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James (Jim) Vivenzio counsels financial institutions and other clients on all matters involving examination processes, corporate activities, and regulatory compliance with Bank Secrecy Act/Anti-Money Laundering (BSA/AML), Office of Foreign Assets Control (OFAC), and countering the financing of terrorism (CFT) requirements.

Financial technology firms and certain banks and bank holding companies can expect to face increased scrutiny as the Board of Governors of the Federal Reserve System takes another step to stem risks related to crypto-assets, use of blockchain technology, and complex fintech partnerships with nonbanks to deliver financial services to customers. Through its newly announced Novel Activities Supervision Program (“NAS Program”), the Federal Reserve will be taking a harder look at its supervised banking organizations, even those with less than $10 billion in assets, “to ensure that the risks associated with innovation are appropriately addressed” in four key areas:Continue Reading The Federal Reserve’s Novel Activities Supervision Program: What Banks and Nonbanks Need to Know