By Kristina Whittaker and Ed O’Keefe. For the last three weeks or so, the federal and state banking agencies, collectively and individually, have, with increasing urgency, called on financial institutions to meet the financial needs of customers impacted by the COVID-19. Congress…
The shuttered storefronts and grounded airplanes that by now have become an all too familiar image of the COVID-19 pandemic are quickly creating a ripple effect through the U.S. economy. As unemployment rises and Americans struggle to pay their bills,…
By: Elena F. Mitchell and Frank Schall. Further implementing the Foreign Investment Risk Review Modernization Act of 2018 (“FIRRMA“), the U.S. Department of the Treasury recently published a proposed rule to establish filing fees for parties filing voluntary notices of…
By Kate Wellman and Neil Bloomfield. As COVID-19 continues to spread globally, U.S. financial services regulators have released guidance to their supervised institutions to encourage proactive planning for what may be months of sustained impact to business infrastructure and the…
The transition away from LIBOR was born from the financial crisis. For years regulators have been pushing for an alternative to the dominant market benchmark. The underlying market was illiquid. The rate was set by opinion, not transactions. It was…
A black swan has arrived – the Pandemic of 2020 and with it a bear market. As with previous black swan events, experts and leaders are in learning mode, with the facts and events evolving hourly. As my financial advisor…
Last week, the House Financial Services Committee Subcommittee on National Security, International Development and Monetary Policy held a hearing on transnational trafficking networks and illicit finances. Titled “The Traffickers’ Roadmap: How Bad Actors Exploit Financial Systems to Facilitate the Illicit…
By: Elena F. Mitchell and Frank Schall. The U.S. Department of the Treasury recently published final regulations to further implement the Foreign Investment Risk Review Modernization Act of 2018 (“FIRRMA“) and to better address national security concerns resulting from certain…
On January 24, 2020 the CFPB issued a long-awaited policy statement about the meaning of “abusiveness” in the Bureau’s frequently-used enforcement weapon, 1031(d) of the Dodd-Frank Act, commonly referred to as UDAAP. Unlike the standards for unfairness and deceptiveness (the…
Anti-Money Laundering and Know Your Customer departments at financial institutions are on the front lines of human trafficking. Not only does enhanced transaction monitoring help law enforcement identify trafficking circumstances through generation of Suspicious Activity Reports but it helps avoid…