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NYDFS proposes new antimoney laundering requirements, liability for compliance officers

USA - December 7 2015 On December 1, 2015, New York Governor Andrew Cuomo announced proposed New York State Department of Financial Services ("NYDFS") rules that would...

Helen V. Cantwell, Robert T. Dura, David A. O'Neil, Satish M. Kini, Eric R. Dinallo.


Federal Reserve proposes total loss absorbing capacity requirement

USA - November 4 2015 On October 30, 2015, the Federal Reserve Board (the “FRB”) issued a proposed rule (the “Proposal”) designed to improve the resolvability and...

Gabriel W. Lezra, Gregory J. Lyons, Paul M. Rodel, Samuel E. Proctor, David L. Portilla.


OCC’s final “heightened expectations”: an overview focusing on how the OCC responded to industry comments

USA - September 12 2014 On September 2, 2014, the Office of the Comptroller of the Currency (“OCC”) issued final guidelines establishing heightened risk governance standards...

Gregory J. Lyons, Byungkwon Lim, Samuel E. Proctor, Lee A. Schneider, David L. Portilla.


FinCEN proposes enhanced customer due diligence requirements

USA - August 5 2014 On July 30, 2014, the U.S. Treasury Department's Financial Crimes Enforcement Network ("FinCEN") issued proposed rules to codify and strengthen...

Phil V. Giglio, Naeha Prakash, Gregory T. Larkin, Satish M. Kini, Raj A. Vashi.


Enhanced prudential standards for foreign banking organizations a guide for each FBO type

USA - February 27 2014 On Tuesday, February 18, 2014, the Federal Reserve Board (the "Federal Reserve") adopted a final rule (the "Final Rule") implementing the enhanced...

Satish M. Kini, Gregory J. Lyons, Samuel E. Proctor, Lee A. Schneider, David L. Portilla.