Between the Lines Blog

Legal Options When Bank Employees Take Confidential Data from Bank Systems
Category: Banking & Finance, Employment, Information Privacy, Security and Data Rights, Litigation
Despite bank policies, training, computer warning banners, governing laws and banking regulations, bank employees still take bank or customer data as their employment ends. They take potential or current customer lists, transactional data and supporting customer files, procedural manuals, or other…
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The Benefit of Achieving Tier III Classification for Marijuana and Cannabis Related Businesses
Category: Banking & Finance, Business
In 2020 the legal segment of the marijuana industry exceeded $10 billion dollars in the United States with California alone generating $3.1 billion in sales in 2019, and Colorado in a close second at $1.6 billion. With the solidified foothold the industry has gained in the marketplace and the sheer…
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Securities Litigation Results in Win for Broker and Clarifies Law in the Eighth Circuit
Category: Appellate Law, Banking & Finance, Litigation
Through an investment bank (acting as broker), clients invested in Reverse Convertible Notes (RCNs). RCNs are a complex “structured financial product” that is sometimes championed as a high-yield, short-term investment promising above-market interest payments but is nonetheless viewed as “perhaps…
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The High Points: SARs and the Three Tiered Framework for MRBs
Category: Banking & Finance, Health Care
As green states continue to grow, intentional or unintentional exposure to Marijuana Related Business (“MRB”) customers for financial institutions and broker-dealers is an inevitability. Whether your business has decided to actively shoulder the risk of allowing MRB customers in pursuit of the…
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Accuracy Counts: Filing Complete and Accurate SARs and Program Specific Red Flags Related to Covid-19 Criminal or Fraudulent Activity
Category: Banking & Finance, Health Care
On September 29, 2020, at the 19th Annual AML & Anti-Financial Crime Conference, Financial Crimes Enforcement Network (“FinCEN”) Director Kenneth Blanco reported over 91,000 suspicious activity reports (“SARs”) have been filed related to Covid-19 criminal and fraudulent activity. These 91,000…
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