Photo of Keith J. Barnett

Keith’s experience representing clients in the financial services industry as a litigation, compliance, regulatory, investigations (internal and regulatory), and enforcement attorney spans 20 years. Keith represents clients against government regulators (CFPB, FTC, SEC, CFTC), industry regulators (FINRA), and private litigants in federal courts, state courts, and before arbitration and administrative law panels in the financial services industry.

On April 7, the Federal Deposit Insurance Corporation (FDIC) released a letter, requiring all FDIC-supervised institutions that intend to engage in, or that are currently engaged in, crypto-related activities to notify its FDIC Regional Director. The FDIC also encouraged institutions to notify their state regulator. The FDIC provided an initial noncomprehensive list of activities

On March 28, Representative Stephen Lynch (D-MA), along with co-sponsors Jesús G. García (D-IL), Rashida Tlaib (D-MI), Ayanna Pressley (D-MA), and Alma Adams (D-NC), introduced H.R. 7231, the Electronic Currency and Secure Hardware Act (ECASH Act), which would direct the secretary of the U.S. Department of the Treasury (not the Federal Reserve) to develop

On March 17, Senators Elizabeth Warren (D-MA), Jack Reed (D-RI), Mark Warner (D-VA), and Jon Tester (D-MT) introduced the Digital Asset Sanctions Compliance Enhancement Act (Act) in an attempt to ensure blacklisted Russian individuals and businesses do not use cryptocurrency to evade economic sanctions.

“In order for the sanctions levied by the United States and

On March 17, the Senate Committee on Banking, Housing and Urban Affairs conducted a hearing titled, “Understanding the Role of Digital Assets in Illicit Finance,” which focused extensively on whether and how Russia could use digital assets to avoid sanctions, as well as how Ukraine is using cryptocurrency to support their fight against Russia.

In

On March 8, the U.S. Federal Reserve Banks launched the FedNow Service Provider Showcase (Showcase) to show financial institutions and users the various services to assist them in implementing the FedNow Service (Service).

The FedNow Service is an instant payment service to provide all depository institutions in the United States with access to instant payment

This article was republished on insideARM on March 28, 2022.

On March 15, the Federal Trade Commission (FTC or Commission) released a consent agreement with Electronic Payment Systems and its owners John Dorsey and Thomas McCann (collectively, EPS) for allegedly opening credit card processing merchant accounts for fictitious companies on behalf of Money Now Funding

On March 11, Britain, Canada, France, Germany, Italy, Japan, and the United States (collectively, the G7) announced more sanctions against Russia, including first-time sanctions specific to virtual assets. The White House also announced that the Department of the Treasury would issue “new guidance [that] will continue to make clear that Treasury’s expansive actions against Russia

The Board of Governors of the Federal Reserve System (the Board) recently issued a supplemental notice and request for comment to the guidelines proposed in May 2021 for use by Federal Reserve Banks (Reserve Banks) in evaluating requests to access Federal Reserve accounts and payment services, in an effort to ensure that Reserve Banks use

On March 9, President Biden signed an Executive Order (the Order) to establish the first comprehensive federal digital asset strategy for the U.S., which would promote digital asset innovation while balancing benefits and associated risks. The order directs the Justice Department, U.S. Department of the Treasury, the Board of Governors of the Federal Reserve System,

On February 21, President Biden issued an executive order blocking property of certain persons, and prohibiting transactions regarding Russia’s invasion of the Ukraine. The following day, the U.S. Treasury’s Office of Foreign Assets Control (OFAC) issued restrictions on activities with Russian individuals and entities. On February 25, these lists were updated to include political leaders