the New York Department of Financial Services (“NYDFS”) finalized guidance on how the banks and mortgage institutions it regulates (“New York Institutions”) should manage climate-related financial and...more

Hudson Cook, LLP

New York DFS Finalizes Amendments to Cybersecurity Regulations

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On November 1, 2023 the New York Department of Financial Services ("DFS") released amended cybersecurity regulations ("Regulations"). These changes will impose additional controls, demand more frequent risk assessments, and...more

BakerHostetler

NYDFS Issues Revised Proposed Second Amendment to Its Cybersecurity Regulation

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The New York State Department of Financial Services (NYDFS) recently published a revised proposed second amendment to its cybersecurity regulation, 23 NYCRR 500. ...more

Walkers

Director exemptions: changes to AML obligations

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Introduction - Further to a recent update, in which the Government, in consultation with the Jersey Financial Services Commission ("JFSC"), announced its intention to make legislative changes to the anti-money laundering,...more

Cadwalader, Wickersham & Taft LLP

Basel Committee Issues Guidance on Core Principles for Effective Banking Supervision

In April 2022, the Basel Committee on Banking Supervision (the Basel Committee) began a review of “the core principles for effective banking supervision” (Core Principles or CP). Last month, the Basel Committee published...more

Latham & Watkins LLP

Acting Comptroller Confronts “Too Big to Manage” Issue

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The Acting Comptroller of the OCC discussed the limits of large bank manageability and the steps that regulators can take to address the risks posed by size and complexity. On January 17, 2023, Acting Comptroller of the...more

Latham & Watkins LLP

NYDFS Proposes Guidance on Climate Change Risk Management

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The Guidance would increase expectations for regulated financial institutions to identify, measure, monitor, and control climate-related financial risks. For the past few years, the New York State Department of Financial...more

Latham & Watkins LLP

FCA Issues Final Notice to Former Banking CEO Over Anti-Money Laundering Failures

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The case provides instructive practical examples of the “reasonable steps” companies can take according to the FCA and a reminder of the FCA’s cultural expectations of CEOs. On 16 November 2022, the FCA issued a final...more

Holland & Knight LLP

NYDFS Proposes Amendments to Cybersecurity Regulation

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The New York Department of Financial Services (NYDFS) on Nov. 9, 2022, released Proposed Amendments to its Cybersecurity Regulation. The NYDFS Cybersecurity Regulation was one of the first laws requiring companies to comply...more

Epiq

Planning for a Remediation: Proactive Considerations for Financial Institutions

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Financial institutions are more regularly dealing with voluntary remediations and public consent order activity due to heightened scrutiny by regulators and changing internal policies. These events can be complex and also...more

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