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California Governor Vetoes Proposed Law Imposing Stronger Data Protection Requirements

Posted by Charlene Brownlee

California Governor Arnold Schwarzenegger vetoed AB 779 — legislation that would have amended California’s data security breach legislation to impose stronger data protection requirements than the Payment Card Industry Data Security Standard

AB 779 would have prohibited businesses that sell goods or services to any resident …

Bank Regulatory Agencies Release Updated BSA/AML Examination Manual

Posted by Peter Mucklestone

The Federal Financial Institutions Examination Council (FFIEC) recently released an updated 2007 version of the Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual, which updates and further clarifies supervisory expectations since the 2006 version was published last year. The Manual is used in connection with examinations of supervised …

OFAC Publishes Guidance for Banks

Posted by Peter Mucklestone

The Office of Foreign Assets Control (OFAC) recently published a brochure titled "Foreign Assets Control Regulations for the Financial Community" dated June 15, 2007, to help banks comply with the statutes and regulations that OFAC administers.

OFAC administers laws and regulations, including the Trading With the …

SAR Forms Revised

Posted by Peter Mucklestone

The Financial Crimes Enforcement Network (FinCEN) has revised the forms of Suspicious Activity Report (SAR). Certain financial companies are required to file SARs with the Treasury Department to report suspicious activity relevant to possible violations of law or regulations. The new forms should not be used before June …

Customer Identification Responsibilities for Agency Lending Transactions

Posted by Peter Mucklestone and Stuart Louie

On April 25, 2006, the Department of the Treasury, Financial Crimes Enforcement Network issued a guidance statement in respect of Customer Identification Program (“CIP”) responsibilities arising out of transactions where U.S. banks or broker-dealers (“Agent Lenders”) arrange loans of securities to broker-dealers (“Borrowers”) …

2006 – The Year Of Communication

Posted by Peter Mucklestone

The Fifth National Conference on Ensuring Privacy and Security of Consumer Information, sponsored by the American Conference Institute, began Thursday morning at the Marriott East Side Hotel in New York. The conference is billed by its sponsor as the leading legal and regulatory forum for privacy …

Federal Bank and Thrift Regulatory Agencies Publish Guide to Help Financial Institutions Comply with Information Security Guidelines

Posted by Peter Mucklestone and Stuart Louie

The federal bank and thrift regulatory agencies recently announced the publication of a compliance guide for the Interagency Guidelines Establishing Information Security Standards (the “Security Guidelines”). The Security Guidelines (i) implement section 501(b) of the Gramm-Leach-Bliley Act (GLB Act) and section 216 of …

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