News & Analysis as of

Suspicious Activity Reports (SARs) Office of the Comptroller of the Currency Banking Sector

Sheppard Mullin Richter & Hampton LLP

OCC Issues Bulletins on Customer Financial Record Protections and Politicized Debanking

On September 8, the OCC issued two bulletins addressing banks’ obligations under the Right to Financial Privacy Act and clarifying how the agency will evaluate “politicized or unlawful debanking” in licensing and Community...more

Cooley LLP

Fed Signals Fraud a Top Priority in Special Compliance Outlook Issue

Cooley LLP on

The Federal Reserve (Fed) has devoted its entire Second Issue 2025 of Consumer Compliance Outlook (Outlook) to fraud – a rare, single-topic focus that underscores regulators’ and industry’s heightened concern for addressing...more

Nutter McClennen & Fish LLP

Nutter Bank Report: December 2023

A recent OCC report identified key issues facing the federal banking system, including increasing credit risk due to higher interest rates, increasing risk in commercial real estate lending, prolonged inflation, declining...more

Goodwin

CFPB Launches New Initiative Focused on Rural Communities

Goodwin on

In This Issue. The Consumer Financial Protection Bureau (CFPB) announced a new initiative focused on financial issues faced by rural communities and also updated its examination procedures to cover unfair discrimination; the...more

Miller Nash LLP

I Just Wanna Know—Federal Bank Regulators to Require Notice of Major Cyber Security Events

Miller Nash LLP on

Hardly a day goes by without news of a new cybercrime hobbling a major business.1 The grand scope of the SolarWinds hack, which went undetected for many months, underscored that even the most sophisticated technology...more

Goodwin

Federal Agencies Issue Joint Statement on Management of LIBOR Transition

Goodwin on

In This Issue. Federal agencies issued a joint statement regarding an orderly transition away from the London Interbank Offered Rate (LIBOR); the Office of the Comptroller of the Currency (OCC) issued an updated...more

Goodwin

Biden Administration Issues Regulatory Freeze On New Agency Rules

Goodwin on

In this Issue. In one of its first acts after being installed on January 20, the Biden Administration issued a regulatory freeze on new agency rules that have been adopted but are not yet effective; in one of its final acts...more

Ballard Spahr LLP

The OCC Embraces Technology, Proposes Exemption to SAR Requirements and Announces Acceptance of Distributed Ledgers and...

Ballard Spahr LLP on

The Comptroller of the Currency (the “OCC”) has been busy, and focused on technology. We discuss two recent developments: proposed regulations that would allow the OCC to grant exemptions relating to Suspicious Acivity...more

Goodwin

FDIC Finalizes Brokered Deposits and ILC Rules Ahead of the Holidays

Goodwin on

In this Issue. The Federal Deposit Insurance Corporation (FDIC) was busy this week, finalizing rules that modernize brokered deposits regulations, establish new standards for parent companies of industrial loan companies and...more

Eversheds Sutherland (US) LLP

Federal agencies clarify SAR filing requirements for financial services provided to hemp-related businesses

On December 3, 2019, four federal agencies, in consultation with state banking regulators, clarified the legal status of hemp growth and production under the Bank Secrecy Act (BSA) for banks providing financial services to...more

Dorsey & Whitney LLP

Banking Services for Hemp Growers – FinCEN Makes a Statement

Dorsey & Whitney LLP on

On December 3, 2019, FinCEN, along with the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency, in consultation with the Conference of...more

Bradley Arant Boult Cummings LLP

Is the Bank Open? Federal Agencies Clarify Regulatory Requirements for Banking Hemp

On December 3, several federal agencies issued guidance (Guidance) that, by its terms, “provide[s] clarity” regarding “the regulatory requirements under the Bank Secrecy Act (BSA) for banks providing services to hemp-related...more

The Volkov Law Group

Rabobank Coughs Up $368 Million and Pleads Guilty to Conspiracy to Money Launder and Obstruct Investigation

The Volkov Law Group on

The Justice Department announced a guilty plea by a subsidiary of Rabobank, a Dutch global bank, to a conspiracy to violate money laundering laws and obstruct a regulatory investigation of Rabobank’s activities in California....more

A&O Shearman

U.S. Subsidiary Of Dutch Bank Pleads Guilty To Allegations That It Conspired To Obstruct OCC Examination Of AML Program

A&O Shearman on

On February 7, 2018, Dutch bank Rabobank’s U.S. subsidiary pleaded guilty to conspiring to impair, impede, and obstruct a review by the Office of the Comptroller of the Currency (“OCC”) of the bank’s anti-money laundering...more

Carlton Fields

Banks to Broaden Reporting of Suspicious Cyber Activity; Regulators Propose “Enhanced” Cybersecurity Standards

Carlton Fields on

The fourth quarter of 2016 has seen an uptick in regulatory activity respecting the financial services sector in the cybersecurity space, both at the state level as previously discussed (here) and on the federal level....more

A&O Shearman

Financial Regulatory Developments Focus - November 2016

A&O Shearman on

In this newsletter, we provide a snapshot of the principal US, European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset managers and...more

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