Fourth Quarter Compliance Forum - Southwest

Bank Secrecy Act, Anti-Money Laundering and Counter Financing of Terrorism

• Preparing for 2025 Priorities
  • Financial Crime Trends
  • Exam Priorities
• Recent Enforcement Actions
  • Formal Agreement with Axiom Bank, N.A., Maitland, Florida, for unsafe or unsound practices, including those related to the bank’s BSA/AML compliance program and violations of BSA/AML internal controls and BSA officer.  October 2024
  • C&D and CMP against TD Bank, N.A., Wilmington, Delaware, and TD Bank USA, N.A., Wilmington, Delaware, for deficiencies in the banks’ BSA/AML compliance program. The assessed CMP is $450 million.  October 2024
  • C&D against Clear Fork Bank, N.A., Albany, Texas, for violations of law and unsafe or unsound practices related to the BSA/AML. The bank failed to correct previously reported BSA problems. November 2024
• FinCEN Releases
  • FIN-2024-Alert003, October 23, 2024, FinCEN Alert to Financial Institutions to Counter Financing of Hizballah and its Terrorist Activities
  • FIN-2024-Alert004, November 13, 2024, FinCEN Alert on Fraud Schemes Involving Deepfake Media Targeting Financial Institutions.

Payments Update

• Payment Processing Ecosystem
  • P2P and B2B Systems
  • FinTech Payments and Partnerships
  • FinTech Guidance from Regulators
  • Debit Cards and Credit Cards
  • Wires, ACH, Checks and Other Payments
• Payments Fraud Trends
• CFPB Orders Apple and Goldman Sachs to Pay Over $89 Million for Apple Card Failures (October 2024)

Regulatory Updates

• CFPB Finalizes Rule on Federal Oversight of Popular Digital Payment Apps to Protect Personal Data, Reduce Fraud, and Stop Illegal “Debanking” (11/2024)
• CFPB Report Details Student Borrower Harms from Servicing Failures and Program Disruptions (11/2024)
• CFPB Orders Global Tel Link to Pay $3 Million for Illegally Freezing and Draining Payments Accounts for People Who Are Incarcerated (11/2024)
• CFPB Report Details Carveouts for Financial Institutions in State Data Privacy Laws
• CFPB Orders Navy Federal Credit Union to Pay More Than $95 Million for Illegal Surprise Overdraft Fees (11/2024)
• CFPB Takes Action to Address Townstone Financial’s Unlawful Redlining (11/2024)
• CFPB Orders VyStar Credit Union to Pay $1.5 Million for Illegally Stranding Consumers from Accessing Their Money and Accounts (10/2024)
• CFPB Takes Action to Curb Unchecked Worker Surveillance
• FRB Consumer Compliance Outlook, Third Edition 2024
• CFPB Finalizes Personal Financial Data Rights Rule to Boost Competition, Protect Privacy, and Give Families More Choice in Financial Services (October 2024)
• FDIC extending the compliance date for the new FDIC signage and advertising rule from January 1, 2025, to May 1, 2025 for a portion of the final rule designed to modernize the rules governing use of the official FDIC signs and advertising statements – Part 328, subpart A.
• Regulatory Compliance Threshold Updates for 2025