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A seasoned regulatory and compliance attorney, Carlin brings extensive experience representing financial institutions, fintechs, lenders, payment processors, neobanks, virtual currency companies, and mortgage servicers.

On February 23, The Board of Governors of the Federal Reserve System (the Board), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, the Agencies) issued a statement on the liquidity risks presented by funding provided to banks related to certain crypto activities and offering some effective

In the second segment of our four-part Crypto Year in Review series, Rene McNulty, Carlin McCrory, and Ethan Ostroff discuss the Federal Reserve and its research and experimentation on Central Bank Digital Currencies (CBDCs), examining the steps that the Fed took toward potential CBDC implementation. Our panelists also review recent crypto-related regulatory developments at the FDIC and OCC, discussing what these actions can tell us about regulatory trends and priorities.

In a letter dated February 10, the American Bankers Association (ABA), Consumer Bankers Association (CBA), Credit Union National Association (CUNA), National Association of Federally‐Insured Credit Unions (NAFCU), and The Clearing House (TCH) (collectively, the Associations) vigorously requested that the Federal Reserve Board (Fed) extend the effective date for the final rule amending Regulation II (Final

In the first of a four-part Crypto Year in Review series, Carlin McCrory, Keith Barnett, and Ethan Ostroff look at how the CFPB and FTC viewed and regulated cryptocurrency in 2022. The panel examines statements by CFPB Director Rohit Chopra and recent CFPB and FTC enforcement actions, identifying likely regulatory trends for 2023 and beyond.

In this episode of The Crypto Exchange, Troutman Pepper attorney Carlin McCrory welcomes Disputes, Compliance and Investigations Managing Director Terri Sands from Stout to discuss the risks and regulatory scrutiny that financial institutions and fintechs face as to fraud and the Bank Secrecy Act (BSA). In her position, Terri serves as a leader in the payments, BSA/AML, and OFAC/Sanctions and fraud and risk management areas.

On January 3, The Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (the Agencies) issued a joint statement to banking organizations highlighting a number of risks associated with crypto-assets.

While the Agencies expressly state that “banking organizations are neither prohibited nor

On December 14, Senators Elizabeth Warren (D-Mass.) and Roger Marshall (R-Kan.) introduced the Digital Asset Anti-Money Laundering Act of 2022 (the Act) that would extend anti-money laundering and countering of the financing of terrorism requirements to cryptocurrency and digital assets. The bill follows warnings from the Treasury Department, Department of Justice, and national security and

The Consumer Financial Protection Bureau (CFPB) issued a decision denying Nexo Financial, LLC’s petition to modify a civil investigation demand (CID) originally served on the company on December 1, 2021. At that time, Nexo Financial and its affiliates advertised a range of products, including interest-accruing accounts and lines of credit. In its petition, Nexo Financial

On November 30, Senate Banking Committee Chairman Sherrod Brown (D-OH) sent a letter to Treasury Secretary Janet Yellen requesting that she coordinate with other financial regulators to further work on the recommendations from the Financial Stability Oversight Council Report on Digital Asset Financial Stability Risks and Regulation (FSOC report), which we previously discussed here.

On November 28, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a $362,158.70 settlement with Payward, Inc. d/b/a Kraken. The Delaware-incorporated virtual currency exchange allegedly processed 826 transactions amounting to approximately $1.7 million on behalf of individuals located in Iran. In addition to the fine, Kraken also has agreed to