Risk Assessment

Three Members of Congress and U.S. Treasury Express Concerns that Florida Law Prohibiting Banks from Considering Customers’ Business Sectors or Political or Religious Beliefs Conflicts with Federal AML/CFT Requirements

By Kristen E. Larson & Peter D. Hardy on July 30, 2024

Posted in Risk Assessment, State regulation

As we previously blogged, a Florida law (Fla. Stat. § 655.0323, entitled “Unsafe and unsound practices”) which became effective July 1, 2024 prohibits federal and state depository institutions conducting business in the state from denying services based on religion or political beliefs and activities. Every year, financial institutions must attest to their compliance with the Florida law.… Continue Reading

Federal Banking Agencies Issue NPRM Consistent with FinCEN’s AML/CFT Modernization Proposal

By Kaley Schafer on July 29, 2024

Posted in BSA/AML, FDIC, Federal Reserve Board, NCUA, OCC, Proposed Rulemaking, Risk Assessment

The federal banking agencies, including the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of the Comptroller of the Currency (collectively the “Agencies”), issued a notice of proposed rulemaking (“Agencies’ NPRM”) to modernize financial institutions’ anti-money laundering and countering terrorist financing (“AML/CFT”) programs.… Continue Reading

Department of Treasury Issues Strategy on De-Risking

By Shauna Pierson & Peter D. Hardy on May 23, 2023

Posted in AMLA of 2020, BSA/AML, Correspondent Bank Accounts, De-Risking, Money Services Business, Not-For-Profits, Risk Assessment

Report Offers Weak Insight on Causation but Lists Steps that Treasury Can and Should Take

The Department of Treasury (“DOT”) recently released its first ever strategy report (the “Strategy”) on the topic of de-risking, taking the form of a 54-page document that combines a summary of the problem of de-risking with an overview of recommended steps to solve it.… Continue Reading