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Christian Larson Commentary by Christian Larson

The Financial Action Task Force ("FATF") urged jurisdictions to take coordinated actions to prevent the misuse of virtual assets for crime and terrorism. The FATF also updated the FATF Recommendations to define "virtual assets" and "virtual asset service providers," and to require countries to regulate virtual asset service providers to combat money laundering and the financing of terrorism. The FATF noted that its standards require regulation only for purposes of anti-money laundering and countering the financing of terrorism ("AML/CFT"), and emphasized that the FATF Recommendations "do not

A national bank agreed to pay $65 million to settle charges for misleading investors by failing to disclose sales misconduct, which affected its reported "cross-sell" ( i.e., selling products/services to existing customers) metrics. According to the settlement agreement, Wells Fargo & Company ("Wells Fargo") failed to disclose to investors that the success of its "cross-sell" business model was built on sales misconduct at the bank. The Office of the Attorney General of New York alleged that employees in Wells Fargo's community bank (i) opened 3.5 million possibly fraudulent deposit, credit

Commentary by Conor Almquist

The Federal Trade Commission ("FTC") outlined its enforcement, education and research efforts to protect older consumers from fraud, identity theft, and other financial abuse. In a new report submitted to Congress, the FTC identified various types of financial elder abuse including business imposter scams, sweepstakes, lottery scams, family or friend imposter scams, and prizes. The FTC described key enforcement actions it has taken to protect older Americans. In addition, the agency detailed its outreach and education efforts and highlighted the Every Community Initiative and the Pass It On

The Loan Syndications and Trading Association ("LSTA") updated its guidance for customer identification procedures applicable to syndicated lending facilities to reflect FinCEN's Beneficial Ownership Rule. As previously covered, the Beneficial Ownership Rule went into effect on May 11, 2018, and requires "covered financial institutions" to obtain information on the beneficial owners of a legal entity that opens a new account for each new formal banking relationship established, even if the legal entity is an existing customer. LSTA's updated guidance clarifies that primary lenders "would not