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Publications
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04.08.2024Get Ready for the New York LLC Transparency ActUpdatesOn March 1, 2024, New York Governor Kathy Hochul signed an amended version of the New York LLC Transparency Act, which was originally signed with provisions for amendments in December 2023. The NYLTA will go into effect on January 1, 2026, and it will impose certain beneficial ownership disclosure requirements for limited liability companies formed or authorized to do business in New York.
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01.19.2024Banks Should Brace for Virtual Currency Reporting Plan’s ImpactArticlesJim Vivenzio and Steven Merriman authored an article for Bloomberg Law titled "Banks Should Brace for Virtual Currency Reporting Plan’s Impact," detailing how a federal proposal for virtual currency reporting expands blockchain definitions and could disrupt financial institutions.
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01.04.2024CTA Compliance Tip: Spouses and Domestic Partners in Community Property States May Also Be “Beneficial Owners”UpdatesAs discussed in our prior Update on the Corporate Transparency Act, anyone who owns or controls at least 25% of the ownership interests of a CTA reporting company must report their beneficial ownership to the Financial Crimes Enforcement Network.
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12.19.2023Corporate Transparency Act Will Require Disclosure of Senior Officers and Directors of Many US and Foreign CompaniesUpdatesThis Update discusses how the Corporate Transparency Act rules will affect directors and senior officers of CTA reporting companies, in particular. All senior officers, directors and their advisers, and counsel should be aware of these rules and potential implications.
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12.11.2023Think Public and Large Companies Are Entirely Exempt From the Corporate Transparency Act? Think Again.UpdatesKey portions of the Corporate Transparency Act will take effect on January 1, 2024, requiring an estimated 30 million “reporting companies” to disclose to the federal government information and documentation about the entity’s beneficial owners and keep that information current.
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12.04.2023The Corporate Transparency Act: What To Know and Expect Starting January 1, 2024UpdatesBeginning January 1, 2024, the Corporate Transparency Act will require most entities formed or registered to do business in the United States to disclose detailed information regarding their owners, officers, and control persons to the U.S. Department of the Treasury Financial Crimes Enforcement Network.
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11.07.2023
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08.29.2023FFIEC BSA/AML Exam Manual Updates—Implications for BanksUpdatesThe Federal Financial Institutions Examination Council released the fifth phase of updates to the FFIEC Bank Secrecy Act/Anti-Money Laundering Examination Manual on August 2, 2023.
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08.16.2023A New National Security Frontier: Executive Order and Coming Regulations Restricting US Technology Investments in ChinaUpdatesPresident Biden issued a long-awaited executive order, “Addressing United States Investments in Certain National Security Technologies and Products in Countries of Concern” (the Executive Order or E.O.) on August 9, 2023, highlighting the risks these technologies and products pose to U.S. national security and marking the latest round in the ever-increasing competition between the United States and China.
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06.06.2023Final Interagency Third-Party Risk Management Guidance Issued on June 6, 2023: Implications for Banks and FinTech CompaniesArticles
Perkins Coie LLP
There is an adage among regulators, “same risks, same rules” or “leveling up,” and on June 6 the Office of the Comptroller of the Currency (OCC), Board of Governors of the Federal Reserve System (FRB), and Federal Deposit Insurance Corporation (FDIC) (together, the “Agencies”) issued final interagency guidance on managing the risks associated with third-party relationships (Final Guidance). -
03.29.2023Practical Tips For Managing Bank D&O Liability RiskArticles
Law360
As with past banking crises, the recent failures of Silicon Valley Bank and Signature Bank will likely put the directors and officers of affected banking institutions in the proverbial crosshairs as regulators second-guess their decisions and look for potential sources of loss recovery. -
03.12.2023Distressed Bank Update as of March 12, 2023UpdatesAt 6:15 p.m. ET on March 12, 2023, the Department of the Treasury, Federal Reserve, and FDIC announced “actions enabling the FDIC to complete its resolution of Silicon Valley Bank, Santa Clara, California, in a manner that fully protects all depositors. Depositors will have access to all of their money starting Monday, March 13” (emphasis added).
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03.11.2023Silicon Valley Bank Update as of March 11, 2023UpdatesAn overview of the failure of Silicon Valley Bank (SVB) and what we expect to happen next. This reflects information as of 4:00 p.m. PT on March 11, 2023. We note that it is an evolving situation; we will provide updates as warranted in the coming days. Please contact your Perkins Coie lawyer or email SVBSupport@perkinscoie.com with questions or for assistance.
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03.07.2023DOJ Announces Shift Toward Corporate Enforcement for Sanctions and Export Control ViolationsUpdatesDeputy Attorney General Lisa Monaco delivered groundbreaking remarks at the American Bar Association National Institute on White Collar on March 2, 2023, heralding a new era of corporate enforcement aimed at addressing U.S. national security priorities.
Presentations
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05.16.2024
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02.28.2024Preventing and Combatting Illicit TradeSpeaking Engagements
Panelist
11th Annual U.S. – Mexico Security Conference / Washington, D.C. -
10.11.2023Strengthening Compliance: US Government's Tri-Seal Guidance and DOJ Call for Sanctions Evasion VigilanceSpeaking EngagementsKharon / Virtual
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04.27.2023The Way of the Future: Forging and Maintaining Relationships With TradFiSpeaking EngagementsConsensus / Austin, TX
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03.29.2023Regulatory Enforcement and Litigation: The Contagion Effect of FTX and Silicon Valley BankWebinarsThe webinar examined recent events, beginning with the Terraform Labs cryptocurrency collapse and continuing to the downfall of various entities, including FTX Trading Ltd. and Silicon Valley Bank. Our panel of experts addressed key legal and regulatory issues relating to these events.
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03.21.2023Beyond Bank Failures: Rethinking the Role of Traditional Banks in the Crypto AgeSpeaking EngagementsDC Blockchain Summit / Washington, D.C.
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02.23.2023AML Conversations: Enforcement Over the YearsSpeaking EngagementsAML RightSource / PodcastA timely discussion with a key industry thought leader reflecting on my 32-year OCC career, with a focus on the evolution of Bank Secrecy Act enforcement, fraud and technology over that time period.
