On July 14, 2026, a split 9th U.S. Circuit Court of Appeals panel affirmed a preliminary injunction barring enforcement of the Financial Crime Enforcement Network’s (FinCEN) border geographic targeting order…
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Brazilian Gang Terrorist Designations: What U.S. Financial Institutions Need to Know About the CV and PCC
On May 28, 2026, Secretary of State Marco Rubio announced that the U.S. Department of State designated Comando Vermelho (CV) and Primeiro Comando da Capital (PCC), Brazil’s two largest and…
The OCC’s Recent Consent Order Is a Warning for Community Banks in the Fintech Partnership Space
On May 21, 2026, the Office of the Comptroller of the Currency (OCC) made public an April 2026 consent order (AA-ENF-2025-21) against a federal savings association based in the Northeast…
FinCEN’s IRGC Alert: What Financial Institutions Need to Know About Iran’s Oil Smuggling and Shadow Banking Networks
On May 11, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an alert designed to help financial institutions identify and disrupt funding streams and procurement…
On April 13, 2026, Maine enacted new laws (L.D. 1901) that are intended to have an immediate and retroactive impact on the origination and servicing of shared appreciation…
The Ninth Circuit case United States ex rel. Thrower v. Academy Mortgage Corp. provides mortgage lenders, servicers, and other entities submitting claims for payment to the federal government an important…
Regulation B Rulemaking Finalized: CFPB Issues Final Rule Amending ECOA Provisions on Disparate Impact, Discouragement, and Special Purpose Credit Programs
On April 22, 2026, the Consumer Financial Protection Bureau (CFPB) issued a final rule amending Regulation B – the implementing regulation of the Equal Credit Opportunity Act (ECOA). Building on…
The Post-Dodd-Frank Rollback Begins? New Executive Order Targets Mortgage Origination, Servicing, and Reporting Rules
On March 13, 2026, President Trump signed an executive order titled “Promoting Access to Mortgage Credit,” directing federal financial regulators to consider a broad set of revisions to…
Following the Supreme Court’s decision in McLaughlin Chiropractic Associates v. McKesson Corp., which we discussed last year in depth, federal courts have gained the ability to deviate from the…
This past year, the False Claims Act (FCA) continued to be a key tool for the Justice Department and whistleblowers to bring suits against companies, including those in the financial…






