The U.S. Department of the Treasury has issued its first proposed rule under the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act, marking a key milestone in federal efforts to regulate payment stablecoins. The Notice of Proposed Rulemaking (NPRM) outlines the principles Treasury will use to assess whether a state’s regulatory regime is “substantially similar” to the federal framework, which determines whether certain stablecoin issuers may be supervised by states rather than the OCC or other federal agencies.… Continue Reading
Kelly A. Lenahan-Pfahlert
Kelly A. Lenahan-Pfahlert | lenahanpfahlertk@ballardspahr.com | 215.864.7311 | view full bio
Kelly focuses her practice on white collar defense and complex civil litigation. Kelly has substantial experience in litigating BSA/AML issues on behalf of financial institutions relating to both discovery and liability, assisting with AML-related internal investigations
FinCEN’s Proposed Rule to Reform Financial Institution AML/CFT
Posted in FinCEN
As part of the U.S. Department of Treasury’s efforts to modernize the U.S. anti-money laundering regulatory and supervisory framework, the Financial Crimes Enforcement Network (FinCEN) has issued a proposed rule that would reform how financial institutions design and operate their anti-money laundering and countering the financing of terrorism (AML/CFT) programs. Though not a wholesale rebuild of the existing framework, FinCEN and the banking regulators are signaling a new emphasis on an approach that prioritizes risk-based effectiveness over process-driven compliance and establish FinCEN’s central role in AML/CFT supervision among the Federal bank regulators.… Continue Reading
Crypto clarity: OCC’s new guidelines pave the way for banking innovation
Posted in OCC
On March 7, 2025, the Office of the Comptroller of the Currency (“OCC”) released Interpretive Letter 1183, marking a pivotal change in regulatory guidance for national banks and federal savings associations engaging in cryptocurrency activities. This recent directive, issued under Acting Comptroller Rodney Hood, rescinds the requirements set by Interpretive Letter 1179 from November 2021.… Continue Reading
Federal banking agencies issue guide to third-party risk management practices for community banks
On May 3, 2024, the Board of Governors of the Federal Reserve System (the “Federal Reserve”), the Federal Deposit Insurance Corporation (“FDIC”), and the Office of the Comptroller of the Currency (“OCC”) jointly released the “Third-Party Risk Management: A Guide for Community Banks” (the “Guide”), presenting it as a resource for community banks to bolster their third-party risk management programs, policies, and practices.… Continue Reading