Insights

December 4, 2023 | Due Diligence Financial Crime Consulting Risk + Compliance

What You Need to Know

In October 2023, the Department of Treasury’s Office of Foreign Asset Control (OFAC) enacted multiple sanctions targeting the supply chain of fentanyl and other illicit drugs. In addition to sanctions compliance obligations, financial institutions that deal in trade finance should modify their existing sanctions and suspicious monitoring programs to identify narcotics traffickers who produce, sell and purchase chemicals of interest. These additional efforts would both combat the fentanyl crisis and limit the financial institution’s risk … Read More

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

March 12, 2021 | Financial Crime Consulting Risk + Compliance

In 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 use its … Read More

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