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RESULTS FOR: FinCEN

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

Regulators Are Catching Up With The Crypto Boom

October 4, 2018 | Compliance Financial Crime Consulting

As published in Forbes, September 27, 2018.

Say goodbye to the under-regulated era of cryptocurrency. While crypto trading on the more mainstream exchanges is fueling the market, it’s also bringing greater scrutiny from regulators, as shown by the recent report by the New York State Attorney General’s office (OAG) on crypto exchange abuse, The Financial Action Task Force (FATF) announcements about upcoming crypto standards, and warnings to investors. And as guidance emerges and enforcement actions increase, crypto exchanges will, … Read More

Out of Many, One? — The Future of U.S. FinTech Regulation

October 2, 2018 | Compliance Financial Crime Consulting

As published in FinTechWeekly August 29, 2018.

Not for the first time, the federal government and states are at odds over the future regulation of FinTech.

On July 31, 2018, the Office of the Comptroller of Currency (OCC) at the U.S. Department of the Treasury (DoT) announced it would begin accepting applications from FinTechs for special bank charters, which would allow them to operate nationally. But individual states and inter-state organizations are strongly opposed. The Conference of State Bank Supervisors … Read More

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