On Jan. 3, 2023, the Board of Governors of the Federal Reserve System (Federal Reserve), Federal Deposit Insurance Corporation (FDIC), and Office of the Comptroller of the Currency (OCC) (collectivelyContinue Reading Federal Reserve, FDIC, and OCC Issue the First Joint Statement on Crypto-Asset Risks to Banking Organizations
Marina Olman-Pal advises foreign and U.S. financial institutions on a broad range of regulatory matters including licensing, acquisitions, divestitures, compliance with Bank Secrecy Act (BSA)/anti-money laundering (AML) laws and regulations, and compliance with Office of Foreign Assets Control (OFAC) sanctions programs. Marina counsels a wide range of companies in the financial services sector including, domestic and foreign banks, gaming companies, money services businesses including money transmitters, cryptocurrency businesses, Fintech companies and digital payment companies. Throughout her career, Marina has represented clients before U.S. regulators such as the Federal Reserve, OCC, FDIC, FinCEN, OFAC, the Florida Office of Financial Regulation and other state supervisory authorities.
Marina also regularly develops anti-money laundering programs for a wide range of financial services businesses and non-financial services businesses including, U.S. and foreign companies active in industries such as real estate, hospitality, automotive and artificial intelligence, among many others.
On Dec. 15, 2022, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking implementing the provisions of the Corporate Transparency Act that…Continue Reading FinCEN Proposes Rule on Access to Beneficial Ownership Information
On Dec. 13, 2022, the Department of Justice announced that Danish global financial institution Danske A/S (Danske Bank) pled guilty and agreed to forfeit $2 billion to resolve an investigation…Continue Reading Danske Bank Pleads Guilty, Agrees to Pay More Than $2 Billion in Coordinated Resolution of Investigations into Fraud Related to Its Anti-Money Laundering Controls
On Sept. 29, 2022, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule, effective Jan. 1, 2024, implementing the beneficial ownership information reporting…Continue Reading Beneficial Ownership Reporting Requirements: FinCEN Issues Final Rule for Implementation of Corporate Transparency Act
On Oct. 11, 2022, the U.S. Treasury Department announced that cryptocurrency exchange Bittrex Inc. had agreed to settle $53 million total in fines over allegations it violated sanctions and anti-money-laundering…Continue Reading Crypto Exchange Bittrex Settles $53 Million in Fines with Treasury Department for Sanctions, Anti-Money-Laundering Violations
On July 14, 2022, the U.S. House of Representatives passed bipartisan legislation that, if passed by the Senate and signed into law, would expand the types of institutions required to…Continue Reading ENABLERS Act Proposes to Expand Definition of ‘Financial Institution’; Impose BSA/AML Requirements on Professional Service Providers
Federal regulatory agencies are closely monitoring crypto-asset developments and banking organizations’ participation in the crypto-asset industry. This GT Alert covers the guidance issued by the FDIC, CFPB, and the Federal…
Continue Reading Regulatory Scrutiny on the Rise of Bank and Crypto Company Dealings
On June 28, 2022, the Financial Crimes Enforcement Network (FinCEN) and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a rare Joint Alert focused on the…
Continue Reading FinCEN and BIS Warn Financial Institutions About Potential Evasion of Russian and Belarusian Export Controls
On May 12, 2022, Gov. Ron DeSantis signed bill CS/HB 273 (the Bill), amending Florida’s money services business (MSB) laws (i.e., Chapter 560 of the Florida Statutes) to, among other…
Continue Reading Florida Gov. Signs Bill that Defines ‘Virtual Currency’ and Eases Licensing Restrictions on Certain Virtual Currency Transactions in the State
On Jan. 20, 2022, the Board of Governors of the Federal Reserve System (Fed) issued the Money and Payments: The U.S. Dollar in the Age of Digital Transformation paper (Paper)…
Continue Reading Federal Reserve System Takes First Step Toward Creating Its Own Digital Currency