On March 30, 2022, the Federal Deposit Insurance Corporation (the “FDIC”) issued a notice regarding a proposed Statement of Principles for Climate-Related Financial Risk Management for Large Financial Institutions (the “Principles”). The notice also requests comments from the public on the proposed Principles. The Principles are substantively similar to those issued by the Office of the Comptroller of the Currency on December 16, 2021. As proposed, the Principles would create a high-level framework for the safe and sound management of exposures to climate-related financial risks.
Effective January 1, 2021, the National Defense Authorization Act for Fiscal Year 2021 (the “Act”) became law. Among other provisions, the Act contains the most significant changes to the Bank Secrecy Act (the “BSA”) since 2001. Most significantly, the Act requires the Department of the Treasury, through the Financial Crimes Enforcement Network (“FinCEN”), to adopt regulations within one year that will establish a framework by which smaller, closely held businesses, regardless of the type of enterprise (e.g., corporation, limited liability company or partnership) will be required to disclose their beneficial ownership to FinCEN.