S&C Critical Insights –  NYDFS and FinCEN Guidance in Response to COVID-19

March 20, 2020



In this episode of S&C’s Critical Insights podcast series, S&C litigation partner Sharon Cohen Levin discusses a recent order by the New York Department of Financial Services granting regulated entities temporary relief to help them meet compliance obligations while managing disruptions associated with the COVID-19 pandemic. The measures include the relaxation of requirements for the temporary relocation or closure of regulated entities, including those caused by the need to operate remotely, the extension of filing deadlines for certain required reports and permitting the use of electronic means for in-person presence at board meetings. Sharon also discussed FinCEN’s recent guidance encouraging financial institutions to communicate concerns related to the timely filing of reports required under the Bank Secrecy Act and identifying several patterns of fraudulent transactions that have emerged since the onset of the COVID-19 outbreak.