Pub. 9 2021 Issue 4

In October, the Office of Foreign Assets Control (OFAC) published more targeted guidance for digital asset companies related to compliance with sanctions and best practices for mitigating risks. OFAC’s virtual currency guidance is directed at the entire industry, including “technology companies, exchangers, administrators, miners, wallet providers, and users.” It aims to “help the virtual currency industry prevent exploitation by sanctioned persons and other illicit actors,” according to the press release issued with the guidance. Essentially, the guidance emphasizes that anyone subject to U.S. sanctions laws and regulations must continue to abide by them when engaging with virtual currencies.

Zions Bank President and CEO Scott Anderson was elected chair of the American Bankers Association for the 2021-2022 association year. The election took place on October 19 during ABA’s annual convention in Tampa, FL.

It’s the message a CEO never wants to receive: “We’ve got your data and you need to pay up if you want it back.”

Unfortunately, that message is landing in CEO inboxes increasingly often, as ransomware attacks ramp up in the U.S. In just the first six months of 2021, the Financial Crimes Enforcement Network identified $590 million in ransomware-related Suspicious Activity Reports — a 42% increase from the 2020 total of $416 million. And FinCEN reports that we could be on track to see a higher transaction value for ransomware-related SARs than we’ve seen in the past 10 years combined.

From this point forward, bankers can’t look at the political process the same. Everything changed the moment the President of the United States of America nominated Saule Omarova to be the top banking regulator. This is a person who is vocal about wanting to eliminate the U.S. Banking system as we know it. Some found her views to be shocking, but for me, they confirmed everything I’ve been watching for the last 15 years or so. The fact is, she is NOT the only person inside the beltway that wants to eliminate banks.