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Publications
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02.29.2024CFPB Issues Proposed Open Banking RuleArticlesThe Consumer Financial Protection Bureau announced that it was issuing a Notice of Proposed Rulemaking regarding Personal Financial Data Rights on October 19, 2023. The proposed rule would implement section 1033 of the Consumer Financial Protection Act of 2010, which gives consumers the right to access their financial data and authorizes third parties to access it on their behalf.
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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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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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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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05.26.2022US Treasury Highlights Anti-Money Laundering Priorities in 2022 Illicit Finance StrategyUpdatesThe U.S. Department of the Treasury, on May 13, 2022, published its 2022 National Illicit Finance Strategy—a comprehensive statement of the agency’s key priorities, goals, and plans for safeguarding the U.S. financial system against illicit activity in order to “strengthen national security and prosperity.”
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10.19.2021OFAC Releases New Detailed Guidance for the Digital Currency IndustryUpdatesOn October 15, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control released guidance on sanctions compliance for the digital currency industry, the agency’s most detailed guidance to date on its expectations for participants in this rapidly growing industry.
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01.31.2017Ninth Circuit Refines Antitrust Standing Doctrine Under Illinois BrickUpdatesThe U.S. Court of Appeals for the Ninth Circuit recently addressed again when plaintiffs have standing to pursue federal antitrust claims under the U.S. Supreme Court’s landmark decision in Illinois Brick Co. v. Illinois.
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08.31.2016FTC Complaint Counsels Caution When Settling Disputes With CompetitorsUpdatesThe Federal Trade Commission recently sued 1-800 Contacts, Inc., the largest contact lens retailer in the United States, charging it with restraining competition in violation of Section 5 of the Federal Trade Commission Act, 15 U.S.C. § 45.
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10.07.2014Third Quarter 2014: States Expanding Data Breach Notification RequirementsUpdatesCalifornia, Florida, Kentucky, and Iowa have changed their security breach notification requirements in the past few months.
