Tag Archives: foreign banks

New U.S. AML Legislation – Five Provisions for Foreign Banks to Watch

On January 1, 2021, the United States Congress enacted the Anti-Money Laundering Act of 2020 (the “AMLA”), as part of the National Defense Authorization Act (the “Act”).  The AMLA includes extensive and fundamental reforms to anti-money laundering (“AML”) laws in the United States, including the Bank Secrecy Act (“BSA”). In a previous client alert, we … Continue Reading

Federal Reserve Eliminates CCAR’s Qualitative Objection for Most Firms

On March 6, 2019, the Federal Reserve issued a final rule to exempt from the qualitative component of the Comprehensive Capital Analysis and Review (“CCAR”) exercise large firms that have participated in CCAR for four consecutive years and have passed the final year’s qualitative component without objection.  The final rule serves to provide an immediate … Continue Reading

Federal Reserve Eliminates SOSA Rating and Proposes New Standards for FBO Daylight Overdraft Capacity

On December 7, 2017, the Federal Reserve announced that it will eliminate the use of the Strength of Support Assessment (or “SOSA” rating) as a supervisory tool.  The SOSA rating measures the extent to which a foreign banking organization (“FBO”) is in a position to provide support to its U.S. branches, agencies, and subsidiary banks, … Continue Reading
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