Articles

NCUA and Third-Party Risk Management

Regulatory Status The National Credit Union Administration (NCUA) is seeking regulatory oversight authority related to third-party vendors who present additional cyber risks to the industry. In March 2022, the NCUA published a paper entitled, Third-Party Vendor Authority, in which it puts forth its case that without the statutory...

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BSA Reporting: Significance to Law Enforcement

In terms of the Bank Secrecy Act (BSA), Financial Institutions (FIs) regularly file Suspicious Activity Reports (SARs) and Currency Transaction Reports (CTRs) with FinCEN[1] as well as provide information under the 314(a) requests received through FinCEN. The FIs also share crucial information amongst themselves under the safe harbor...

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Regulatory Hot Topics – February 2020

I. LIBOR Sunset and SOFR Transition                                                          In 2014, the Federal Reserve asked the Alternative Reference Rates Committee (ARRC) to identify...

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OFAC Compliance

OFAC Compliance - what everyone needs to know! While financial institutions are aware of Office of Foreign Assets Control (OFAC) compliance requirements and have mitigating controls in place, it is not unusual to see penalties for OFAC violations imposed on financial institutions. Moreover, since OFAC compliance has much...

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