On September 11, 2026, the OCC, FDIC, Federal Reserve, and NCUA proposed to replace the 2023 Interagency Guidance on Third-Party Relationships with a shorter, principles-based document.1 Two companion releases complete the package: a final interagency statement on the supervision
FinTalk
FinTalk, published by Crowell & Moring LLP, focuses on legal developments and regulatory issues in financial services and related sectors. The blog covers topics such as management service organizations (MSOs) in law firms, third-party litigation funding and its regulatory frameworks in the US and UK, transparency and disclosure requirements for limited liability companies, and regulatory actions by financial authorities including FinCEN. It also addresses emerging areas like crypto-asset disputes and fintech regulatory challenges. The content includes analysis of legislative changes, compliance obligations, and enforcement actions affecting financial institutions, law firms, and investors.
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You Can Say More Than You Think: Regulators Clarify SAR Confidentiality for Customer Communications
Key Takeaway
On September 2, 2026, the Federal Reserve, FDIC, NCUA, OCC, and FinCEN confirmed that a bank may tell a customer that an account restriction or closure, or a rejected deposit, may be related to suspected fraud or other…
OCC and FDIC Redefine “Unsafe or Unsound Practices”: The New Supervisory Framework for Banks
On August 27, 2026, the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) jointly issued a final rule that, for the first time, gives the term “unsafe or unsound practice” a binding regulatory…
Crowell’s Paul Muscutt Quoted in Car Dealer Magazine UK on Collapsed Car Finance Litigation Funder
By Paul Muscutt
Paul Muscutt was recently quoted in Car Dealer Magazine UK in an article covering the collapse of car finance litigation funder Woodville Consultants in a £330 million bankruptcy.
Paul and Crowell’s London Restructuring and Insolvency team have been appointed by…
Crowell’s Cristina Diaz Featured in Corporate Counsel Q&A on What Separates Great Bank Regulatory Lawyers
Cristina Diaz was recently featured in an in-depth Corporate Counsel Q&A that covers her return to private practice after more than a decade in-house at UBS.
In the interview, Cristina discusses what her years in-house taught her about turning regulatory…
FinCEN Finalizes BOI Reporting Rule: What U.S. Companies Need to Know
Key Takeaway: Domestic reporting companies—meaning entities formed under the laws of any U.S. state or Tribal jurisdiction—have no beneficial ownership information reporting obligations to FinCEN under the final rule.
What happened: On August 14, 2026, the Financial Crimes Enforcement Network…
Following the Money: FinCEN Maps the Financial Footprint of Human Smuggling
What You Need to Know
Key takeaway #1: On August 13, 2026, FinCEN issued a Financial Trend Analysis showing 67,540 Bank Secrecy Act (BSA) reports filed between 2023 and 2025 involved more than $4.9 billion in reported suspicious activity potentially…
Lending Against Digital Assets: Five Key Takeaways for Lenders After a Year of Regulatory and UCC Change
What You Need to Know
Key takeaway #1: Bank regulators have shifted from prior approval to examination scrutiny. Banks no longer need supervisory nonobjection to lend against crypto collateral. Regulators are likely to focus their examinations on collateral operations, BSA/AML…
Crowell & Moring Expands Financial Services Group with Former UBS Bank USA General Counsel Cristina Diaz
Crowell & Moring has added Cristina Diaz, former executive director and general counsel of UBS Bank USA, and most recently head of legal for UBS’s U.S. Remediation Management Office, to the firm’s Financial Services Group as senior counsel in…
QFMA Introduces International Licensing Regime for Financial Services Firms
The Board of Directors of the Qatar Financial Markets Authority (QFMA) has issued Decision No. 3 of 2026, introducing the Instructions for the International License to Practice Certain Activities in International Financial Markets (the Instructions).
The Instructions create a regulatory…