Morrison & Foerster LLP | USA | 18 Nov 2020
The Florida Office of Financial Regulation (“OFR”) has rejected a petition for a declaratory statement seeking confirmation that payment processing…
Morrison & Foerster LLP | USA | 10 Nov 2020
A new proposed rulemaking (the “NPRM”) would lower the current $3,000 threshold for the applicability of the Bank Secrecy Act (“BSA”) Recordkeeping…
Morrison & Foerster LLP | USA | 21 Sep 2020
Earlier this year, the California Department of Business Oversight (DBO) issued a draft rulemaking relating to the scope of the agent of a payee…
Morrison & Foerster LLP | USA | 14 Aug 2020
A recent federal district court ruling in a criminal anti-money laundering case suggests that the transmission of virtual currency on behalf of…
Morrison & Foerster LLP | USA | 28 Jul 2020
On July 23, 2020, in an effort to increase transparency in commercial financings so borrowers may make more informed decisions, the New York State…
Morrison & Foerster LLP | USA | 15 Jul 2020
Developments in virtual currency regulation have been top-of-mind with recently announced initiatives from the New York Department of Financial…
Morrison & Foerster LLP | USA | 10 Mar 2020
For what appears to be only the second time, the Financial Crimes Enforcement Network (“FinCEN”) has assessed a civil money penalty (“CMP”) against…
Morrison & Foerster LLP | USA | 5 Mar 2020
A year after issuing an invitation for comments, the California Department of Business Oversight (“DBO”) has finally released a much-anticipated…
Morrison & Foerster LLP | USA | 14 Feb 2020
One of the defining aspects of the payments revolution of the past few years—at least from a regulatory perspective—has been the question of whether…
Morrison & Foerster LLP | USA | 12 Feb 2020
On February 10, 2020, the Federal Deposit Insurance Corporation (FDIC) published a proposed rule intended to modernize the regulatory treatment of…