On May 19, 2026, President Trump issued an executive order titled “Restoring Integrity to America’s Financial System,” directing federal financial regulators to review and strengthe...
The OCC, Federal Reserve, and FDIC released updated guidance on model risk management, which rescinds and supersedes prior guidance to establish a more principles-based approach. Our visu...
OFAC’s recent “Guidance on Sham Transactions and Sanctions Evasion” suggests heightened due diligence obligations and erodes the “bright line” distinction between ownership and ...
FinCEN and OFAC have taken steps to implement the AML/CFT and sanctions compliance obligations under the GENIUS Act, the most notable of which include compliance requirements applicable t...
Davis Polk counsel Kendall Howell authored “Deploying agentic AI in BSA and sanctions compliance” in ABA Risk and Compliance. In the article, Kendall explores how banks and financial ...
FinCEN and the federal banking agencies released proposed AML/CFT program rules that largely reorganize the compliance requirements that were initially proposed in 2024 and introduce a ne...
This visual memorandum provides a summary and overview of the Department of the Treasury’s proposed rules that would update requirements for anti-money laundering and countering the fin...
FinCEN’s proposed rule would offer significant financial incentives to individuals who report corporate violations of anti-money laundering, sanctions and national security laws across ...
FinCEN announced that it will not enforce reporting requirements under its residential real estate rule following the U.S. District Court for the Eastern District of Texas’s decision to...
Davis Polk AML/CFT head Dan Stipano and counsel Kendall Howell authored “Practical AI governance for community and midsize banks” in ABA Risk and Compliance. In the article, they prov...
