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Risk Management Regulatory Reform

Polsinelli

Virtual Oversight, Real Impacts: “Incident-To” and Beyond in CMS’s CY 2026 PFS Proposed Rule

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Key Takeaways - CMS proposes to significantly expand the use of virtual direct supervision for incident-to services, removing prior limitations based on Professional Component (PC)/Technical Component (TC) indicators and...more

Venable LLP

Compliance as a Competitive Advantage

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Recently, we presented on Compliance as a Competitive Advantage at Compliance University by Online Lenders Alliance. We shared a perspective we've developed over 20 years of working with financial services companies: that...more

Hogan Lovells

PEP talk: The UK FCA issues final guidance on the treatment of politically exposed persons

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The Financial Conduct Authority (“the FCA”) has published final guidance on the treatment of politically exposed persons (PEPs) for anti-money laundering purposes, which updates its Guidance issued in 2017 (“the 2017...more

Woods Rogers

Trump Administration Releases Action Plan and Executive Orders for “AI Dominance”

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On July 23, 2025, the Trump Administration issued a 28-page action plan (the Action Plan or the Plan) and three corresponding Executive Orders designed to “win the AI race” and achieve “global dominance” in the AI...more

Alston & Bird

FinCEN Delays Enforcement of Investment Adviser AML/CFT Rule

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Our Financial Services and Investment Funds Teams examine the delay by the Financial Crimes Enforcement Network (FinCEN) of the effective date for the Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT)...more

Seyfarth Shaw LLP

PAID Back: DOL Revives Voluntary Self-Audit Program

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The U.S. Department of Labor has officially revived its Payroll Audit Independent Determination (PAID) program. Designed to help employers proactively resolve FLSA issues—and now, for the first time, certain FMLA...more

Paul Hastings LLP

Banking Regulators Clarify Crypto Custody Expectations, Congress Advances Landmark Digital Asset Legislation and Senate Releases...

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In a pivotal week for digital asset policy, federal banking regulators issued long-awaited guidance outlining risk-management expectations for crypto-asset safekeeping activities. The OCC, Federal Reserve and FDIC released a...more

Lowenstein Sandler LLP

Considerations from America’s AI Action Plan

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On July 23, the White House released “America’s AI Action Plan” (the Plan), a comprehensive federal strategy aimed at ensuring the United States achieves and maintains global leadership in artificial intelligence (AI)....more

Husch Blackwell LLP

Trump Administration’s AI Action Plan and New Executive Orders Offer Strategic Opportunities and Legal Risks for Private...

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Key Point: “Winning the Race: America’s AI Action Plan,” the Trump Administration’s summary approach to federal artificial intelligence (AI) policy, and three new Executive Orders (EO) propose a wide-ranging federal strategy...more

Davis Wright Tremaine LLP

FDIC Rethinks Industrial Banks—Again

Industrial banks or industrial loan companies (ILCs)—FDIC-insured banks chartered by certain states, notably Utah—have long been a niche component of the U.S. financial system. These institutions may be owned by commercial...more

A&O Shearman

FSB chair letter on global outlook and priorities

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The Financial Stability Board (FSB) has published a letter from Andrew Bailey, Governor of the Bank of England, who was appointed chair of the FSB from 1 July. In the letter, the chair confirms his commitment to the FSB's...more

White & Case LLP

To ‘cut sewage pollution in half by 2030’ the Government seizes on the Cunliffe Report to restructure environmental law

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UK, Environment Secretary Steve Reed has announced immediate changes and a review of environmental law in response to the Independent Water Commission’s 465-page report (the "Cunliffe Report") on the UK's water industry....more

Paul Hastings LLP

White House Releases AI Action Plan: "Winning the Race: America's AI Action Plan"

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On July 23, the White House released its strategic action plan on AI, “Winning the Race: America’s AI Action Plan” (the AI Action Plan), which is designed to secure U.S. global leadership in AI with a strategic focus on...more

Jackson Lewis P.C.

OSHA Proposes Dozens of Deregulatory Rules: How They’ll Impact Multiple Industries

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The Occupational Safety and Health Administration (OSHA) has published over two dozen proposed rules in the Federal Register on July 1, 2025, marking a sweeping regulatory initiative that impacts multiple industries. Although...more

Smith Anderson

Feds' Shift On Reputational Risk Raises Questions For Banks

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In a significant shift, each of the country's three federal bank regulatory agencies have announced they will no longer consider reputational risk as a stand-alone supervisory category. Originally published in Law360 -...more

Morgan Lewis

OSHA’s Aggressive Deregulatory Efforts Begin

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The Occupational Safety and Health Administration (OSHA) has begun what the US Department of Labor describes as “aggressive deregulatory efforts” to “put American workers and job creators first.” In response to President...more

Alston & Bird

SEC Withdraws Proposed Cyber-Related Rule Applicable to Broker-Dealers And Signals SolarWinds Settlement on the Horizon

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The Securities and Exchange Commission (SEC) recently announced the withdrawal of several Biden-era regulations, including a proposed rule that would have required a broad range of platforms and financial intermediaries (such...more

Jones Day

Reform of the EU Securitisation Framework—Part 1: STS Label Extended to Unfunded Credit Protection

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In January 2019, the EU introduced its current regulatory framework for securitisations, seeking to improve transparency, robustness, and market confidence following the global financial crisis. Market participants have...more

McDermott Will & Emery

Proposals For Relaxation of EU Securitization Framework

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Vlad Maly and Michal Chajdukowski present the key takeaways from a package of amendments to the existing EU securitization framework, published by the European Commission on June 17, 2025. The proposals aim at...more

Hogan Lovells

UK’s Financial Services Growth and Competitiveness Strategy: Welcome news for insurers

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The UK government’s Financial Services Growth and Competitiveness Strategy published on 15 July 2025, identifies insurance/reinsurance as one of the sectors with ‘priority growth opportunities’ and as such the Strategy sets...more

Latham & Watkins LLP

Cybersecurity Regulation in Flux as Trump Administration Focuses on Evolving Foreign and Tech Threats

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The administration has signaled a potential softening of cyber regulation for domestic entities, with increasing focus on national security priorities and preparing for the future....more

Orrick, Herrington & Sutcliffe LLP

OCC removes reference to disparate impact for examiners

On July 14, the OCC announced it has removed the references to disparate impact liability from the “Fair Lending” booklet of the Comptroller’s Handbook and has started removing references in other issuances. The OCC has also...more

Ropes & Gray LLP

FDA Commissioner Makary Promises “Real Time” Release of Complete Response Letters: Can FDA Really Do That?

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On July 10, 2025, in the name of embracing “radical transparency,” the U.S. Food and Drug Administration (“FDA”) announced that it was publishing more than 200 complete response letters (“CRLs”) issued in response to drug and...more

Skadden, Arps, Slate, Meagher & Flom LLP

UK’s Proposed New Captive Insurer Regime: Key Developments and Next Steps

What is new: The UK government has proposed a new regulatory framework for captive insurance companies, aiming to simplify regulations and enhance competitiveness in the financial services sector. Why it matters: The...more

Davis Wright Tremaine LLP

Federal Reserve Board Proposes Revisions to Large Financial Institution Rating System

On July 15, 2025, the Federal Reserve Board released a proposed rule to revise the Large Financial Institution rating system or "LFI Framework." The proposal would change how the Fed evaluates the financial and managerial...more

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