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

USA - February 1 2021 The Financial Crimes Enforcement Network ("FinCEN") issued a statement describing its approach to enforcing the Bank Secrecy Act ("BSA") and its…

Melissa G.R. Goldstein, Betty Santangelo, Gary Stein, Hannah Thibideau, Joseph P. Vitale

OCC Finalizes Rule Clarifying the ‘True Lender’ in Bank/Nonbank Lending Partnerships

USA - October 28 2020 On Oct. 27, 2020, the Office of the Comptroller of the Currency (“OCC”) finalized a rule that clarifies that a national bank or federal savings…

Joseph P. Vitale

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, Joseph P. Vitale

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…

Joseph P. Vitale

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…

Joseph P. Vitale