Alerts Now

Our Alerts Now service can help you keep track of the most recent regulatory updates being made in the compliance world. We review major announcements from 8 regulatory agencies on a weekly basis.

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FinCEN Alert on Real Estate, Luxury Goods, and Other High-Value Assets Involving Russian Elites, Oligarchs, and their Family Members

Issue Date:March 16, 2022
Agency:FinCEN
Highlights:

The Financial Crimes Enforcement Network (FinCEN) is issuing a second alert on the importance of identifying and quickly reporting suspicious transactions involving real estate, luxury goods, and other high-value assets of sanctioned Russian elites and their family members and those through which they act (collectively, “sanctioned Russian elites and their proxies”). This alert provides select red flags to assist financial institutions in identifying suspicious transactions, and reminds financial institutions of their Bank Secrecy Act (BSA) reporting obligations. This alert also complements other recent coordinated U.S. Government actions related to luxury goods, and highlights the establishment of U.S. and international task forces and programs designed to freeze and seize the assets of sanctioned Russian actors.

Reference:

FinCEN Alert on Real Estate, Luxury Goods, and Other High-Value Assets Involving Russian Elites, Oligarchs, and their Family Members | FinCEN.gov

Personnel Affected:BSA Officer, OFAC officer
Status:Guidance
Keywords:Russia, SDN list
Effective Date:
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FinCEN Provides Financial Institutions with Red Flags on Potential Russian Sanctions Evasion Attempts

Issue Date:March 7, 2022
Agency:FinCEN
Highlights:

The Financial Crimes Enforcement Network (FinCEN) today issued a FinCEN Alert, advising all financial institutions to be vigilant against potential efforts to evade the expansive sanctions and other U.S.-imposed restrictions implemented in connection with the Russian Federation’s further invasion of Ukraine. The alert provides examples of red flags to assist in identifying suspected sanctions evasion activity and reminds financial institutions of their reporting obligations under the Bank Secrecy Act.

Reference:

FinCEN Provides Financial Institutions with Red Flags on Potential Russian Sanctions Evasion Attempts | FinCEN.gov

Personnel Affected:BSA officer
Status:Guidance
Keywords:Russia, SDN list
Effective Date:
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Federal Reserve Board invites public comment on supplement to its May 2021 proposal

Issue Date:March 1, 2022
Agency:Federal Reserve
Highlights:

The Federal Reserve Board on Tuesday invited public comment on a supplement to its May 2021 proposal intended to ensure that Reserve Banks use a transparent and consistent set of factors when reviewing requests to access Federal Reserve accounts and payment services.

Reference:

Federal Reserve Board – Federal Reserve Board invites public comment on supplement to its May 2021 proposal

Personnel Affected:Compliance Officer
Status:Comments Due
Keywords:Payments
Effective Date:04/21/2022
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Federal Reserve Board invites public comment on proposed guidance to implement a framework for the supervision of certain insurance organizations overseen by the Board

Issue Date:January 28, 2022
Agency:Federal Reserve
Highlights:

The proposed supervisory framework—for depository institution holding companies significantly engaged in insurance activities—would apply guidance and allocate supervisory resources based on the risk of a firm. It would also formalize a supervisory rating system for these companies and describe how examiners work with state insurance regulators.

Reference:

Federal Reserve Board – Federal Reserve Board invites public comment on proposed guidance to implement a framework for the supervision of certain insurance organizations overseen by the Board

Personnel Affected:insurance brokers
Status:Comments Due
Keywords:insurance
Effective Date:04/01/2022
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Consumer Financial Protection Bureau Launches Initiative to Save Americans Billions in Junk Fees

Issue Date:January 26, 2022
Agency:CFPB
Highlights:

Today, the Consumer Financial Protection Bureau (CFPB) launched an initiative to save households billions of dollars a year by reducing exploitative junk fees charged by banks and financial companies. Today’s request is a chance for the public to share input that will help shape the agency’s rulemaking and guidance agenda, as well as its enforcement priorities in the coming months and years.

Reference:

Consumer Financial Protection Bureau Launches Initiative to Save Americans Billions in Junk Fees | Consumer Financial Protection Bureau (consumerfinance.gov)

Personnel Affected:deposit operations
Status:Comments Due
Keywords:deposit fees
Effective Date:
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FinCEN Issues Proposed Rule for Suspicious Activity Report Sharing Pilot Program to Combat Illicit Finance Risks

Issue Date:January 24, 2022
Agency:FinCEN
Highlights:

The pilot program would permit a financial institution with a SAR reporting obligation to share SARs and information related to SARs with the institution’s foreign branches, subsidiaries, and affiliates for the purpose of combating illicit finance risks, subject to approval and conditions set by FinCEN.  The proposed rule aims to ensure that the sharing of information is limited by the requirements of federal and state law enforcement, takes into account potential concerns of the intelligence community, and is subject to appropriate standards and requirements regarding data security and the confidentiality of personally identifiable information.

Reference:

FinCEN Issues Proposed Rule for Suspicious Activity Report Sharing Pilot Program to Combat Illicit Finance Risks | FinCEN.gov

Personnel Affected:BSA officers
Status:Comments Due
Keywords:SAR
Effective Date:03/28/2022
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FDIC Approves Final Rule Regarding Deposit Insurance Simplification

Issue Date:January 21, 2022
Agency:FDIC
Highlights:

The final rule simplifies deposit insurance coverage for deposits held in connection with revocable and irrevocable trusts by merging these two deposit insurance categories and applying a simpler, common calculation to determine coverage. Currently, the FDIC receives more inquiries related to deposit insurance coverage for trust deposits than all other types of deposits combined. The final rule will make the trust rules consistent and easier to understand for bankers and depositors and will facilitate prompt payment of deposit insurance by the FDIC in the event of an insured depository institution’s failure. Meanwhile, the FDIC expects that the vast majority of trust depositors will experience no change in the coverage for their deposits when the final rule takes effect.

Reference:

FDIC: PR-4-2022 1/21/2022

Personnel Affected:trust personnel
Status:Final Rule
Keywords:deposit insurance
Effective Date:04/01/2024
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Federal Reserve Board releases discussion paper that examines pros and cons of a potential U.S. central bank digital currency (CBDC)

Issue Date:January 20, 2022
Agency:Federal Reserve
Highlights:

The Federal Reserve Board on Thursday released a discussion paper that examines the pros and cons of a potential U.S. central bank digital currency, or CBDC. It invites comment from the public and is the first step in a discussion of whether and how a CBDC could improve the safe and effective domestic payments system. The paper does not favor any policy outcome.

Reference:

Federal Reserve Board – Federal Reserve Board releases discussion paper that examines pros and cons of a potential U.S. central bank digital currency (CBDC)

Personnel Affected:CFO
Status:Comments Due
Keywords:cryptocurrency
Effective Date:05/25/2022
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CFPB Issues Bulletin to Prevent Unlawful Medical Debt Collection and Credit Reporting

Issue Date:January 13, 2022
Agency:CFPB
Highlights:

The Consumer Financial Protection Bureau (CFPB) today released a bulletin reminding debt collectors and credit bureaus of their legal obligations in light of the No Surprises Act, which protects consumers from certain unexpected medical bills. Companies that try to collect on medical bills that are prohibited by the No Surprises Act, or who furnish information to credit bureaus about such invalid debts, may face significant legal liability under the Fair Debt Collection Practices Act (FDCPA) and the Fair Credit Reporting Act (FCRA). The bulletin advises credit bureaus that the accuracy and dispute obligations imposed by the FCRA apply with respect to debts stemming from charges that exceed the amount permitted by the No Surprises Act.

Reference:

CFPB Issues Bulletin to Prevent Unlawful Medical Debt Collection and Credit Reporting | Consumer Financial Protection Bureau (consumerfinance.gov)

Personnel Affected:debt collectors
Status:Bulletin
Keywords:medical debt
Effective Date:
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Federal Reserve Board finalizes technical rule that will streamline reporting requirements for member banks related to their subscriptions to Federal Reserve Bank capital stock

Issue Date:January 10, 2022
Agency:Federal Reserve
Highlights:

The Federal Reserve Board on Monday finalized a technical rule that will streamline reporting requirements for member banks related to their subscriptions to Federal Reserve Bank capital stock. The final rule is substantially similar to the proposal.

Reference:

Federal Reserve Board – Federal Reserve Board finalizes technical rule that will streamline reporting requirements for member banks related to their subscriptions to Federal Reserve Bank capital stock

Personnel Affected:CFO
Status:Final Rule
Keywords:reporting
Effective Date:02/17/2022