transaction monitoring

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In a pair of coordinated actions on April 24, 2026, the Office of the Comptroller of the Currency (OCC) moved to reaffirm and expand the scope of National Bank Act (NBA) preemption to credit and debit card interchange fees and the use of electronic payment transaction data.

The OCC issued (i) an interim final rule clarifying that interchange fees are protected “non-interest charges,” and (ii) an interim final order expressly preempting the Illinois Interchange Fee Prohibition Act (IFPA).… Continue Reading

Second in a Two-Part Series on the Utility of BSA Filings

In this post, we will once again consider the issue of the utility of Bank Secrecy Act (BSA) filings to the global anti-money laundering/countering the financing of terrorism (AML/CFT) compliance regime. 

In our first blog post in this series, we invited Don Fort, a former Chief of the Internal Revenue Service’s Criminal Investigation (CI) Division, to answer questions on utility of BSA filings from the perspective of law enforcement. … Continue Reading