Insights

Combatting AI-Enabled Fraud – A Top Financial Crime Threat

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Summary Situation Overview: In January 2026, the Association of Certified Anti-Money Laundering Specialists (ACAMS) published its 2026 Global Anti-Financial Crime Threats Report (ACAMS Report). The ACAMS Report identified artificial intelligence…

Prediction Market Surveillance: CFTC Advisory and SRO Enforcement Action

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Summary Situation Overview: Kalshi announced that it pursued enforcement actions against two participants for alleged manipulative trading activity. The CFTC also issued a related Prediction Markets Advisory reaffirming its oversight authority…

OCC GENIUS Proposal: Three Policy Issues to Watch

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Summary Situation Overview: The Office of the Comptroller of the Currency (OCC) issued a notice of proposed rulemaking (NPR) to implement the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act). The NPR addresses…

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…

Understanding the New De-Banking Executive Order

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Summary: Situation Overview: On August 7, 2025, President Trump issued an Executive Order (the “Order”) entitled “Guaranteeing Fair Banking for All Americans”, which has implications for retail and institutional fair lending practices. What:…

The Future of U.S. Crypto Regulation: Analyzing the CLARITY Act and the RFIA

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Summary: Context: The U.S. Congress is actively developing a robust regulatory framework to govern digital assets, aiming to provide clarity and stability to the rapidly evolving industry. What: The House of Representatives passed the CLARITY…
Office of the Comptroller of the Currency

OCC Acting Comptroller Discusses “Too Big to Manage” Banks, Four-Step Escalation Framework

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Acting Comptroller of the Currency Michael Hsu presents a framework for scrutinizing banks viewed as “too big to manage.” Hsu describes a four-step escalation framework for supervisory issues, with a “credible threat of restrictions…
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By: Chris Beckmann, Bryan Hubbard, Keith Noreika
Office of the Comptroller of the Currency

Banking Regulators Send Strong Warning About Crypto Risks

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Federal banking agencies encourage banks to monitor crypto risks, stress importance of keeping crypto sector risks isolated from broader financial system. Regulators view open, public or decentralized networks as highly likely to be inconsistent…
Office of the Comptroller of the Currency

Regulators Warn on Interest Rate Risks, Banks Should Prepare for Scrutiny

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Rising interest rates are adversely affecting bank investment portfolios, leaving banks with a difficult set of choices. Regulators increasingly are expressing concern with the effect of interest rate risk. Banks must ensure their…
Office of the Comptroller of the Currency

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…
Office of the Comptroller of the Currency

Mortgage Risk Redux in This (or the Next) Recession

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While a recession is a mere technicality, inflation and other adverse economic factors are already working to make the risks in the mortgage industry that have accumulated over a 13-year expansion more likely to become reality. How nearly $12…