RESULTS FOR: Financial Crime Consulting
FinCEN’s Assessment on the Use of No-Action Letters—What Happens Next?
July 26, 2021 | Financial Crime Consulting
On June 30, 2021, the Financial Crimes Enforcement Network (“FinCEN”) finished an assessment of whether it should create a process for issuing no-action letters in connection with the Bank Secrecy Act (“BSA”) and other anti-money laundering and countering the financing of terrorism (“AML/CFT”) laws and regulations. The short answer is Yes—FinCEN has concluded that a no-action letter process would be valuable, and the agency will be taking steps towards a rulemaking.
A no-action letter is a letter from an agency … Read More
5 Tips to Best Position Your Fintech for a Banking Charter License Application
March 23, 2021 | Financial Crime Consulting Risk + Compliance
Recently, several financial technology (“Fintech”) organizations have applied for – and been granted – banking charter licenses. For example, in May 2019, Grasshopper was approved for a charter issued by the Office of the Comptroller of the Currency, while in July 2020, Varo Money was approved for a national bank charter.
As mentioned in an earlier post, in March, Square, Inc. (“Square”) announced that it had commenced banking operations under its independently governed subsidiary industrial bank, Square Financial Services … Read More
The Unique Advantages Fintechs Have When Expanding into Banking Operations – A Trend is Underway
March 12, 2021 | Financial Crime Consulting Risk + Compliance
On March 1, 2021, Square, Inc. (“Square”) announced that it had commenced banking operations under its independently governed subsidiary industrial bank, Square Financial Services (“Square Financial”). The announcement comes after Square successfully completed the charter approval process with the Federal Deposit Insurance Corporation (“FDIC”) and the Utah Department of Financial Institutions for an Industrial Bank/Industrial Loan Corporation (“ILC”) license. Square Financial will offer business loan and deposit products, beginning with underwriting and originating business loans for Square’s existing sellers who … Read More
Bank Secrecy Act Modernization Likely to Increase BSA/AML Enforcement, Including From Larger Whistleblowing Awards
January 13, 2021 | Financial Crime Consulting
2020 saw a substantial amount of enforcement activity in the BSA/AML/OFAC area. Even prior to last month’s enactment of the Anti-Money Laundering Act of 2020 (the “2020 AMLA”), conventional wisdom favored an increase in enforcement activity by regulators and prosecutors for violations of laws in these areas under the incoming Biden Administration. [See Division F]
The 2020 AMLA just gave this area of enforcement a significant shot in the arm. In an era where federal legislation has become … Read More