On June 27, 2025, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an order (Order) allowing banks,[1] and their subsidiaries, subject to the jurisdiction of the Office of the Comptroller...more
Imagine sitting in your living room, enjoying a cup of your favorite morning coffee, and you open your mail to discover that you recently opened a new bank account at XYZ Bank, unbeknownst to you. Or maybe you receive an...more
Editor's Note - 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,...more
On September 29, 2020, at the 19th Annual AML & Anti-Financial Crime Conference, Financial Crimes Enforcement Network (“FinCEN”) Director Kenneth Blanco reported over 91,000 suspicious activity reports (“SARs”) have been...more
The Social Security Administration (SSA) has announced the development of a portal that would allow financial institutions to join a planned real-time electronic system for verifying the identity of credit applicants. ...more
Following the recent Equifax data breach wherein millions of consumers’ private information may have been compromised, it is increasingly clear that consumer-interfacing businesses need to, and in some cases are required to,...more