The requirements of building an effective AML program can be found within many US Rules and Regulations. While having a robust AML program is key, it is equally critical to adhere to the controls and oversight set forth within the program. Recently, an AML Compliance… Read More »FINRA Holding Compliance Accountable for AML Supervision and Oversight
Earlier this month, acting Comptroller of the OCC, Michael Hsu, gave a thought-provoking speech before the British American Business Transatlantic Finance Forum. Comptroller Hsu discussed the mainstreaming of crypto despite regulatory and legal uncertainty and highlights the attention stablecoins are receiving from regulators, and the trust stablecoins… Read More »Collaboration and Coordination Amongst Regulators
Since it went effective early in 2021, there’s been an open question as to how much traction the industry would see from the Financial Crimes Enforcement Network (FinCEN) in implementing the requirements of the Anti-Money Laundering Act of 2020 (AMLA 2020). While there haven’t been… Read More »What’s been happening with AMLA 2020?
Earlier this month the Federal Financial Institutions Examination Council (FFIEC) released one new section and several updates to the Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual. The updates can be found in the Introduction (new), Charities and Nonprofit Organizations, Independent Automated Teller Machine Owners or Operators and… Read More »FFIEC updates BSA/AML Examination Manual
Continuing the trend of increasing oversight of cryptocurrencies, on November 23 the Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation and Office of the Comptroller of the Currency (the “Agencies”) issued a joint statement describing their recent “policy sprints” regarding future cryptocurrency regulation.… Read More »US banking agencies’ future plans to regulate cryptocurrencies
Earlier this month OCC Interim Head Michael Hsu discussed “Modernizing the Financial Regulatory Perimeter”. Interesting points were raised regarding the market capitalization of the fintech industry today, and where it was 5 years ago. In addition, the lack of consolidated supervision over fintech and crypto… Read More »OCC Acting Comptroller discusses “Modernizing the Financial Regulatory Perimeter”
Frustrated with the lack of a regulatory framework in the cryptocurrency markets, the President’s Working Group on Financial Markets, along with the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency, published a report on stablecoins. The report, which concludes that Congressional… Read More »Regulators demand Congressional action on stablecoins
The Financial Action Task Force (FATF) updated its prior guidance for Virtual Assets and Virtual Asset Service Providers (VASPs). FATF requires countries to assess and mitigate the risks associated with VASPs, and to subject them to the same standards applied to financial institutions. The new FATF… Read More »FATF Guidance Revised for Virtual Assets
On October 15, the Treasury Department’s Office of Foreign Assets Control (“OFAC”) published tailored guidance for the cryptocurrency industry. The guidance is designed to assist those in the virtual currency industry in: Evaluating sanctions-related risks in their lines of business; Building a risk-based sanctions compliance program; Protecting… Read More »OFAC Issues Virtual Currency Guidance
Reinforcing the need to implement strong AML controls, FINRA issued a Notice to Members encouraging firms to begin incorporating FinCEN’s recently issued AML/CFT Priorities into their AML programs. FINRA highlighted the need to update AML ‘red flags’ to include factors such as customers’ business activities, size, the geographic locations… Read More »FINRA urges firms to implement FinCEN’s AML/CFT Priorities
