By

David Teitelbaum

24 December 2020

FinCEN Proposes Tracking and Reporting Virtual Currency Transactions Involving Unhosted Wallets

On December 18, 2020, the Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking (NPR) regarding a proposal to impose on banks1 and money service businesses (MSBs) new recordkeeping, reporting, and identity verification requirements in relation to certain transactions involving convertible virtual currency (CVC) or digital assets … Read More

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23 December 2020

Comments Sought on Proposed Rulemaking: Computer-Security Incident Notification Requirements for Banking Organizations and Their Bank Service Providers

On December 15, 2020, the U.S. Federal Deposit Insurance Corporation (FDIC) approved and the federal banking agencies jointly announced on December 18 a notice of proposed rulemaking, Computer-Security Incident Notification Requirements for Banking Organizations and Their Bank Service Providers (NPR).1 The NPR is a joint proposal by the Office … Read More

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05 October 2020

Introducing Sidley’s Blockchain Legal Launch Pad

Adoption of blockchain and distributed ledger technology has the potential to revolutionize business and business practices in ways not seen since the advent of the internet and e-commerce.

Whether you are directly responsible for researching, developing, or implementing new blockchain initiatives, or you are executive management and need a more … Read More

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07 July 2020

NYDFS Announces a Series of Virtual Currency Initiatives

On June 24, 2020, the New York State Department of Financial Service (NYDFS) announced a series of virtual currency initiatives aimed at providing additional opportunities and clarity for BitLicense and limited-purpose trust company applicants and licensees. These initiatives include:

  • A proposed framework for obtaining a conditional BitLicense when partnering with
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12 June 2020

The U.S. Office of the Comptroller of the Currency Seeks Comment on Digital Innovation by Banks

The U.S. Office of the Comptroller of the Currency (OCC) has issued an Advance Notice of Proposed Rulemaking (ANPR)1 seeking input on how best to accommodate new technology and innovation in the business of banking, in connection with the OCC’s “comprehensive review” of its regulations at 12 C.F.R. part … Read More

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23 March 2020

U.S. Office of the Comptroller of the Currency Updates Third-Party Relationships Risk Management Guidance

On March 5, 2020, the Office of the Comptroller of the Currency (OCC) issued an updated set of answers to frequently asked questions (FAQs)1 regarding risk management in national bank relationships with third parties to further supplement its 2013 guidance, OCC Bulletin 2013-29 (the Bulletin),2 and its 2017 … Read More

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10 January 2020

California Department of Business Oversight December 2019 Actions

The California Department of Business Oversight (CDBO) recently concluded that the point of sale consumer financing programs offered by Sezzle, Inc., and another, unnamed party constituted making loans for purposes of the California Financing Law (CFL). A number of payment providers and technology companies have been developing innovative payment options, … Read More

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06 December 2019

Federal Banking Agencies Release Joint Statement on Use of Alternative Data for Credit Underwriting

On December 3, 2019, the five federal banking agencies1 issued a joint statement (the “Joint Statement”) regarding the use of alternative data for credit underwriting. The Agencies highlighted potential benefits that may arise from the use of alternative data, including the ability to make faster and more accurate credit … Read More

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16 October 2019

U.S. Financial Regulators Clarify Oversight of AML/CFT Obligations in Connection With Digital Asset Activities

On October 11, 2019, the leaders of the U.S. Commodity Futures Trading Commission (CFTC), the Financial Crimes Enforcement Network (FinCEN) and the U.S. Securities and Exchange Commission (SEC) (together, the Agencies) issued a joint statement highlighting the application of anti-money laundering and countering the financing of terrorism (AML/CFT) obligations under … Read More

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