Crypto-asset businesses, particularly those offering crypto lending, non-fungible tokens, or digital wallet/payments products — which are already facing intense scrutiny from the SEC, CFTC, U.S. Department of Justice and U.S. Department of the Treasury — should not neglect the need to prepare for CFPB and FTC scrutiny. This article explores this trend by the CFPB
On Jan. 3, 2023, the Board of Governors of the Federal Reserve System (Federal Reserve), Federal Deposit Insurance Corporation (FDIC), and Office of the Comptroller of the Currency (OCC) (collectively, the “Agencies”) issued a joint statement (Joint Statement) that reiterates prior crypto-related guidance and highlights crypto-asset risks to banking organizations. The Joint Statement follows a
Welcome to the inaugural issue of Greenberg Traurig’s Financial Services Insights. The impact of Coronavirus Disease 2019 (COVID-19) has been both unexpected and devastating. As the economic fallout spreads, financial institutions are faced with major challenges in how they conduct business and interact with their customers. This newsletter reviews significant cases and legal developments affecting
On July 22, 2019, the federal bank regulatory agencies and the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (collectively, the “Agencies”), issued a Joint Statement on Risk-Focused Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Supervision. The Joint Statement emphasizes their risk-focused approach to examinations of banks’ BSA/AML compliance programs and is the third statement
Today, the SEC announced the adoption of amendments to several rules under the Investment Advisers Act of 1940 and to Form ADV, the investment adviser registration and reporting form. Although there is a long lead-in time to get in compliance with the new rules and Form ADV, advisers should consider beginning work now to
In connection with the Press Release announcing a Rule Proposal regarding adoption of written business continuity and transition plans by SEC-registered investment advisers (see our blog post on the topic), the Division of Investment Management also distributed a Guidance Update (No. 2016-04) discussing BCPs for registered investment companies (RICs). RICs have been expected to address
On June 23, 2016 the Office of the Comptroller of the Currency (OCC) hosted the Forum on Responsible Innovation in the Federal Banking System in Washington, D.C. Hundreds of industry stakeholders gathered to discuss “Responsible Innovation,” fintech, and the role of the OCC in regulating the financial industry as it evolves. The forum addressed reaction
There is no doubt that the regulation of financial technology (fintech) companies is on the rise. Fintech companies broadly mean companies that provide products, services and technology where traditional banking and financial services leave off and technology takes off.
Though all of the federal banking agencies and other agencies will play a vital role in
On Jan. 11, 2016, the Office of Compliance Inspections and Examinations (OCIE) of the U.S. Securities and Exchange Commission (SEC) issued its annual Examinations Priorities for 2016 (Exam Priorities), which is available for download here. In the Exam Priorities, OCIE notes that its priorities focus on the same three thematic areas as in 2015