IBA Compliance Connection

Illinois bankers are constantly challenged with new laws, regulations, enforcement trends, and other pressing compliance concerns. The IBA is here to help! Your IBA membership includes access to members-only compliance resources, guidance on compliance inquiries, outstanding educational events and networking opportunities, a weekly compliance newsletter, and more!

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FinCEN Identifies “Bitzlato” Cryptocurrency Exchange as a Primary Money Laundering Concern. FinCEN has issued an order identifying Bitzlato Limited, a convertible virtual currency exchange incorporated in Hong Kong, as a primary money laundering concern connected to Russian illicit finance. The order prohibits transmittals of funds involving Bitzlato by financial institutions, effective February 1, 2023, with no cessation date. Read the announcementFAQs, and order.

January 19, 2023

CFPB Identifies Potential UDAAP Violations in Subscription Service Practices. The CFPB has issued a Consumer Financial Protection Circular concluding that “negative option” subscription services (subscriptions that automatically renew unless a consumer affirmatively cancels) must comply with consumer financial protection laws, including the prohibition on unfair, deceptive, and abusive acts or practices (UDAAP). Subscription services risk UDAAP violations if they: (1) do not clearly and conspicuously disclose the material terms of the negative option, (2) do not obtain consumers’ informed consent, or (3) make it unreasonably difficult for consumers to cancel. Read the announcement and Circular 2023-01.

January 19, 2023

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