Another Joint Statement from the Federal Anti-money Laundering Working Group: Improving Transparency of Risk-Focused BSA/AML Supervision

By Marc-Alain Galeazzi & Barbara Mendelson on August 27, 2019

On July 22, 2019, the five federal agencies tasked with the supervision, examination, and enforcement of Bank Secrecy Act and anti-money laundering requirements for banks issued a joint statement clarifying their risk-based approach to BSA/AML examinations. Our alert discusses the key implications of the Statement. Read our client alert.…

MoFo ReEnforcement: The Enforcement Blog

Agencies Issue Final Rule Conforming Volcker Rule Regulations to 2018 Regulatory Relief Act

By Henry Fields, Marc-Alain Galeazzi, Oliver Ireland, Jiang Liu, Barbara Mendelson & Mark Sobin on August 27, 2019

On July 22, 2019, a final rule conforming the Volcker Rule regulations to Sections 203 and 204 of the Economic Growth, Regulatory Relief, and Consumer Protection Act (“Regulatory Relief Act”) was published in the Federal Register. The final rule, and the provisions of the Regulatory Relief Act upon which it is based, exclude certain community banks from coverage of the Volcker Rule and relax restrictions on banking entities using the same name as hedge funds and…

MoFo ReEnforcement: The Enforcement Blog

Federal Reserve Proposes New Control Regulations

By Henry Fields, Marc-Alain Galeazzi, Oliver Ireland, Jiang Liu, Barbara Mendelson, Meghan Dwyer & Mark Sobin on May 1, 2019

The Board of Governors of the Federal Reserve System released a proposed rule to revise regulations related to the determination of “control” under the Bank Holding Company Act (“BHC Act”) and the Home Owners’ Loan Act. The Proposed Rule would incorporate existing interpretations under the “controlling influence” prong of the control definition into Federal Reserve regulations and would make certain adjustments to historical Federal Reserve practice in this area. Read our client alert.…

MoFo ReEnforcement: The Enforcement Blog

Banking Agencies Propose a More Tiered Approach to Large Foreign Bank Supervision

By Henry Fields, Marc-Alain Galeazzi, Oliver Ireland, Jiang Liu, Barbara Mendelson, Meghan Dwyer & Mark Sobin on April 25, 2019

On April 8, 2019, the federal banking agencies released two proposals which, if adopted, would further tailor the approach to supervision of large foreign banking organizations (FBOs). For FBOs with a more significant U.S. presence, the proposals would establish categories for the application of requirements based on size and certain other risk-based indicators. These categories would parallel the tailored framework proposed for the supervision of large domestic banking organizations released in November 2018. Read our client …

MoFo ReEnforcement: The Enforcement Blog

Federal Reserve and FDIC Issue Proposed Changes to Resolution Plan Requirements for Foreign and Domestic Banking Organizations

By Henry Fields, Marc-Alain Galeazzi, Oliver Ireland, Jiang Liu, Barbara Mendelson, Meghan Dwyer & Mark Sobin on April 25, 2019

On April 8 and 16, 2019, the Federal Reserve and the FDIC published proposed changes to resolution plan (or “living will”) requirements applicable to U.S. and foreign banking organizations. The regulatory changes are necessary because the 2018 Regulatory Relief Act raised the asset thresholds for applicability of the living will requirements. The proposal would apply different filing frequency and informational content requirements based on the risk a firm poses to the U.S. financial system. Read our…

MoFo ReEnforcement: The Enforcement Blog

Agencies Issue Further Guidance Regarding Emerging Approaches to BSA/AML Compliance

By Barbara Mendelson, Marc-Alain Galeazzi & Meghan Dwyer on December 14, 2018

On December 3, 2018, the Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, Financial Crimes Enforcement Network, National Credit Union Administration, and Office of the Comptroller of the Currency (collectively, the “Agencies”) issued a joint statement regarding “innovative approaches” to Bank Secrecy Act/anti-money laundering compliance. This is the second joint statement issued this year by the Agencies addressing approaches to BSA/AML compliance. This alert discusses those statements along with the broader…

MoFo ReEnforcement: The Enforcement Blog

OCC Guidance Suggests Flexibility for Third-Party Risk Management

By Oliver Ireland, Barbara Mendelson, Nate Taylor, Jeremy Mandell & Calvin Funk on June 12, 2017

On June 7, 2017, the Office of the Comptroller of the Currency issued frequently asked questions that supplement the OCC’s 2013 guidance entitled “Third-Party Relationships: Risk Management Guidance.” The 2013 Bulletin sets forth the OCC’s expectation for banks’ due diligence and ongoing monitoring of third-party service providers, including enhanced diligence and monitoring for third parties that support critical activities. While the FAQs affirm this guidance, they provide substantial flexibility for banks to right-size their approach…

Barbara Mendelson

Another Joint Statement from the Federal Anti-money Laundering Working Group: Improving Transparency of Risk-Focused BSA/AML Supervision

Agencies Issue Final Rule Conforming Volcker Rule Regulations to 2018 Regulatory Relief Act

Federal Reserve Proposes New Control Regulations

Banking Agencies Propose a More Tiered Approach to Large Foreign Bank Supervision

Federal Reserve and FDIC Issue Proposed Changes to Resolution Plan Requirements for Foreign and Domestic Banking Organizations

Agencies Issue Further Guidance Regarding Emerging Approaches to BSA/AML Compliance

OCC Guidance Suggests Flexibility for Third-Party Risk Management

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