January 14, 2022

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.

New leadership usually takes us into the future. The Office of the Comptroller of the Currency (OCC) is reversing this trend by first taking us into the past for a bit. Seeing the June 5, 2020, final rule to modernize its Community Reinvestment Act (CRA) framework (June 2020 Rule) as a false start, the OCC has issued a proposed rule to rescind it in favor of working with the other agencies to develop a new rule. The proposed rule would replace the existing 12 CFR part 25 with a revised 12 CFR part 25 based on the 1995 Rules and reinstate 12 CFR part 195 (for savings associations). The proposed 12 CFR part 25 would be substantively identical to the 1995 rule. All definitions, performance tests and standards, and related data collection, recordkeeping, and reporting requirements would revert to those in place before the OCC issued the June 2020 Rule. Also, the rules surrounding the public file and public notice requirements would revert to those in the 1995 rule. The proposed rule applies to all national banks and all federal and state savings associations. If you would like to comment on any aspect of the proposal, you must submit those before Oct. 29, 2021. The June 2020 Rule would remain in effect until replaced by final rules based on this proposal.

In November, 2020, Arizona joined a growing number of states legalizing cannabis for adult use. While Arizona has had a medical marijuana program in place since 2010, the move to welcome recreational marijuana represents a significant expansion of the market. With 73 dispensaries already approved to sell recreational marijuana, Arizona is on track to surpass $1 billion in total annual sales of medical and recreational cannabis. Some analysts predict the state will top $2 billion in annual sales after recreational sales have been in place for a few years. As a result, cannabis companies from around the country have been exploring expansions and acquisitions in Arizona, and existing companies are planning to grow.

Cryptocurrency – virtual or electronic currencies – has been in the financial news a lot lately. However, it remains a mystery to most people. Below is an overview of cryptocurrencies: how they work, what drives interest in them, and their associated risks.

As the largest and wealthiest generation of Americans prepares to retire, as much as $68 trillion will be passed down to younger generations over the next two decades. This phenomenon, dubbed “The Great Wealth Transfer,” is already beginning today.

Banks and financial institutions rely on technology to operate successfully and provide customers the best products and services. With technology, though, comes the heightened risk of falling victim to wire fraud schemes that can result in significant financial losses.

Many bankers are looking for ways to put their liquidity to good use. Buoyed by government relief, deposits surged at many financial institutions (FIs) at the start of the pandemic. Despite predictions that liquidity would tighten in pace with an economic recovery, FIs still have more cash than opportunities to profitably deploy it.

2022 May 4-6, Colorado & Arizona Bankers Summit, Colorado Springs Broadmoor Resort. Register at azbankers.org/events