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Federal Reserve, FDIC, and OCC Issue 2nd Joint Statement Highlighting Liquidity Risks to Banks Engaged in Crypto-Asset-Related Activities

By Marina Olman-Pal, Mark D. Shaffer, Steven T. Cummings & Janiell "Alexa" Gonzalez on March 13, 2023
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On Feb. 23, 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) (collectively, the Agencies) issued a joint statement (Joint Statement) that highlights liquidity risks crypto-asset-related (CAR) funding sources pose to banking organizations and provides some effective practices to manage such risks.

Click here to continue reading the full GT Alert.

Photo of Marina Olman-Pal Marina Olman-Pal

Marina Olman-Pal is a Co-Chair of the firm’s Financial Regulatory & Compliance Practice. She advises foreign and U.S. financial institutions on a broad range of U.S. federal and state regulatory and compliance matters including licensing/chartering, acquisitions, mergers, divestitures, third-party risk management and oversight…

Marina Olman-Pal is a Co-Chair of the firm’s Financial Regulatory & Compliance Practice. She advises foreign and U.S. financial institutions on a broad range of U.S. federal and state regulatory and compliance matters including licensing/chartering, acquisitions, mergers, divestitures, third-party risk management and oversight issues, BaaS and other bank/fintech-related matters, compliance with Bank Secrecy Act (BSA)/anti-money laundering (AML) laws and regulations, GENIUS Act and fair access law matters.

Marina counsels a wide range of companies in the financial services sector including, domestic and foreign banks, money services businesses including money transmitters, cryptocurrency businesses, Fintech companies, digital payment companies, and non-financial services companies considering new payment or digital wallet models. 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.

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Photo of Mark D. Shaffer Mark D. Shaffer

Mark Shaffer advises U.S. and foreign financial institutions, broker-dealers, cryptocurrency businesses, fintech companies, and digital payment companies on a broad range of regulatory and compliance matters relating to SEC regulations, FRB and other banking regulations, FINRA rules, and Bank Secrecy Act (BSA)/anti-money laundering

…

Mark Shaffer advises U.S. and foreign financial institutions, broker-dealers, cryptocurrency businesses, fintech companies, and digital payment companies on a broad range of regulatory and compliance matters relating to SEC regulations, FRB and other banking regulations, FINRA rules, and Bank Secrecy Act (BSA)/anti-money laundering (AML) laws and regulations. He frequently helps clients understand how such laws and regulations map onto new technologies and innovative products.

Mark assists financial institutions, their employees, and associated persons to respond to regulatory examinations and inquiries and provides effective representation in a range of enforcement proceedings. Mark has handled enforcement matters involving issues relating to currency and equities market manipulation, collusion, insider trading, money laundering, OFAC sanctions, false statements, and accounting fraud. Throughout his career, Mark has represented clients before the U.S. Department of Justice and regulators such as the SEC, CFTC, Federal Reserve, FinCEN, OFAC, and the New York State Department of Financial Services.

Mark has assisted multiple banking entities in resolving MRAs and MRIAs, and in developing and implementing compliance programs and regulatory remediation plans. Mark also assists companies in staying current on material changes to applicable laws, rules and regulations, and helps to develop or amend their policies, procedures, controls, compliance manuals and related training.

Prior to joining the firm, Mark practiced at two large law firms in Washington, D.C. and served as an in-house counsel and compliance officer at a variety of global financial institutions. Mark clerked for Judge Richard L. Nygaard of the United States Court of Appeals for the Third Circuit.

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Photo of Steven T. Cummings Steven T. Cummings

Steven T. Cummings focuses his practice on the regulation of financial services providers, including virtual currency companies, money transmitters, payment processors, and fintech companies.

In his prior role as the Virtual Currency Applications Team lead for the New York State Department of Financial…

Steven T. Cummings focuses his practice on the regulation of financial services providers, including virtual currency companies, money transmitters, payment processors, and fintech companies.

In his prior role as the Virtual Currency Applications Team lead for the New York State Department of Financial Services, Steven supervised the virtual currency team in evaluating virtual currency applications for regulatory compliance with anti-money laundering, cybersecurity, and consumer protection requirements.

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Photo of Janiell "Alexa" Gonzalez Janiell "Alexa" Gonzalez

Janiell A. Gonzalez focuses her practice on helping bank and non-bank financial institutions navigate the federal and state regulatory environment governing payments, lending, and consumer financial services. She represents and advises industry leaders in the development and implementation of emerging payment products, including…

Janiell A. Gonzalez focuses her practice on helping bank and non-bank financial institutions navigate the federal and state regulatory environment governing payments, lending, and consumer financial services. She represents and advises industry leaders in the development and implementation of emerging payment products, including Internet- and mobile-based payment products and services. Janiell regularly assists clients with federal money services business registrations, nationwide state money transmitter and lending licensing applications, and ongoing licensing compliance issues. Janiell helps clients design Bank Secrecy Act (BSA)/Anti-Money Laundering (AML)/Office of Foreign Asset Control (OFAC) compliance policies and procedures, conducting independent risk assessments, and providing company-wide training on these topics.

Janiell also serves as the Deputy General Counsel for the Hispanic National Bar Association’s charitable arm, HNBA VIA, where she provides advice on a broad range of legal issues affecting the organization.

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  • Posted in:
    Banking, Finance and Securities
  • Blog:
    Financial Services Observer
  • Organization:
    Greenberg Traurig, LLP
  • Article: View Original Source

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