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Russia/Ukraine Sanctions Update - Month of August 2025

I. U.S. SANCTIONS - U.S. Department of the Treasury Sanctions Russian Cryptocurrency Exchange: On August 14, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) re-designated the cryptocurrency exchange, Garantex Europe OU (“Garantex”), determined to have directly facilitated notorious ransomware actors and other cybercriminals by processing over $100 million in transactions linked to illicit activities, since 2019....By: Mayer Brown

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UK FCA Continues to Simplify Supervisory Communications

The UK Financial Conduct Authority (FCA) has confirmed further steps to simplify its supervisory communications, building on its April announcement and aligning with its Consumer Duty Requirements Review. The FCA confirms it will simplify multi-firm and thematic reviews, labelling those published before 2022 as "historical"....By: A&O Shearman

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Eye on Economic Crime: HMRC Brings Forward First Corporate Prosecution Under Failure to Prevent Tax Evasion Offence

On 11 August 2025, HM Revenue & Customs ("HMRC") initiated its first corporate prosecution under the failure to prevent the facilitation of tax evasion offence, which was introduced by the Criminal Finances Act 2017.  Bennett Verby Ltd, a Stockport-based accountancy firm, and six individuals, including a former director, were charged in connection with an alleged research and development ("R&D") tax credit repayment fraud....By: Mayer Brown

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District Court Allows Federal TILA and Maryland Consumer Loan Law Claims to Move Forward Against Earned Wage Access Provider

On August 8, the U.S. District Court for the District of Maryland issued an opinion partially granting an earned wage access (EWA) provider’s motion to dismiss that challenged whether the company operated as an unlicensed lender in violation of the Maryland Consumer Loan Law (MCLL), charged unlawful fees, and failed to comply with disclosure obligations under the Truth in Lending Act (TILA). Plaintiffs also alleged the company violated the Maryland Consumer Protection Act’s (MCPA) prohibition on...By: Sheppard Mullin Richter & Hampton LLP

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FATF Announce the Launch of New NRA Toolkit for AML/CFT Measures

The Financial Action Task Force (FATF) has announced the launch of a new National Risk Assessment (NRA) toolkit aimed at enhancing countries' ability to identify and address money laundering risks. The toolkit supports a risk-based approach aligned with FATF Standards and provides cross-country insights into predicate offences, laundering methods, and proceeds of crime. It focuses on four priority areas that are currently consistently challenging to assess, including: corruption, virtual assets...By: A&O Shearman

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CFPB Proposes Rule Narrowing Nonbank Supervisory Authority Under CFPA

On August 26, 2025, the CFPB published a notice of proposed rulemaking to narrow the scope of its authority to designate nonbanks for supervision under the Consumer Financial Protection Act (CFPA). The proposal follows earlier announcements by the Bureau that it would reassess its use of this authority (previously discussed here)....By: Sheppard Mullin Richter & Hampton LLP

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Horizon - ESG Regulatory News and Trends - August 2025

Welcome to Horizon, DLA Piper’s monthly bulletin reporting on late-breaking legislative and policy developments in ESG. Our aim is to scan the litigation, enforcement, and regulatory horizon to help inform business decisions....By: DLA Piper

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UK FCA Issues Statement on Workplace Savings Schemes

The UK Financial Conduct Authority (FCA) has issued a statement alongside a press release aimed at clarifying the rules surrounding workplace savings schemes. These schemes, which allow employees to save directly from their salary via payroll, are seen as a tool to enhance financial resilience and support economic growth....By: A&O Shearman

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Illinois Proposes Regulations for Shared Appreciation Agreements Under the Residential Mortgage License Act

On August 15, the Illinois Department of Financial and Professional Regulation proposed regulations to implement recent amendments to the Residential Mortgage License Act of 1987 (RMLA) covering “shared appreciation agreements.” The proposed revisions treat these agreements as residential mortgage loans subject to RMLA licensing and compliance requirements....By: Sheppard Mullin Richter & Hampton LLP

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California Finalizes New CCPA Rules on ADMT, Cybersecurity Audits, and Risk Assessments

On July 24, the California Privacy Protection Agency (CPPA) approved a major rule package covering automated decision-making technology (ADMT), mandatory cybersecurity audits, and privacy risk assessments under the California Consumer Privacy Act (CCPA). The package narrows the definition of ADMT to tools that replace human decision making for significant decisions in areas like lending, housing, employment, education, and health care....By: Sheppard Mullin Richter & Hampton LLP

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CFPB Returns to Rulemaking on Personal Financial Data Rights Rule 1033

On August 22nd, the Consumer Financial Protection Bureau (the “CFPB”) published an advanced notice of proposed rulemaking (an “ANPR”) relating to a reconsideration of the CFPB’s current Personal Financial Data Rights Rule (the “Current PFDR Rule”) that had been previously released in late 2024 pursuant to the authority of Section 1033 of the Dodd-Frank Act....By: Moore & Van Allen PLLC

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Revisiting the State of the Law in ERISA Forfeitures Cases

On July 14, 2025, we published a detailed Legal Update describing the state of the law with respect to the ongoing wave of ERISA forfeiture lawsuits. This Legal Update analyzes the material developments that we have seen over the past six weeks, which include additional motion to dismiss rulings and a growing number of pending appeals....By: Mayer Brown

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Wyoming Launches First State-Issued Stable Token

On August 19, the Wyoming Stable Token Commission announced the launch of the Frontier Stable Token (FRNT), making Wyoming the first public entity in the United States to issue a state-backed, blockchain-based stablecoin. The program is authorized under the Wyoming Stable Token Act and chaired by Governor Mark Gordon....By: Sheppard Mullin Richter & Hampton LLP

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Artificial Intelligence for RIAs: Compliance Considerations and Practical Policies

The use of artificial intelligence (“AI”) notetakers, while beneficial for productivity, raises significant concerns around privacy, security, and compliance. These risks are at the center of Brewer v. Otter.ai, a lawsuit filed on August 15, 2025, which claims Otter.ai unlawfully recorded conversations on popular video conferencing platforms without all participants’ consent and used the data to train its machine-learning models....By: Stark & Stark

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Nutter Bank Report: August 2025

Comptroller of the Currency Jonathan Gould and Acting FDIC Chairman Travis Hill recently issued public statements in support of President Trump’s executive order titled Guaranteeing Fair Banking For All Americans. The executive order issued on August 7 asserts that “[f]inancial institutions have engaged in unacceptable practices to restrict law-abiding individuals’ and businesses’ access to financial services on the basis of political or religious beliefs or lawful business activities.” On...By: Nutter McClennen & Fish LLP

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2025 State Enforcement Recap

Until the Dodd-Frank Act, the states were at the forefront of consumer credit regulation and enforcement. The arrival of the federal Consumer Financial Protection Bureau gave the states, which typically operated within tight budget constraints, some breathing room, allowing them to focus resources elsewhere....By: Hudson Cook, LLP

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CFPB Enters a Proposed Agreement with Banking-as-a-Service Platform After Failure to Maintain Records Following Bankruptcy

The Consumer Financial Protection Bureau (CFPB) announced that it filed a complaint against a banking-as-a-service platform on August 21, 2025 in the U.S. Bankruptcy Court for the Central District of California, San Fernando Valley Division....By: Goodwin

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Tribal Tax and Investment Reform Act of 2025

On June 11, 2025, Senator Catherine Cortez Masto (D-NV) introduced S.2022, titled the Tribal Tax and Investment Reform Act of 2025 (the Bill). The bipartisan Bill, co-sponsored by Senator Lisa Murkowski (R-AK), aims to provide tax parity for tribal governments and stimulate economic development in Indian Country by providing tribal nations access to the same tax benefits and treatment as state governments....By: WilmerHale

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Recapping the DOJ’s Evolving Policies on Corporate Enforcement and Compliance

This article recaps Department of Justice guidance since the Trump Administration took office in January. These are topics we’ve addressed in previous articles and alerts, and are presented here in summarized form....By: Womble Bond Dickinson

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“Fair Banking” Executive Order Directs Federal Regulators to Address Debanking

President Trump’s executive order, “Guaranteeing Fair Banking for All Americans,” asserts that financial institutions have denied or terminated financial services to “persons participating in activities or causes commonly associated with conservatism and the political right” and those “engaged in lawful activities and industries disfavored by regulators.”...By: Woods Rogers

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