News & Analysis as of

Suspicious Activity Reports (SARs) Office of the Comptroller of the Currency Financial Institutions

Orrick, Herrington & Sutcliffe LLP

FinCEN issues guidance on cross-border information sharing for financial institutions

On September 5, FinCEN, in consultation with the FDIC, NCUA and the OCC, issued guidance to encourage the voluntarily cross-border sharing of information among financial institutions. ...more

Troutman Pepper Locke

OCC to Assess Banks’ “Debanking” Practices as Part of Licensing and CRA Reviews

Troutman Pepper Locke on

On September 8, the Office of the Comptroller of the Currency (OCC) took significant action to “depoliticize” the federal banking system by issuing two bulletins to banks that further the goals of Executive Order 14331...more

Bradley Arant Boult Cummings LLP

Community Banks and BSA/AML Compliance: The OCC’s Consent Order with Clear Fork Bank Proves Regulators Aren’t Only Focused on...

On October 10, 2024, the financial services community was stunned by the $3.1 billion settlement between the federal government and TD Bank over Bank Secrecy Act (BSA) and anti-money laundering (AML) violations. TD Bank’s...more

Troutman Pepper Locke

Federal and State Financial Agencies Issue Guidance on Elder Financial Exploitation

Troutman Pepper Locke on

Earlier this week, the Board of Governors of the Federal Reserve System (FRB), Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Financial Crimes Enforcement Network (FinCEN), National...more

Lowenstein Sandler LLP

TD Bank to Pay Historic $3 Billion Over AML Compliance Violations

Lowenstein Sandler LLP on

On October 10, 2024, multiple U.S. federal and state agencies cumulatively fined a number of US based Toronto Dominion Bank subsidiaries (collectively, TD Bank or the Bank) more than $3 billion after finding that TD Bank...more

Troutman Pepper Locke

Federal Banking Agencies Reiterate Guidance on Managing Risks Posed By Fintech Partnerships and Other Third Party Relationships

Troutman Pepper Locke on

Last week, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (collectively, the agencies) issued a joint statement highlighting...more

WilmerHale

FinCEN’s Proposed AML/CFT Program Rule Potentially Heralds a Change in Approach

WilmerHale on

On June 28, 2024, the US Department of the Treasury’s Financial Crimes Enforcement Network announced long-anticipated proposed rules on anti-money laundering and countering the financing of terrorism program effectiveness;...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

Ballard Spahr LLP

OCC Risk Perspective Report Focuses on Third-Party Relationships with Fintechs

Ballard Spahr LLP on

In its Fall 2023 Semiannual Risk Perspective, published on December 7, the Office of the Comptroller of the Currency (“OCC”) reported on key issues facing the federal banking system. In evaluating the overall soundness of...more

Troutman Pepper Locke

OCC’s Semiannual Report Highlights Emerging Risk of AI in Banking

Troutman Pepper Locke on

On December 7, the Office of the Comptroller of the Currency (OCC) published the fall edition of its Semiannual Risk Perspective, which discusses key issues facing banks. From the OCC’s perspective, the overall strength of...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

Kelley Drye & Warren LLP

Former US Bank Exec Held Individually Liable for Anti-Money Laundering

Compliance Failures - On March 4, 2020, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a consent order assessing a $450,000 civil money penalty against Michael LaFontaine, former Chief...more

The Volkov Law Group

United Bank Risk Officer Agrees to $450k Penalty for AML Compliance Failures

The Volkov Law Group on

Compliance professionals face extraordinary risks – not just for the enterprise but personal risks.  CCOs should not panic or overreact when the government brings an enforcement action against a compliance officer for a...more

Eversheds Sutherland (US) LLP

The OCC’s 2019 annual report addresses anti-money laundering risks for financial institutions

The Office of Comptroller of the Currency (the OCC) has published its 2019 annual report (the Annual Report), which summarized the OCC’s strategic priorities for 2019. The Annual Report also highlighted the OCC’s key...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

White & Case LLP

Review of Anti-Money Laundering and Sanctions Policy and Enforcement

White & Case LLP on

TABLE OF CONTENTS: Executive Summary - Developments and Trends in Policy and Enforcement - US Department of the Treasury - The Office of Foreign Assets Control - Treasury's Financial Crimes Enforcement Network -...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

Spilman Thomas & Battle, PLLC

Response Plan Rewind: The Essentials of Data Breach Response Plans

From the financial sector to the healthcare industry, and even the security business itself, hackers are creeping their way into business data systems and pilfering personal information. For financial institutions, security...more

Carlton Fields

Anti-Money Laundering Trends: Facts, Findings, and Lessons Learned

Carlton Fields on

Increased anti-money laundering (AML) regulation enforcement by federal and state agencies in recent months should have financial institutions across the country reviewing and strengthening their in-house AML policies and...more

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