Bank Secrecy Act (Title 31) Regulations: Enforcement Priorities and Compliance Issues Explored

2021-10-19T22:17:18-04:00

Regulatory supervision of reporting companies is expected to intensify with the Anti-Money Laundering Act of 2020 (AMLA) amendment of Title 31 of the Bank Secrecy Act (BSA). Title 31 revisions include new BSA violations and penalties regarding incomplete or false reports and transactions that involve entities labeled as “primary money laundering concerns.” Reporting requirements concerning beneficial ownership and expansion of the U.S. law’s authority to subpoena foreign banks have also been added.

Recent BSA/AML Trends and Developments: Best Compliance Practices for Your Client

2021-05-14T05:41:43-04:00

As threats of financial crimes continue to grow, enforcement actions under the Bank Secrecy Act/Anti-Money Laundering (BSA/AML) remain to have a significant impact and implication on future regulations.  Recently, the Office of the Comptroller of the Currency (OCC) released its 2020 bank supervision operating plan that sets forth its supervisory strategies and objectives regarding BSA/AML compliance.

LIBOR Transition: Demystifying Trends, Developments, and Legal Issues

2021-03-23T22:30:09-04:00

The concurrent LIBOR transition activities remain to be a major issue for global financial institutions. Recently, the Alternative Reference Rates Committee (ARRC) released a consultation seeking comments intended as part of its fallback provision recommendations for cash products referencing LIBOR. This, along with the other trends and developments that are anticipated to arise, continues to cloud the current legal climate.

‘Zombie’ LIBOR for USD Contracts: Navigating the Critical Issues

2021-05-28T03:36:42-04:00

The scheduled phase-out of the London Interbank Offered Rate (LIBOR) by the end of 2021 is currently posing significant transition challenges for banks and all concerned individuals. Furthermore, ICE Benchmark Administration Limited (IBA) announced last December 2020 the extension of U.S. dollar (USD) LIBOR through June 2023, creating a change in the LIBOR transition process and opening more ambiguities in managing USD contracts.

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