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…
On November 6, 2019, the Fraud Section of the Department of Justice with the Office of the U.S. Attorney for the Southern District of Texas, and the CFTC, announced settlements of their spoofing and market manipulation investigations of Tower Research…
On September 16, 2019, the Department of Justice and the CFTC jointly announced the indictment of three precious metal traders for an alleged eight year conspiracy to manipulate gold, silver, platinum, and palladium futures prices and civil charges based upon…
By Neil Bloomfield. In another sign of progress, the Federal Deposit Insurance Corporation (FDIC) proposed easing a rule that requires banks to put cash aside to safeguard derivatives trades among affiliates. The proposal would remove the current requirement for members…
By Neil Bloomfield and Kristina Whittaker. Operational risk is a continuing and increasing focus of the Office of the Comptroller of the Currency, and, as a result, it needs to be a greater priority of the institutions it regulates. The…
Colleagues, I hope you are enjoying your summer and have had or are planning a break. Summer breaks help us maintain a healthy balance of rest and work. Ed O'KeefeEd O’Keefe, former Global General Counsel of Bank of America Corporation, advises…
By Elena F. Mitchell, Barbara S. Meeks, and Neil T. Bloomfield* Elena MitchellElena Mitchell is an Associate with the Litigation team in Moore & Van Allen’s Charlotte office. Her practice primarily focuses on complex litigation matters in state and federal court.…
The article titled “The Time Is Now to Prepare for Congressional Inquiries from a Democrat-Led House,” written by Charlotte Members Neil Bloomfield and Edward O’Keefe, and Associate Elena Mitchell, was published and first appeared in the March 4, 2019 edition…