Monthly Archive:: November 2021

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, ...Read More

Q: What is the current closed-end threshold for partial exemptions?  When does it change? A: The partial exemption closed-end threshold is currently 500 transactions in each of the two previous years and is not currently scheduled to change.  There is currently a full reporting ...Read More

Question: Can you give us some tips drafting an MSA for a joint advertising campaign to avoid a RESPA Section 8 issue? Answer: As I am sure you have found, “marketing services agreements” is definitely a hot topic. It is still unclear to what ...Read More

by Rob Nichols, American Bankers Association 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 ...Read More