Russian Related Money Laundering Concern
Primary Money Laundering Concern - FinCEN issued an order identifying the virtual currency exchange Bitzlato Limited as a “primary money laundering concern” in connection with Russian illicit finance pursuant to section 9714(a) of the Combatting Russian Money Laundering Act. This type of action, a rarely used so-called death-knell sanction that cuts off the entity from the U.S. financial system, has been used mainly in the past against banks and other financial institutions and in most cases has forced the institution to close.
CFPB Comments on Negative Subscription Services
Negative Option Subscription Services - The CFPB issued a new circular affirming that companies offering “negative option” subscription services must comply with federal consumer financial protection law. Negative option programs include subscription services that automatically renew unless the consumer affirmatively cancels, and trial marketing programs that charge a reduced fee for an initial period and then automatically begin charging a higher fee.
Updated Mortgage Servicing Exam Procedures
Mortgage Servicing – The CFPB updated its Mortgage Servicing Examination Procedures for forbearances and other tools that mortgage servicers have used during the COVID-19 national emergency. The updated Procedures also integrate focus areas from the CFPB’s Supervisory Highlights findings, including questions about the fees servicers charge borrowers, such as phone pay fees, and misrepresentations related to foreclosure. Additionally, it advises examiners to seek information on how the servicers communicate with borrowers about homeowner assistance programs.