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FinCEN and Banking Agencies Provide Clarification on PEP Screening Best Practices

USA - October 5 2020 On Aug. 21, 2020, in response to inquiries from various banks, the Financial Crimes Enforcement Network (“FinCEN”), a bureau of the U.S. Department of…

Melissa G.R. Goldstein, Kyle B. Hendrix, Betty Santangelo, Gary Stein, Hannah Thibideau, Joshua B. Wright

AML Update: FinCEN Issues First-Ever Enforcement Guidelines and Federal Banking Agencies Update Enforcement Guidance

USA - September 2 2020 On Aug. 18, 2020, the Financial Crimes Enforcement Network (“FinCEN”) issued a statement describing its approach to enforcing the Bank Secrecy Act…

Melissa G.R. Goldstein, Jennifer M. Opheim, Betty Santangelo, Gary Stein, Hannah Thibideau, Nicholas A. Wilson

OCC Now Open to Receiving National Payments Charter Applications, But State Banking Regulators Mull a Legal Challenge

USA - August 31 2020 As provided in our June 29, 2020 Alert,Mr. Brooks previously indicated that there would be two versions of the payments charter — Version 1.0…

Kara A. Kuchar, Adam J. Barazani, Donald J. Mosher

States Sue to Block FDIC Final Rule Clarifying Validity of Interest Rates on Assigned Bank Loans

USA - August 20 2020 The states argue that the Final Rule “unlawfully extend[s] federal law in order to preempt state rate caps that would otherwise apply to . . . nonbank…

Nicholas A. Wilson

New York, California and Illinois Sue to Block OCC Rule That Would Undo Madden v. Midland Funding LLC

USA - July 30 2020 On July 29, 2020, New York, California and Illinois filed a lawsuit against the Office of the Comptroller of the Currency (“OCC”) over its final rule…

Nicholas A. Wilson