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 networks supporting Iran’s Islamic Revolutionary Guard Corps (IRGC). The alert arrives at a moment of intensified U.S. economic pressure on the Iranian regime — part
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 reminder of how private litigants create potential liability under the False Claims Act (FCA), even when the government shows little initiative to proceed (or, in
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 the mortgage regulatory framework. The order is the most comprehensive signal to date that the administration intends to revisit core elements of the post-Dodd-Frank compliance
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 Federal Communications Commission’s interpretations of the Telephone Consumer Protection Act (TCPA). Last week, the Fifth Circuit Court of Appeals issued what may be the most
On February 13, 2026, the Financial Crimes Enforcement Network (FinCEN) issued a significant order (FIN-2026-R001) granting exceptive relief to covered financial institutions from the long-standing requirement to identify and verify the beneficial owners of legal entity customers at each new account opening. While this development will be welcomed by many in the financial services industry
Two recent guilty pleas by former TD Bank employees — Oscar Marcel Nunez-Flores and Wilfredo Aquino — are a timely reminder that insider-enabled money laundering can defeat control frameworks if banks do not actively design for, detect, and deter employee misconduct. These cases come on the heels of TD Bank’s October 2024 criminal guilty plea
In Florida’s 2026 legislative session, both chambers will consider bills that would impose strict requirements for caller identification on businesses. The bills target both telecommunications companies and the callers. While the legislation is presumably meant to target telephone scams and robocalls, its broad blocking mandates and authentication requirements would impact any company that places calls
New York has taken a significant step toward reshaping its consumer and market-protection framework with the enactment of the Fostering Affordability and Integrity through Reasonable (FAIR) Business Practices Act. The newly signed law amends Article 22-A of the General Business Law, expanding the scope of conduct prohibited under GBL § 349 and clarifying how
Speaking at the Clearing House’s annual conference, Comptroller of the Currency Jonathan Gould assured industry leaders that the agency remains steadfast in defending federal preemption under the National Bank Act. Gould’s comments come in the wake of recent federal appellate court decisions in the Ninth and First circuits, which challenged the OCC’s stance by finding
In the wild new world of TCPA litigation following the end of binding deference to the Federal Communications Commission (FCC), one of the more salient questions is whether the Do-Not-Call (DNC) Registry’s protections extend to the sending of text messages. Florida finds itself at ground zero for this debate after three different federal district courts