The corrective measures that the bank is required to take as to its AML program are set out by the OCC with a good degree of specificity.  Accordingly, it would be prudent for any bank's AML Compliance Officer to review this enforcement action and consider how its AML program matches up with the description in the action.

Generally, the federal agencies responded to President Biden's Executive Order as expected (see previous ). On risk management, the agencies proposed to engage in massive rule making, and for innovation, massive hiring.

If the outcome is an AI rule-writing campaign, the question is whether it can do so without stifling progress, inhibiting free speech, and writing rules that are either wholly ambiguous or impossible to meet. To the extent that the regulators follow up on their…

Not surprisingly, scientists at the GAO recognize the benefits that AI is able to provide. Moreover, it does not appear that they are establishing impossible standards to meet in the use of AI.

Firms will need to figure out how deal with the delivery and funding issues caused by cross-border timing differences. Non-U.S. firms trading U.S. securities need to give careful consideration to the timing mismatches between the requirements of payments for, and deliveries of, U.S. securities; particularly as to both (i) the requirements of securities in many other jurisdictions and (ii) the fact that currency transactions generally do not settle until T+2.