Insights

Congress Champions Community Bank Regulatory Relief

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Summary Situation Overview: The 21st Century ROAD to Housing Act passed the Senate 85-5 on June 22, 2026, and the House 358-32 the following day. President Trump declined to sign or veto the bill, and it became law without his signature at…

Rogue AI Is More Than a Cybersecurity Story

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Summary Situation Overview: Two major artificial intelligence (AI) labs recently disclosed that agentic AI models had broken out of isolated testing “sandboxes” and onto the open internet. In one case, the agent evaded the lab’s internal…

Banking Regulators Replace Comprehensive Model Risk Management Guidance with Risk-Based Approach

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Summary Situation Overview: On April 17, 2026, the Federal Reserve Board, the Office of the Comptroller of the Currency (OCC), and the Federal Deposit Insurance Corporation (FDIC) jointly issued revised model risk management (MRM) guidance,…

Understanding Regulatory Attention on Private Assets and AI Across Capital Markets and Insurance

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Summary Situation Overview: Private assets and artificial intelligence (AI) are playing an increasingly prominent role across the financial system, including in capital markets and insurance. These developments are unfolding against a backdrop…

Regulatory Key Non-Financial Focus Areas: Financial Crimes, Fintechs, Digital Assets and AI

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Summary Situation Overview: Against the backdrop of deregulation, we expect regulators to continue to focus on financial crimes as well as fintech partnerships, digital assets, and artificial intelligence (AI). What: Firms must keep compliance…

FinCEN Targets Three Mexican Financial Institutions for Fentanyl Trafficking

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Summary: Situation Overview: The U.S. Financial Crimes Enforcement Network (FinCEN) cited recent fentanyl-related legislation to impose a previously unused sixth special measure, prohibiting the transmittal of funds by U.S. persons to three…

Office of the Comptroller of the Currency Orders Blue Ridge Bank to Improve its Third-Party Risk Management

On August 29, Blue Ridge Bank, National Association, disclosed to the U.S. Securities and Exchange Commission a formal agreement with the Office of the Comptroller of the Currency (OCC). The OCC announced the agreement on October 20, detailing…

Crypto Policy Consensus On Capitol Hill Elusive in 2022, But Regulator Action Looms

Even though there’s no policy consensus for cryptocurrency regulation as 2022 kicks off, the cryptocurrency community’s engagement with policymakers in 2021 had a positive effect in Washington.

Digital Currencies’ Role in Facilitating Ransomware Attacks: A Brief Explainer

Patomak’s Kristine Johnson co-authored a paper for Third Way that details how Bitcoin—the most popular digital currency—is used to facilitate ransomware attacks and how criminals try—and sometimes fail—to cover their tracks. Understanding how criminals use digital currencies for ransomware attacks can lead policymakers to solutions in thwarting and enforcing cybercrimes.