FinCEN Proposes Reporting Requirement of International Transport of Prepaid Access Devices

The Financial Crimes Enforcement Network (“FinCEN”) has recently issued a Notice of Proposed Rulemaking (“Proposed Rule”) to add certain tangible prepaid access devices to the list of monetary instruments to be reported when transported into or out of the United States.  Current regulations require that a Currency and Monetary Instrument Report (CMIR) be filed regarding […]


FinCEN Issues Final Rule to Implement Section 104(e) of CISADA

The Financial Crimes Enforcement Network (“FinCEN”) has recently issued a Final Rule (“Final  Rule”) to implement section 104(e) of the Comprehensive Iran Sanctions, Accountability and Divestment Act of 2010 (“CISADA”), imposing certain reporting requirements upon U.S. banks that maintain a correspondent account for a foreign bank.  CISADA prohibits the opening and maintenance of correspondent and […]


Is Your Company Complying with the Equal Employment Opportunity Commission’s Regulations under ADA Amendments Act

ATTENTION EMPLOYERS: Make Sure Your Company Complies with the Equal Employment Opportunity Commission’s Regulations under ADA Amendments Act Employers must be proactive in their efforts to comply with the Amendments Act and the EEOC’s implementing regulations. This spring, the Equal Employment Opportunity Commission published regulations implementing the ADA Amendments Act of 2008 (“Amendments Act”).  The […]


USCIS Initiatives to Promote Startup Enterprises and Spur Job Creation

In congruence with the Obama Administration’s focus on creating high-skilled jobs for U.S. workers and improving the economy, Secretary of Homeland Security Janet Napolitano and U.S. Citizenship and Immigration Services (USCIS) and Director Alejandro Mayorkas have outlined a series of policy, operational, and outreach efforts to fuel the nation’s economy and stimulate investment by attracting […]


The Time is Coming – Mandatory Electronic Filing

The Financial Crimes Enforcement Network (“FinCEN”) has issued a proposal (“Proposal”) to require that FinCEN reports filed under the Bank Secrecy Act (“BSA”) be filed electronically starting on June 30, 2012.  Electronic filing (“E-Filing”) of certain FinCEN reports first became available in 2002.  Since then, FinCEN has been encouraging the use of E-Filing.  Approximately 85% […]


FDIC, FinCEN and OFR Assess Civil Money Penalty Against Ocean Bank

The Federal Deposit Insurance Corporation (“FDIC”), the Financial Crimes Enforcement Network (“FinCEN”) and the State of Florida, Office of Financial Regulation (“OFR”) (collectively, the “Regulators”) announced the assessment of concurrent civil money penalties of $10,900,000 (“Civil Penalty”) against Ocean Bank, Miami, Florida (“Ocean Bank”), for violations of federal and state Bank Secrecy Act (“BSA”) and […]


President Signs Executive Order to Block Property of the Government of Syria and Prohibit Certain Transactions with Respect to Syria

On August 17, 2011, President Obama signed Executive Order 13582, Blocking Property of the Government of Syria and Prohibiting Certain Transactions With Respect to Syria (“Executive Order”). The Executive Order increases sanctions by blocking all property of the Syrian Government that is subject to US jurisdiction.  Firthermore, the Executive Order imposes additional restrictions such as prohibiting: (i) […]


SEC’s New Whistleblower Program Officially Launches

The SEC’s new whistleblower rules and the new Office of the Whistleblower officially launched today. The new rules, mandated by the Dodd-Frank Act, provide that eligible whistleblowers may receive an award for providing information concerning certain fraudulent activity to the SEC. An “eligible whistleblower” is a person who voluntarily provides the SEC with original information […]


Deceptive Mortgage Advertisements Targeted by the FTC

The Federal Trade Commission recently issued a new rule targeting deceptive claims about consumer mortgages in advertising and other types of commercial communications.  Although this rule does not mandate any affirmative disclosures, it does contain potentially onerous recordkeeping requirements. This rule prohibits any person from making “any material misrepresentation, expressly or by implication, in any […]


UPDATE: Richard Cordray to head Consumer Financial Protection Bureau

President Obama announced that former Ohio Attorney General Richard Cordray has been nominated as the Consumer Financial Protection Bureau’s new agency director. Obama and Cordray were joined by consumer advocate Elizabeth Warren, who was responsible for starting the agency and had the support of consumer groups to be named as its leader. Warren was strongly […]


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