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Financial Services Observer

News & Commentary on Financial Regulatory and Compliance Matters

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11th Circuit

11th Circuit Answers When Would-Be ‘Customers’ May Bring a FINRA Arbitration Against FINRA Members and Associated PersonsFDCPA – 11TH Circuit: Kinlock v. Wells Fargo Bank – Post-Foreclosure Offers of Financial Assistance to Defaulted Borrower Not Violative of FDCPA/Florida Consumer Collection Protection Act

2d Circuit

Are Syndicated Term Loans Securities Under Reves v. Ernst & Young? 2nd Circuit Solicits SEC ViewsFDIC Follows OCC Lead in Attempt to Clarify Madden UncertaintySCOTUS to Resolve Circuit Split Over Dodd-Frank Whistleblowers

account freezing order

Prove It or Lose It! Part III: A Step Too Far? Account Freezing Orders & Account Forfeiture Orders in the UK

annuity

Illinois Supreme Court Rules Annuities Are Not Securities Under Illinois Securities Act

anti-bribery

AML Compliance Scrutiny of Virtual Currency Services in 2020 and BeyondUK Review of the Bribery Act 2010 – Committee Concludes New Guidance Needed

Anti-Money Laundering

Expansive New Bank Secrecy Act, Sanctions Whistleblower Program: Department of Commerce InsightsFinCEN Proposes Rule on Access to Beneficial Ownership InformationDanske Bank Pleads Guilty, Agrees to Pay More Than $2 Billion in Coordinated Resolution of Investigations into Fraud Related to Its Anti-Money Laundering Controls

Appointed Representatives Regime

Principals in the Spotlight as UK’s FCA Consults on Changes to Appointed Representatives Regime

Arbitration

11th Circuit Answers When Would-Be ‘Customers’ May Bring a FINRA Arbitration Against FINRA Members and Associated Persons

banking

Private Fund Adviser RulemakingCalifornia Regulator Finalizes Rule Expanding UDAAP Authority to Commercial FinancingFederal Banking Agencies Propose New Rules to Strengthen Capital Requirements for Large Banks

Banking Regulators

Are Syndicated Term Loans Securities Under Reves v. Ernst & Young? 2nd Circuit Solicits SEC ViewsCFPB And FTC Take Their Place As Powerful Crypto CopsThe 2023 Banking Contagion: Questions & Answers for Insured and Uninsured Depositors, Other Affected Parties

Bankruptcy

Are Syndicated Term Loans Securities Under Reves v. Ernst & Young? 2nd Circuit Solicits SEC ViewsThe 2023 Banking Crisis: Updated Questions & Answers for Insured and Uninsured Depositors, Other Affected PartiesThe 2023 Banking Contagion: Questions & Answers for Insured and Uninsured Depositors, Other Affected Parties

Banks

Are Syndicated Term Loans Securities Under Reves v. Ernst & Young? 2nd Circuit Solicits SEC ViewsThe 2023 Banking Crisis: Updated Questions & Answers for Insured and Uninsured Depositors, Other Affected PartiesThe 2023 Banking Contagion: Questions & Answers for Insured and Uninsured Depositors, Other Affected Parties

BitLicense

The OCC and SEC’s FinHub Issue Guidance on Fiat-Backed Stablecoin ReservesNew York State Department of Financial Services Proposes Framework for a Conditional BitLicenseNew York State Releases Final BitLicense Regulation

Blockchain

Federal Reserve, FDIC, and OCC Issue 2nd Joint Statement Highlighting Liquidity Risks to Banks Engaged in Crypto-Asset-Related Activities5 Trends to Watch: 2023 UK Contentious Financial RegulationFINRA Targeting Crypto Asset Retail Communications

Blockchain Technology Task Force

Crypto Exchange Bittrex Settles $53 Million in Fines with Treasury Department for Sanctions, Anti-Money-Laundering ViolationsFlorida Gov. Signs Bill that Defines ‘Virtual Currency’ and Eases Licensing Restrictions on Certain Virtual Currency Transactions in the StateFinCEN Proposes to Extend Recordkeeping, Reporting, and Identity Verification Requirements to Certain Virtual Currency and Digital Asset Transactions

Brokers

Proposed Legislation Would Create a Tiered Exemption from Broker RegistrationCongress Codifies Longstanding M&A Broker Exemption from SEC RegistrationSEC Proposes to Establish a New Best Execution Standard

California

California Regulator Finalizes Rule Expanding UDAAP Authority to Commercial FinancingThe 2023 Banking Contagion: Questions & Answers for Insured and Uninsured Depositors, Other Affected Parties

Capital Markets

SEC Chair Continues Push to Regulate Digital Asset MarketsSEC Proposes Rule Changes to Mutual Fund and Exchange Traded Fund DisclosuresFederal Reserve Takes Actions to Provide Over $2 Trillion in Liquidity to U.S. Credit Markets, Including the Launch of its Main Street Lending Program

CFPB

CFPB Issues Guidance on Credit Denials Involving Artificial IntelligenceCFPB Updates Small Business Lending Rule FAQsCFPB Teams with HHS and Treasury to Examine Medical Financial Products

CFTC

Commodity Futures Trading Commission Issues Time-Limited Relief from CFTC Rule 1.56CFTC Cancels and Replaces Proposed Regulation ATCFTC Proposes Expanding Exemption for Non-U.S. Commodity Pool Operators

Class Action Litigation

Financial Services Insights | Summer 2020Tyson Foods, Inc. v. Bouaphakeo: Supreme Court Upholds Use of Statistical Evidence in Class Actions

Client Alert

Nevada Enacts Nation’s First State Licensing Regime for Earned Wage Access ServicesAre Syndicated Term Loans Securities Under Reves v. Ernst & Young? 2nd Circuit Solicits SEC ViewsThe 2023 Banking Contagion: Questions & Answers for Insured and Uninsured Depositors, Other Affected Parties

Commodities

CFTC Cancels and Replaces Proposed Regulation ATCFTC Proposes Expanding Exemption for Non-U.S. Commodity Pool OperatorsCFTC and NFA Commodities Regulatory Update

Compliance

Maryland Office of Financial Regulation Provides Guidance on Earned Wage Access ProductsCFPB Spotlight Targets Mobile ‘Tap-To-Pay’ TechnologyCFPB Updates Small Business Lending Rule FAQs

Consumer Financial Services

Small Business Lenders: CFPB Issues Final Rule on Small Business LendingCFPB Issues Report on Unlawful ‘Junk Fees’ Uncovered in Deposit Accounts, Multiple Loan Servicing MarketsCFPB Says ‘Show Me The (Consumer Unfriendly) Fine Print’

Consumer Lending

Small Business Lenders: CFPB Issues Final Rule on Small Business LendingThe 2023 Banking Contagion: Questions & Answers for Insured and Uninsured Depositors, Other Affected PartiesCFPB Warns Insufficient Data Security Measures May Violate Consumer Financial Protection Act

convertible virtual currency

Florida Gov. Signs Bill that Defines ‘Virtual Currency’ and Eases Licensing Restrictions on Certain Virtual Currency Transactions in the StateFinCEN Proposes to Extend Recordkeeping, Reporting, and Identity Verification Requirements to Certain Virtual Currency and Digital Asset TransactionsSEC Issues No-Action Letter Facilitating the Secondary Trading of Digital Assets

coronavirus

CFPB Metrics Report Shows Increased Scrutiny of Borrower Access to Servicers, Information, and Loss Mitigation OpportunitiesUpdate: CFPB Finalizes Pandemic Mortgage Servicing RulesCFPB Reiterates Focus on Mortgage Industry COVID-19 Response, Highlights Fair Servicing Concerns

Corporate Governance

CFPB Policy Statement Aims to Clarify Prohibition on Abusive Conduct in Consumer Financial MarketsSEC Proposes Exemption from Registration for FindersCOVID-19 Pandemic: Banking & Finance ‘Phase 2’ Measures in Italy

cryptocurrency

CFPB And FTC Take Their Place As Powerful Crypto CopsFederal Reserve, FDIC, and OCC Issue 2nd Joint Statement Highlighting Liquidity Risks to Banks Engaged in Crypto-Asset-Related ActivitiesFederal Reserve, FDIC, and OCC Issue the First Joint Statement on Crypto-Asset Risks to Banking Organizations

Cybersecurity

SEC Finalizes Cyber Rules for Public Companies: What You Need to KnowNYDFS Proposes Significant Changes to Its Cybersecurity RegulationFTC Delays Compliance Date of the Safeguards Rule

Debt

CFPB Begins Scrutinizing Companies Using ‘Buy Now, Pay Later’ Credit

Debt relief

Financial Services Insights | Summer 2020Congress Passes the PPP Flexibility ActFCC Proposes Rules to Limit the Use of Robocalls to Collect Debts Owed to or Guaranteed by the United States

Digital Assests

Federal Reserve, FDIC, and OCC Issue 2nd Joint Statement Highlighting Liquidity Risks to Banks Engaged in Crypto-Asset-Related ActivitiesSEC Chair Continues Push to Regulate Digital Asset Markets

Digital Assets

FINRA Approves Prometheum Ember Capital LLC to Operate as Special Purpose Broker-Dealer for Digital AssetsCFPB And FTC Take Their Place As Powerful Crypto CopsFederal Reserve, FDIC, and OCC Issue the First Joint Statement on Crypto-Asset Risks to Banking Organizations

Dodd-Frank

CFPB Updates Small Business Lending Rule FAQsCFPB Intends to Supervise and Examine Consumer Payments CompaniesSmall Business Lenders: CFPB’s Anticipated Section 1071 Rule Would Impose New Data Collection, Reporting Obligations

Due Diligence

FinCEN Finalizes Customer Due Diligence RuleDue Diligence Outsourcing: Traps for the Unwary

Earned Wage Access Services

Maryland Office of Financial Regulation Provides Guidance on Earned Wage Access ProductsNevada Enacts Nation’s First State Licensing Regime for Earned Wage Access Services

EB-5

SEC Disgorgement Lives to See Another Day After Supreme Court’s Liu v. SEC RulingNot Every Broker-Dealer is an EB-5 Broker-DealerSEC Charges Attorneys Across the Country for Acting as Unlicensed Securities Brokers

economic sanctions

Expansive New Bank Secrecy Act, Sanctions Whistleblower Program: Department of Commerce InsightsCrypto Exchange Bittrex Settles $53 Million in Fines with Treasury Department for Sanctions, Anti-Money-Laundering Violations

EU's Bank Recovery and Resolution Directive

Derivatives Update: What You Should Know As We Enter 2017Article 55 BRRD Can Impact Your Company

European Union

LIBOR Transition Newsletter – Issue 1LIBOR and “No-Deal” BrexitEU Proposes New Rules to Manage Leverage and Derivative Exposure for Funds – Are Asset Managers Ready?

Events

Webinar – Aug. 20: LIBOR Phaseout - Preparing for the Beginning of the EndGreenberg Traurig’s Nanette Aguirre to Speak at Florida Alternative Investment Association Global Macro Perspective 2018Greenberg Traurig Shareholders Jennifer Weddle and Gil Rudolph to Speak at 2017 Tribal Financial Regulators Conference

Exchange-Traded Funds (ETFs)

SEC Proposes Rule Changes to Mutual Fund and Exchange Traded Fund DisclosuresSEC Passes Long-Awaited New Rule 6c-11 to Modernize Regulation of ETFs

Exempt offerings

SEC Issues Concept Release to Overhaul Current Framework for Exempt Offerings

FCA

Updating and Improving the UK Asset Management Regime: An FCA Discussion Paper5 Trends to Watch: 2023 UK Contentious Financial RegulationFCA Takes Next Step Towards a UK Consumer Duty: An Update for Regulated Businesses

FDIC

The 2023 Banking Crisis: Guidance for Private Investors Seeking to Acquire or Invest in Assets of Failed Insured Depository InstitutionsThe 2023 Banking Contagion: Questions & Answers for Insured and Uninsured Depositors, Other Affected PartiesCFPB Issues Report on Unlawful ‘Junk Fees’ Uncovered in Deposit Accounts, Multiple Loan Servicing Markets

Featured

CFPB Issues Guidance on Credit Denials Involving Artificial IntelligenceMaryland Office of Financial Regulation Provides Guidance on Earned Wage Access ProductsCFPB Spotlight Targets Mobile ‘Tap-To-Pay’ Technology

Federal Reserve System

Federal Banking Agencies Propose New Rules to Strengthen Capital Requirements for Large BanksCFPB And FTC Take Their Place As Powerful Crypto CopsThe 2023 Banking Contagion: Questions & Answers for Insured and Uninsured Depositors, Other Affected Parties

Financial Conduct Authority

5 Trends to Watch: 2023 UK Contentious Financial RegulationUK FCA Implements Controversial Change to Its Decision-Making Procedures

Financial Crimes Enforcement Network

FinCEN Proposes Rule on Access to Beneficial Ownership InformationBeneficial Ownership Reporting Requirements: FinCEN Issues Final Rule for Implementation of Corporate Transparency ActCrypto Exchange Bittrex Settles $53 Million in Fines with Treasury Department for Sanctions, Anti-Money-Laundering Violations

Financial Regulation

CFPB Issues Guidance on Credit Denials Involving Artificial IntelligenceMaryland Office of Financial Regulation Provides Guidance on Earned Wage Access ProductsCFPB Spotlight Targets Mobile ‘Tap-To-Pay’ Technology

Financial Services Litigation

Private Fund Adviser RulemakingFederal Banking Agencies Propose New Rules to Strengthen Capital Requirements for Large BanksCFPB Teams with HHS and Treasury to Examine Medical Financial Products

FINRA

FINRA Approves Prometheum Ember Capital LLC to Operate as Special Purpose Broker-Dealer for Digital Assets2023 Report on FINRA’s Examination and Risk Monitoring ProgramFINRA Files Amendments to Proposed Rule Change That Will Allow Remote Inspections

Fintech

CFPB Spotlight Targets Mobile ‘Tap-To-Pay’ TechnologyCFPB And FTC Take Their Place As Powerful Crypto CopsNYDFS Proposes Significant Changes to Its Cybersecurity Regulation

Firm News

Greenberg Traurig’s Carl Fornaris and William Mack Participate at FMA’s Legal and Legislative Issues ConferenceNanette Aguirre to Speak at the Meeting of the Americas 2017 ConferenceNanette Aguirre Joins Board of Florida Alternative Investment Association

First Circuit

First Circuit Offers Rebuke to SEC in Vacating Sanctions Order

Florida

Florida Gov. Signs Bill that Defines ‘Virtual Currency’ and Eases Licensing Restrictions on Certain Virtual Currency Transactions in the State

FLSA

Tyson Foods, Inc. v. Bouaphakeo: Supreme Court Upholds Use of Statistical Evidence in Class Actions

foreclosure

The Ninth Circuit Issued a Ruling in Bourne Valley Court Trust v. Wells Fargo Bank, NAThird District Court of Appeals Reverses Holding on Statute of Limitations for Florida Foreclosures: The Impact of Deutsche Bank Trust Company Americas, as Trustee v. Beauvais

FSOC

Digital Assets: Financial Stability Oversight Council Risk Report Assesses Regulatory Gaps; Offers RecommendationsFSOC Report Targets Marketplace LendingFinancial Stability Oversight Council Releases 2016 Annual Report

Gaming

GT’s Carl Fornaris Moderates Panel at IAGA, Featured in Gambling ComplianceGreenberg Traurig to Participate at the FIBA Anti-Money Laundering Compliance Conference10 TRENDS: Getting Better All the Time

Global

SEC Finalizes Cyber Rules for Public Companies: What You Need to KnowFinCEN and BIS Warn Financial Institutions About Potential Evasion of Russian and Belarusian Export ControlsCOVID-19 Pandemic: Banking & Finance ‘Phase 2’ Measures in Italy

Government

California Regulator Finalizes Rule Expanding UDAAP Authority to Commercial FinancingFederal Banking Agencies Propose New Rules to Strengthen Capital Requirements for Large BanksProposed Legislation Would Create a Tiered Exemption from Broker Registration

GT Alert

Nevada Enacts Nation’s First State Licensing Regime for Earned Wage Access ServicesAre Syndicated Term Loans Securities Under Reves v. Ernst & Young? 2nd Circuit Solicits SEC ViewsThe 2023 Banking Contagion: Questions & Answers for Insured and Uninsured Depositors, Other Affected Parties

Insurance

GT Recap | NAIC Fall 2020 National MeetingIllinois Supreme Court Rules Annuities Are Not Securities Under Illinois Securities ActFred Karlinsky, Rich Fidei, and Jamey Zellner Co-Author Cybersecurity Update in Reactions Magazine

insurance producer

Illinois Supreme Court Rules Annuities Are Not Securities Under Illinois Securities Act

investment advisor

SEC Risk Alert to Investment Advisers: Assessing Risks, Scoping Examinations, and Requesting DocumentsUpdating and Improving the UK Asset Management Regime: An FCA Discussion PaperSEC Issues Risk Alert Regarding Registered Investment Companies

Investment Company Act of 1940

SEC Issues Risk Alert Regarding Registered Investment CompaniesSEC Staff Issues No-Action Relief for Custody of Certain Loan Interests Under the Investment Company ActThe SEC’s 2020 Amendments to Proxy Rules and Supplemental Guidance to Investment Advisers on Proxy Voting Responsibilities

Investment Regulation

SEC Risk Alert to Investment Advisers: Assessing Risks, Scoping Examinations, and Requesting DocumentsProposed Legislation Would Create a Tiered Exemption from Broker RegistrationSEC Issues Long-Awaited Proposed Rule on Climate Disclosures

Lending

Are Syndicated Term Loans Securities Under Reves v. Ernst & Young? 2nd Circuit Solicits SEC ViewsSmall Business Lenders: CFPB’s Anticipated Section 1071 Rule Would Impose New Data Collection, Reporting ObligationsCFPB Expands Anti-Discrimination by Applying UDAAP to Credit and Non-credit Products

LIBOR

2021 SEC Examination Priorities for Securities Industry RegistrantsFinancial Services Insights | Summer 2020Webinar – Aug. 20: LIBOR Phaseout - Preparing for the Beginning of the End

Litigation

SEC Finalizes Cyber Rules for Public Companies: What You Need to KnowAre Syndicated Term Loans Securities Under Reves v. Ernst & Young? 2nd Circuit Solicits SEC ViewsExpansive New Bank Secrecy Act, Sanctions Whistleblower Program: Department of Commerce Insights

Mortgage

CFPB Issues Report on Unlawful ‘Junk Fees’ Uncovered in Deposit Accounts, Multiple Loan Servicing MarketsCFPB Metrics Report Shows Increased Scrutiny of Borrower Access to Servicers, Information, and Loss Mitigation OpportunitiesCFPB Expands Anti-Discrimination by Applying UDAAP to Credit and Non-credit Products

Nevada

Nevada Enacts Nation’s First State Licensing Regime for Earned Wage Access Services

New York

The 2023 Banking Contagion: Questions & Answers for Insured and Uninsured Depositors, Other Affected PartiesNYDFS Proposes Significant Changes to Its Cybersecurity Regulation

OCIE

2020 SEC Exam Priorities for Securities Industry RegistrantsSEC Publishes OCIE 2020 Examination PrioritiesSEC’s Office of Compliance Inspections and Examinations Releases 2019 Examination Priorities

Office of the Comptroller of the Currency

Federal Reserve, FDIC, and OCC Issue 2nd Joint Statement Highlighting Liquidity Risks to Banks Engaged in Crypto-Asset-Related ActivitiesFederal Reserve, FDIC, and OCC Issue the First Joint Statement on Crypto-Asset Risks to Banking OrganizationsUS Federal Banking Regulators Release Joint Statement on ‘Crypto-Asset Policy Sprint Initiative’

PWG

President’s Working Group on Financial Markets Releases Report and Recommendations on Stablecoins

Real Estate

Private Fund Adviser RulemakingThe 2023 Banking Crisis: Updated Questions & Answers for Insured and Uninsured Depositors, Other Affected PartiesThe 2023 Banking Crisis: Guidance for Private Investors Seeking to Acquire or Invest in Assets of Failed Insured Depository Institutions

Regulatory

SEC Finalizes Cyber Rules for Public Companies: What You Need to KnowFINRA Approves Prometheum Ember Capital LLC to Operate as Special Purpose Broker-Dealer for Digital AssetsNevada Enacts Nation’s First State Licensing Regime for Earned Wage Access Services

Regulatory Compliance

CFPB Issues Guidance on Credit Denials Involving Artificial IntelligenceProposed Legislation Would Create a Tiered Exemption from Broker RegistrationAre Syndicated Term Loans Securities Under Reves v. Ernst & Young? 2nd Circuit Solicits SEC Views

Regulatory Decisions Committee

UK FCA Implements Controversial Change to Its Decision-Making Procedures

Retirement

NY Department of Financial Services Proposes its Own Fiduciary Rule in Response to U.S. DOL DelayThe DOL Issues Broader Fiduciary Adviser Definition: What Does it Mean for You?Proposed Fiduciary Rule for Retirement Accounts One Step Closer to Reality

Risk

2023 Report on FINRA’s Examination and Risk Monitoring ProgramFederal Reserve, FDIC, and OCC Issue the First Joint Statement on Crypto-Asset Risks to Banking OrganizationsNYDFS Proposes Significant Changes to Its Cybersecurity Regulation

Risk Management

The 2023 Banking Contagion: Questions & Answers for Insured and Uninsured Depositors, Other Affected PartiesFederal Reserve, FDIC, and OCC Issue the First Joint Statement on Crypto-Asset Risks to Banking OrganizationsCFPB to Examine Nonbank Financial Companies – Including Fintechs – that Pose Risk to Consumers

Sarbanes-Oxley Act

SCOTUS Rules Dodd-Frank Does Not Protect Internal WhistleblowingNinth Circuit Widens Circuit Split on Whether Dodd-Frank Protects Internal Whistleblowing

SEC

SEC Risk Alert to Investment Advisers: Assessing Risks, Scoping Examinations, and Requesting DocumentsAre Syndicated Term Loans Securities Under Reves v. Ernst & Young? 2nd Circuit Solicits SEC ViewsCFPB And FTC Take Their Place As Powerful Crypto Cops

Securities

Proposed Legislation Would Create a Tiered Exemption from Broker RegistrationSEC Finalizes Cyber Rules for Public Companies: What You Need to KnowFINRA Approves Prometheum Ember Capital LLC to Operate as Special Purpose Broker-Dealer for Digital Assets

Securities and Exchange Commission

FINRA Approves Prometheum Ember Capital LLC to Operate as Special Purpose Broker-Dealer for Digital AssetsCFPB And FTC Take Their Place As Powerful Crypto CopsSEC Announces 2023 Examination Priorities

small businesses

CFPB Updates Small Business Lending Rule FAQsSmall Business Lenders: CFPB Issues Final Rule on Small Business LendingCongress Codifies Longstanding M&A Broker Exemption from SEC Registration

Social & Governance (ESG)

SEC Issues Long-Awaited Proposed Rule on Climate Disclosures

Stablecoin

CFPB And FTC Take Their Place As Powerful Crypto CopsFederal Reserve, FDIC, and OCC Issue the First Joint Statement on Crypto-Asset Risks to Banking OrganizationsSEC Chair Continues Push to Regulate Digital Asset Markets

State and Local

California Regulator Finalizes Rule Expanding UDAAP Authority to Commercial FinancingNevada Enacts Nation’s First State Licensing Regime for Earned Wage Access ServicesThe 2023 Banking Contagion: Questions & Answers for Insured and Uninsured Depositors, Other Affected Parties

sustainable finance

OCC Final Rule Modernizing the Community Reinvestment Act Includes New Incentives for Investing in Indian Country

Tax

IRS Issues New Cryptocurrency GuidanceSEC Issues ‘No-Action’ Letters Allowing Sales of Utility TokensBlockchain & Cryptocurrency Newsletter - Winter 2019

TCPA

Greenberg Traurig’s Gil Rudolph and Lori S. Nugent Participate at CCFL’s Annual Consumer Financial Services ConferenceFCC Proposes Rules to Limit the Use of Robocalls to Collect Debts Owed to or Guaranteed by the United States

Technology

CFPB Spotlight Targets Mobile ‘Tap-To-Pay’ TechnologyCFPB Intends to Supervise and Examine Consumer Payments CompaniesUpdating and Improving the UK Asset Management Regime: An FCA Discussion Paper

Token offering

SEC Clears First Two Regulated Token Offerings

Tokyo Metropolitan Government

The ‘Global Financial City Tokyo’ Initiatives

U.S. Financial Market

SEC Seeks to Expand ‘Dealer’ or ‘Government Securities Dealer’ Definition to Require Additional Firms to Register with Agency and Comply with Federal Securities RegulationsSEC Proposes Rule Changes to Mutual Fund and Exchange Traded Fund DisclosuresInteragency Guidance for Financial Institutions on Coronavirus Disease-Related Loan Modifications

U.S. Supreme Court

Financial Services Insights | Spring 2021SEC Disgorgement Lives to See Another Day After Supreme Court’s Liu v. SEC RulingSEC Order Seeks to Clarify Steps Forward Following Lucia

UK

Updating and Improving the UK Asset Management Regime: An FCA Discussion PaperFCA Takes Next Step Towards a UK Consumer Duty: An Update for Regulated BusinessesPrincipals in the Spotlight as UK’s FCA Consults on Changes to Appointed Representatives Regime

Uncategorized

Crypto Exchange Bittrex Settles $53 Million in Fines with Treasury Department for Sanctions, Anti-Money-Laundering ViolationsSEC Passes Long-Awaited New Rule 6c-11 to Modernize Regulation of ETFsProve It or Lose It! Parts I and II: Unexplained Wealth Orders and Civil Recovery Orders in the United Kingdom

Unclaimed Property & Escheat

Cryptocurrencies and Unclaimed Property: Potential Implications of State Escheat Laws for the Blockchain Technology IndustryUnclaimed Property Litigation Update: Victories on the Horizon for the Holder Community?

Unexplained Wealth Order

Prove It or Lose It! Part III: A Step Too Far? Account Freezing Orders & Account Forfeiture Orders in the UKProve It or Lose It! Parts I and II: Unexplained Wealth Orders and Civil Recovery Orders in the United Kingdom

United Kingdom

5 Trends to Watch: 2023 UK Contentious Financial RegulationUK FCA Implements Controversial Change to Its Decision-Making ProceduresAll Systems Go? LIBOR Transition Efforts During the COVID-19 Pandemic

Virtual Currency

CFPB And FTC Take Their Place As Powerful Crypto CopsFederal Reserve, FDIC, and OCC Issue the First Joint Statement on Crypto-Asset Risks to Banking OrganizationsDigital Assets: Financial Stability Oversight Council Risk Report Assesses Regulatory Gaps; Offers Recommendations

white collar

Expansive New Bank Secrecy Act, Sanctions Whistleblower Program: Department of Commerce InsightsENABLERS Act Proposes to Expand Definition of ‘Financial Institution’; Impose BSA/AML Requirements on Professional Service ProvidersFinCEN Proposes Rule on Beneficial Ownership Reporting Under Corporate Transparency Act

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Greenberg Traurig’s Financial Regulatory and Compliance Group brings together attorneys from various offices and practice areas to assist financial services firms of all types and sizes, as well as vendors to those firms, as they face regulatory, legislative, supervision, examination, licensing, compliance, and governance matters

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Webinar – Aug. 20: LIBOR Phaseout – Preparing for the Beginning of the End

On Thursday, Aug. 20 at 11 a.m. EST, join GT Shareholders Carl Fornaris and Oscar Stephens for a complimentary webinar…

Greenberg Traurig’s Nanette Aguirre to Speak at Florida Alternative Investment Association Global Macro Perspective 2018

Nanette Aguirre, corporate shareholder, will participate in the Florida Alternative Investment Association (FLAIA) Global Perspective 2018 Conference in Miami,…

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  • CFPB Updates Small Business Lending Rule FAQs
  • SEC Risk Alert to Investment Advisers: Assessing Risks, Scoping Examinations, and Requesting Documents

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Greenberg Traurig, LLP has more than 2650 attorneys in 47 locations in the United States, Europe and the Middle East, Latin America, and Asia. The firm is a 2022 BTI “Highly Recommended Law Firm” for superior client service and is consistently among the top firms on the Am Law Global 100 and NLJ 250. Greenberg Traurig is Mansfield Rule 5.0 Certified Plus by The Diversity Lab. The firm is recognized for powering its U.S. offices with 100% renewable energy as certified by the Center for Resource Solutions Green-e® Energy program and is a member of the U.S. EPA’s Green Power Partnership Program. The firm is known for its philanthropic giving, innovation, diversity, and pro bono. Web: www.gtlaw.com.

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