On April 18, 2019, the Financial Crimes Enforcement Network of the U.S. Department of the Treasury announced the assessment of a civil money penalty against Eric Powers for willfully violating the registration, program and reporting requirements of the Bank Secrecy Act and its implementing regulations. Between December 2012 and September 2014, Mr. Powers acted as
Donald J. Mosher
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SEC Publishes First-Ever No-Action Letter for a Cryptocurrency Enterprise and a Framework for when a Cryptocurrency Is a Security
By Charles J. Clark, Stephanie R. Breslow, Marc E. Elovitz, Donald J. Mosher, Howard Schiffman, Melissa G.R. Goldstein, Bayard P. Brown & Schulte Roth & Zabel on
On April 3, 2019, the U.S. Securities and Exchange Commission published a framework aimed at assisting in determining whether a digital asset is a security. Alongside the Framework, the SEC also published a no-action letter for TurnKey Jet, Inc., the first ever no-action letter for a digital asset enterprise.
This is an important development for…
CFPB Proposes Revisions to Its Policy on No-Action Letters and Creation of New Product Sandbox to Spur Fintech Innovation
The Consumer Financial Protection Bureau (“CFPB”) recently issued a proposal consisting of (i) revisions to its Policy on No-Action Letters — which was finalized in February 2016 (“2016 Policy”) — designed to increase interest in applying for no-action letters (“NALs”) under the 2016 Policy; and (ii) the creation of a CFPB Product Sandbox (collectively, the…
FinCEN and Federal Banking Agencies Issue Statement on Pooling Resources for BSA Compliance
Posted in Bank Regulatory
On Oct. 3, 2018, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, the Office of the Comptroller of the Currency and the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (collectively, the “Agencies”) issued an interagency statement regarding the sharing of Bank Secrecy…
OCC Begins Accepting Fintech Charter Applications
Posted in Bank Regulatory, OCC
On July 31, 2018, the Office of the Comptroller of the Currency (“OCC”) issued a news release announcing that it will begin accepting special purpose national bank (“SPNB”) charter applications from fintech companies that do not take deposits but are engaged in the business of lending money or paying checks (including the modern equivalent thereof,…