Financial Services Spotlight

March 2016 Second Half Developments

Posted by Roy Andersen on Apr 6, 2016 12:00:00 PM

Overview

The Fed published a proposed rule that would establish a credit limit for doing business with other large institutions.  In effect, this is a super lending limit for large banks.  It applies at a fairly low level of $50 billion in assets. This is a Dodd-Frank requirement and perhaps part of the rush of the Obama administration to put as many rules as possible over the finish line before a potential change of political will.  The former Federal Bank of the Middle East now known as FBME continues its fight against death sentence effect of the US government determining that a bank is of “primary money laundering concern.” The effect of such a determination can be seen in the Credexbank FinCEN notice whereby the bank was put out of business.   FBME is fighting against this determination and is at least having an independent party determine whether it is indeed engaged in money laundering activities such that it should be put out of business.

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Topics: OFAC, North Korea, Cuba, European Union, CFTC, ESMA, EMIR

About the Spotlight


The Financial Services Spotlight examines the regulatory and technology developments impacting banks, asset managers and other financial services providers—where challenges meet opportunities.

 

Meet the Authors


Roy C. Andersen, of counsel in Sullivan & Worcester's New York office, is a member of the Corporate Department. Mr. Andersen focuses on bank regulatory and compliance matters, including international banks and their branches and agencies in New York.

Joel Telpner, partner in the firm's New York office, is a seasoned advisor, strategist and problem solver. Mr. Telpner brings more than 30 years of legal experience in a career that includes time as an AmLaw 100 partner, the former U.S. general counsel of a global financial institution, and a venture capitalist. He is recognized for his ability to deftly manage complex financial transactions, especially those involving sophisticated structured finance and derivatives matters and has an extensive and unique combination of transactional and regulatory experience.

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