Compliance
OFAC's 50 Percent Rule: Ownership Screening for Shell Structures in Payment Chains
Petra VogelAn entity never listed anywhere can still be blocked property — when enough of it belongs to people who are.
Compliance
The operating side of the rulebook.
Compliance
The E-SIGN Act and Digital Account Opening: What Constitutes Valid Consumer Consent
Petra VogelElectronic signatures bind when the consumer's consent is demonstrable — and the demonstrability is a records design, not a checkbox.
Compliance
Off-Channel Communications After $2 Billion in SEC Settlements: Records Discipline That Actually Holds
Petra VogelThe Commission's recordkeeping sweep made personal-device messaging the most expensive habit on Wall Street; the retention duty it enforced never changed.
Compliance
Regulation E Error Resolution for Fraudulent Transfers: Clocks, Provisional Credit, and P2P Disputes
Petra VogelThe rule that governs a disputed Zelle payment was written for magnetic tape; its clocks still decide what the bank owes and when.
Compliance
Who the FTC Safeguards Rule Covers, and When Its Incident-Notification Requirement Triggers
Petra VogelThe Gramm-Leach-Bliley security rule reached its full modern shape in June 2023, and since May 2024 certain breaches go straight to the Commission within thirty days.
Compliance
How to Document a Compliance Risk Assessment That Survives an OCC Examination
Petra VogelOCC Bulletin 2016-39 asked for risk-based compliance programs eight years before fintech partnerships made the question hard; the exam-ready file has a known shape.