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03/31/2025

FDIC clarifies process for banks to engage in crypto-related activities

The FDIC has issued FIL-7-2025 announcing its rescission of FIL-16-2022 titled Notification of Engaging in Crypto-Related Activities, which established a prior notification requirement for FDIC-supervised institutions that wish to engage in crypto-related activities, and providing new guidance to clarify that FDIC-supervised institutions may engage in permissible crypto-related activities without receiving prior FDIC approval.

Crypto-related activities include, but are not limited to, acting as crypto-asset custodians; maintaining stablecoin reserves; issuing crypto and other digital assets; acting as market makers or exchange or redemption agents; participating in blockchain- and distributed ledger-based settlement or payment systems, including performing node functions; as well as related activities such as finder activities and lending.

FIL-7-2025 affirms that FDIC-supervised institutions may engage in permissible activities, including activities involving new and emerging technologies such as crypto-assets and digital assets, provided that they adequately manage the associated risks. The FDIC expects that FDIC-supervised institutions conduct all activities in a safe and sound manner and consistent with all applicable laws and regulations.

The FDIC will continue to engage with the President’s Working Group on Digital Asset Markets and expects to issue further guidance in the future to provide additional clarity regarding banks’ engagement in particular crypto-related activities.

The FDIC will also work with the other banking agencies to replace interagency documents issued in January 2023 and February 2023 related to crypto-assets with further guidance or regulations.

03/31/2025

Hizballah finance team sanctions evasion network targeted

On Friday, the Treasury Department reported that OFAC had designated five individuals and three associated companies involved in a Lebanon-based sanctions evasion network supporting the Hizballah finance team.

For a link to identification information on the designated parties, see Friday's BankersOnline OFAC Update.

03/31/2025

Senate votes to overturn CFPB overdraft fee rule

Politico has reported that the U.S. Senate has voted to overturn the CFPB's "Overdraft Lending: Very Large Financial Institutions" final rule, which is scheduled to become effective October 1, 2025. The Senate resolution under the Congressional Review Act now goes to the House of Representatives, where a companion bill was approved by the Financial Services Committee earlier this month. If the Senate action is approved by the House and signed into law by the president, the CFPB's rule will be nullified, and the Bureau cannot issue any substantially similar proposals.

03/27/2025

FSB establishes forum on cross-border payments data

The Financial Stability Board (FSB) has announced the establishment of a Forum on Cross-Border Payments Data. This initiative is a key outcome from the FSB’s Recommendations for data frameworks related to cross-border payments that were published in December 2024, and forms part of the FSB’s increasing emphasis on promoting implementation of its policy recommendations.

The FSB said that "differences in laws, regulations, and practices between countries can create unnecessary frictions in cross-border payments, increasing costs and risks for businesses and individuals. By bringing together experts in payments, anti-money laundering and countering terrorist financing, sanctions, and data privacy and protection, the Forum will work to strengthen cooperation on data-related issues in cross-border payments, such as the way data is collected, stored and managed across borders."

The forum will serve as a platform for dialogue, information exchange, and research, helping to identify and address inconsistencies in global data frameworks. An advisory body comprised of private sector representatives will also be created to provide industry perspectives and expertise to the forum.

03/26/2025

Three Iranian officials sanctioned in Robert Levinson case

The Treasury Department reported that OFAC, in coordination with the FBI, has imposed sanctions on three Iranian Ministry of Intelligence and Security officials who were involved in the abduction, detention, and probable death of former FBI Special Agent Robert A. “Bob” Levinson. The individuals designated today, Reza Amiri Moghadam, Gholamhossein Mohammadnia, and Taqi Daneshvar, all played a role in Mr. Levinson’s abduction, probable death, and Iran’s efforts to cover up or obfuscate their responsibility.

Yesterday’s action was taken under Executive Order 14078, which implements the Robert Levinson Hostage Recovery and Hostage-Taking Accountability Act, and holds to account terrorist organizations, criminal groups, and other malicious actors who take hostages for financial, political, or other gain—as well as foreign states that engage in the practice of wrongful detention, including for political leverage or to seek concessions from the United States.

For a link to identification information on the three designated individuals, see yesterday's BankersOnline OFAC Update.

03/26/2025

Executive Order would end federal payments by check

President Trump has issued an Executive Order, "Modernizing Payments To and From America’s Bank Account," calling for a review and update of federal government disbursements practices to phase out, to the extent possible, disbursements by paper check, including tax refunds, vendor payments, benefit payments and intergovernmental transfers.

The Order also encourages payments to the federal government to be made electronically.

  • White House Fact Sheet
  • Link to and title of Executive Order updated.

03/25/2025

FinCEN issues FAQ on SW border GTO

FinCEN has posted a series of 19 Frequently Asked Questions on its March 11, 2025, Geographic Targeting Order Involving Certain Money Services Businesses in California and Texas on the Southwest Border.

Editor's Note: The FAQs are numbered from 1 to 21, but numbers 16 and 19 are omitted.

03/24/2025

SSA resumes Treasury Offset Program for pre-COVID debts

The Social Security Administration (SSA) has announced the immediate resumption of debt collection activities through the Treasury Offset Program (TOP) for debts accrued prior to March 2020. This decision comes after a suspension of collections due to the economic challenges posed by the COVID-19 pandemic.

The Treasury Offset Program, administered by the Department of the Treasury’s Bureau of Fiscal Service, is a centralized program designed to collect delinquent debts owed to federal and state agencies by intercepting Federal and state payments. Since 1992, SSA has referred delinquent Old-Age, Survivors, and Disability Insurance (OASDI) and Supplemental Security Income (SSI) debts to TOP as mandated by law.

SSA said that prior to the suspension in March 2020, SSA had successfully collected almost $2 billion in previously unrecoverable delinquent debt through TOP. The program is essential for maintaining the integrity of the OASDI and SSI programs.

03/24/2025

FinCEN guts BOI Reporting requirements in interim final rule

On Friday, March 21, FinCEN issued an interim final rule that removes the requirement for U.S. companies and U.S. persons to report beneficial ownership information (BOI) to FinCEN under the Corporate Transparency Act.

In the interim final rule, FinCEN revises the definition of “reporting company” in its implementing regulations to mean only those entities that are formed under the law of a foreign country and that have registered to do business in any U.S. State or Tribal jurisdiction by the filing of a document with a secretary of state or similar office (formerly known as “foreign reporting companies”). FinCEN also exempts entities previously known as “domestic reporting companies” from BOI reporting requirements.

Thus, through this interim final rule, all entities created in the United States — including those previously known as “domestic reporting companies” — and their beneficial owners will be exempt from the requirement to report BOI to FinCEN. Foreign entities that meet the new definition of a “reporting company” and do not qualify for an exemption from the reporting requirements must report their BOI to FinCEN under new deadlines, detailed below. These foreign entities, however, will not be required to report any U.S. persons as beneficial owners, and U.S. persons will not be required to report BOI with respect to any such entity for which they are a beneficial owner.

Upon the publication of the interim final rule, the following deadlines apply for foreign entities that are reporting companies:

  • Reporting companies registered to do business in the United States before the date of publication of the IFR must file BOI reports no later than 30 days from that date.
  • Reporting companies registered to do business in the United States on or after the date of publication of the IFR have 30 calendar days to file an initial BOI report after receiving notice that their registration is effective.

    FinCEN is accepting comments on this interim final rule and intends to finalize the rule this year. The interim final rule becomes effective when it is published in the Federal Register. Comments on the interim final rule will be accepted for 60 days following that publication.

    Publication, effective date, and comment period update: Published at 90 FR 13688 on 3/26/2025. Effective upon publication. Comments on the interim final rule will be accepted through 5/27/2025 (62 days, due to the Memorial Day holiday on 5/26/2025).

    The amendments have been made to the Regulations page for 31 C.F.R. § 1010.380.

  • 03/21/2025

    Treasury sanctions network supporting Iran's oil exports

    The Treasury Department has reported that OFAC has designated a “teapot” oil refinery and its chief executive officer for purchasing and refining hundreds of millions of dollars’ worth of Iranian crude oil, including from vessels linked to the Foreign Terrorist Organization, Ansarallah, commonly known as the Houthis, and the Iranian Ministry of Defense of Armed Forces Logistics (MODAFL).

    OFAC also sanctioned 19 entities and vessels responsible for shipping millions of barrels of Iranian oil, comprising part of Iran’s “shadow fleet” of tankers supplying teapot refineries like Luqing Petrochemical. The State Department also designated an entity for having knowingly engaged in a significant transaction for the purchase, acquisition, sale, transport, or marketing of petroleum or petroleum products from Iran.

    For a link to the list of designations under these actions, see yesterday's BankersOnline OFAC Update.

    EDITORIAL NOTE: The OFAC Notice referred to in our OFAC Update also indicates that OFAC published its final rule extending certain recordkeeping requirements to ten years. OFAC published an interim final rule with that requirement on September 13, 2024, with an effective date of March 12, 2025.

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