financial institutions

On July 22, 2019, the federal bank regulatory agencies and the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (collectively, the “Agencies”), issued a Joint Statement on Risk-Focused Bank …
Continue Reading Joint Statement Emphasizes Risk-Focused Approach to Examinations of Banks’ BSA/AML Compliance Programs

On May 23, 2019, Florida Gov. Ron DeSantis signed SB 1024 (Florida Blockchain Bill) into law to establish the Florida Blockchain Task Force (Blockchain Task Force) within the Florida Department…
Continue Reading Florida Creates Blockchain Task Force to Study Benefits of Blockchain Technology

On May 9, 2019, the Financial Crimes Enforcement Network of the U.S. Department of the Treasury (FinCEN) issued “interpretive guidance” addressing how FinCEN’s money services business (MSB) regulations apply to…
Continue Reading FinCEN Issues Guidance on Application of Regulations to Certain Business Models Involving Convertible Virtual Currencies

Last week, in Pictet Overseas, Inc. v. Helvetia Trust, the Eleventh Circuit U.S. Court of Appeals affirmed a Florida district court’s order permanently enjoining two offshore trusts from pursuing …
Continue Reading 11th Circuit Answers When Would-Be ‘Customers’ May Bring a FINRA Arbitration Against FINRA Members and Associated Persons

Adoption of the Corporate Governance Annual Disclosure Model Act and the Corporate Governance Annual Disclosure Model Regulation

Insurance company executives are used to the scrutiny and standards of fiduciary care that may apply to their positions. The standards that apply can be complicated for an insurance company’s senior executives, who have responsibilities related to their shareholders, as well as obligations to the policyholders of the company, subject to robust state regulatory oversight. The National Association of Insurance Commissioners has been studying the states’ general corporate fiduciary standards and working on model corporate governance disclosures that will apply to insurers and/or their holding companies.

Recently, the National Association of Insurance Commissioners’ (NAIC’s) Executive Committee/Plenary voted to adopt the Corporate Governance Annual Disclosure Model Act and the Corporate Governance Annual Disclosure Model Regulation.
Continue Reading Financial Regulatory Changes Underway

In recent months, certain small banks have come under increased investigation by FinCEN, federal bank regulators, and in some instances the Department of Justice (DOJ) for alleged non-compliance with the…
Continue Reading Recent DOJ and Regulatory Actions Against Smaller Institutions Suggest That Community Banks Should Continue to Carefully Consider BSA/AML Risks