Regulatory focus is growing on increasing reliance of financial institutions on outsourcing to third parties, particularly but not exclusively in the technology area.  Here are some thoughts on the future direction based on initial reviews of the comments from the public consultation period which has now closed. Key Takeaways Regulatory and supervisory oversight on outsourcing topics should be expected to

Thanks to many who have reached out after I was again profiled in a Handelsblatt article for having promptly understood and acted upon the internal fraud at Wirecard 1. This was the first time I had spoken to the journalists. On May 8, 2020, Wirecard announced my appointment to the Management Board. The press release described a comprehensive change in the Management

Today, the “Anti-Money Laundering Act of 2020” (“AML Act”) becomes law, providing the greatest expansion of the legal framework in this area since the USA PATRIOT Act twenty years ago. Fundamentally, however, the AML Act must be understood as an endorsement of activity long-since initiated by FinCEN, and a further confirmation of the intent that FinCEN has the central, lead-role