Tag Archives: risk management

Joint Statement Emphasizes Risk-Focused Approach to Examinations of Banks’ BSA/AML Compliance Programs

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 Secrecy Act/Anti-Money Laundering (BSA/AML) Supervision. The Joint Statement emphasizes their risk-focused approach to examinations of banks’ BSA/AML compliance programs and is the third statement from … Continue Reading

New ADV Rule

Today, the SEC announced the adoption of amendments to several rules under the Investment Advisers Act of 1940 and to Form ADV, the investment adviser registration and reporting form. Although there is a long lead-in time to get in compliance with the new rules and Form ADV, advisers should consider beginning work now to ensure compliance … Continue Reading

SEC IM Guidance Update – Investment Company Business Continuity Plans

In connection with the Press Release announcing a Rule Proposal regarding adoption of written business continuity and transition plans by SEC-registered investment advisers (see our blog post on the topic), the Division of Investment Management also distributed a Guidance Update (No. 2016-04) discussing BCPs for registered investment companies (RICs).  RICs have been expected to address … Continue Reading

OCC Forum on Responsible Innovation

On June 23, 2016 the Office of the Comptroller of the Currency (OCC) hosted the Forum on Responsible Innovation in the Federal Banking System in Washington, D.C. Hundreds of industry stakeholders gathered to discuss “Responsible Innovation,” fintech, and the role of the OCC in regulating the financial industry as it evolves.  The forum addressed reaction … Continue Reading

Early Signs on Fintech from the Consumer Financial Protection Bureau

There is no doubt that the regulation of financial technology (fintech) companies is on the rise. Fintech companies broadly mean companies that provide products, services and technology where traditional banking and financial services leave off and technology takes off. Though all of the federal banking agencies and other agencies will play a vital role in … Continue Reading

SEC’s Office of Compliance Inspections and Examinations Releases Annual Examination Priorities

On Jan. 11, 2016, the Office of Compliance Inspections and Examinations (OCIE) of the U.S. Securities and Exchange Commission (SEC) issued its annual Examinations Priorities for 2016 (Exam Priorities), which is available for download here. In the Exam Priorities, OCIE notes that its priorities focus on the same three thematic areas as in 2015 (which we … Continue Reading

How the SEC Proposed New Derivatives Rules Affect Registered Funds and Business Development Companies

On Dec. 11, 2015, the SEC proposed new derivatives rules for registered funds and business development companies. The proposed rules set limits on portfolio exposure and the requirement that funds maintain derivative risk management programs. It is important to evaluate these proposed limits against existing “stress testing” clearing and portfolio margining models. Derivative traders have 90 … Continue Reading

Fred Karlinsky to Speak in the ACC Webcast “Captive Insurance: Business and US Regulatory Considerations”

Fred E. Karlinsky, co-chair of Greenberg Traurig’s Insurance Regulatory and Transactions Practice Group and a shareholder within the Financial Regulatory and Compliance Group, will participate in a webcast hosted by ACC’s Financial Services Committee. Karlinsky will present in the webcast titled “Captive Insurance: Business and US Regulatory Considerations” on Tuesday, Dec. 1, 2015, at 12 … Continue Reading

AML Developments – FDIC Announces That It Will End Its Supervisory Trend of Expecting Regulated Institutions to ‘De-Risk’ Entire Categories of Customers

On Jan. 28, 2015, the Federal Deposit Insurance Corporation (FDIC) in a Financial Institutions Letter (FIL) announced that it would, in effect, do an about-face on its supervisory expectation that banks strongly consider discontinuing the provision of financial services to entire categories of certain purportedly high-risk customers. These categories of customers included, to name a … Continue Reading
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