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• As American businesses, including financial institutions, adjust their operations in the wake of the coronavirus pandemic (COVID-19), the need to work closely with state regulators has become increasingly apparent.
• Under the current federal administration, we have seen state regulatory agencies react in the wake of perceived reduction in federal enforcement. Two leaders in the effort to fill in the regulatory gap in the banking and financial services industry have been the New York Attorney General and the New York State Department of Financial Services (DFS).
• We expect both the New York Attorney General and DFS to continue to expand financial institution enforcement in response to perceived reduction in federal enforcement under the current administration, and to focus on banking and financial sector priorities including anti money laundering, sanctions, Bank Secrecy Act, consumer protection and cybersecurity.