Financial Institutions

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Financial Markets in Crisis: Applications Are In

The Gibson, Dunn & Crutcher Financial Markets Crisis Group is tracking closely government responses to the turmoil that has catalyzed dramatic and rapid reshaping of our capital and credit markets.

Client Alert | October 9, 2008

Financial Markets in Crisis: Treasury Moves to Implement TARP

With the Emergency Economic Stabilization Act (EESA) now law, Treasury is moving quickly to choose advisers, issue regulations, and hire companies to serve as asset managers for the Troubled Asset Relief Program (TARP).Today, Secretary Paulson announced that he has selected Neel Kashkari to be the interim head of the new Office of Financial Stability, which will implement the Troubled Asset Relief Program.  Kashkari is currently Assistant Secretary for International Economics and Development and has been a key adviser to Secretary Paulson.  It is our understanding that Secretary Paulson intends to hire a small staff with expertise in asset management, accounting, and legal issues to commence the Troubled Asset Relief Program.

Client Alert | October 6, 2008

Casinos Continue to Be Vulnerable to Money Laundering

The conviction in August of two former Bank of China managers and their wives in Las Vegas for money laundering and other crimes illustrates the continuing vulnerability of casinos to money laundering.

Client Alert | October 3, 2008

Financial Markets in Crisis: Rescue Bill Reaches Finish Line

The Gibson, Dunn & Crutcher Financial Markets Crisis Group is tracking closely government responses to the turmoil that has catalyzed dramatic and rapid reshaping of our capital and credit markets.

Client Alert | October 3, 2008

Financial Markets in Crisis: Section-By-Section Analysis of the Emergency Economic Stabilization Act of 2008

We are pleased to provide our clients and friends with a section-by-section analysis of the Emergency Economic Stabilization Act of 2008 (hereinafter, the "Act") as passed by the Senate, by a vote of 74-25, on October 2, 2008.

Client Alert | October 2, 2008

Financial Markets in Crisis: Overview of FDIC’s Authority with Respect to Bank Failures

The Gibson, Dunn & Crutcher Financial Markets Crisis Group is tracking closely government responses to the turmoil that has catalyzed dramatic and rapid reshaping of our capital and credit markets.

Client Alert | September 30, 2008

Financial Markets in Crisis: Rescue Bill Fails in House

The Gibson, Dunn & Crutcher Financial Markets Crisis Group is tracking closely government responses to the turmoil that has catalyzed dramatic and rapid reshaping of our capital and credit markets.What follows is our latest in a series of updates on key regulatory and legislative issues.Bipartisan RejectionLawmakers labored over the weekend to craft a financial package that would be palatable to both Democrats and Republicans, as well as to constituents back home.  Draft legislation was circulated and tinkered with all weekend until the House Rules Committee, at 12:01 a.m.

Client Alert | September 29, 2008

Financial Markets in Crisis: Silence on the Rescue Deal Is Golden; Banking Giant WMBank Falls but DIF Held Harmless

The Gibson, Dunn & Crutcher Financial Markets Crisis Group is tracking closely government responses to the turmoil that has catalyzed dramatic and rapid reshaping of our capital and credit markets.What follows is our latest in a series of updates on key regulatory and legislative issues.Debate on the HillIn contrast to yesterday's public display of political and policy wrangling, today's activity was largely behind the scenes as designated negotiators worked to hash out the details of a rescue plan.  Though congressional leaders reported yesterday that they had reached a compromise agreement, Republicans announced that they had developed a competing proposal late Thursday night.  House Minority Leader John Boehner wrote Speaker Pelosi today to express concern that the Democra

Client Alert | September 26, 2008

Financial Markets Crisis: Issues for Hedge Funds and Private Equity Funds

The Gibson, Dunn & Crutcher Financial Markets Crisis Group is tracking government responses to the turmoil that has reshaped our capital and credit markets.  The following is an update on key regulatory and legislative issues that are of particular interest to and are likely to affect hedge funds and private equity funds.Federal Reserve Board Enhances Passive Investment Framework for Minority Investors in Bank Holding Companies and BanksIn connection with its various efforts to increase the capital and liquidity available to the banking industry, on September 22, 2008 the Federal Reserve Board (the "Fed") issued a new policy statement providing additional guidance on making equity investments in a bank or bank holding company ("BHC").  Importantly, the iss

Client Alert | September 26, 2008

Financial Markets in Crisis: Deal on Rescue Bill Appears Likely, but What Will It Contain?

The Gibson, Dunn & Crutcher Financial Markets Crisis Group is tracking closely government responses to the turmoil that has catalyzed dramatic and rapid reshaping of our capital and credit markets.

Client Alert | September 25, 2008

Financial Markets Crisis: Congress and Administration Lurch Toward a Rescue Plan; Federal Reserve Relaxes Restrictions on Investments in Banks

The Gibson, Dunn & Crutcher Financial Markets Crisis Group is tracking closely government responses to the turmoil that has catalyzed dramatic and rapid reshaping of our capital and credit markets.What follows is our latest in a series of updates on key regulatory and legislative issues.Congressional HearingsToday, Treasury Secretary Henry Paulson and Federal Reserve Board Chairman Ben Bernanke testified before the House Financial Services Committee.  Both Secretary Paulson and Chairman Bernanke reiterated the message they conveyed to the Senate Banking Committee yesterday, urging Congress to pass legislation quickly and warning of dire economic consequences if the federal government does not intervene soon.  Tomorrow, the House Financial Services Committee will hear testimon

Client Alert | September 24, 2008

Congressional and Administrative Status Update Regarding Economic Bailout

The Gibson, Dunn & Crutcher Financial Markets Crisis Group is tracking closely government responses to the turmoil that has catalyzed dramatic and rapid reshaping of our capital and credit markets.What follows is our latest in a series of updates on key regulatory and legislative issues.Senate Banking Committee HearingThe Senate Banking Committee met today to hear testimony from Treasury Secretary Henry Paulson, Federal Reserve Chairman Ben Bernanke, Securities and Exchange Commission Chair Chris Cox, and Federal Housing Finance Agency Director James Lockhart.Treasury Secretary Paulson continued to advocate for a narrowly tailored bill without additional corporate governance provisions which could slow down approval of the legislation.  Though he maintained that approval of the le

Client Alert | September 23, 2008

Recent Senate Hearing Targets Dividend Tax Avoidance by Large Financial Firms with Offshore Entities

A key Senate investigative body has issued its latest findings in its investigation of alleged abusive tax practices, which is now in its seventh year.  The investigation has examined alleged offshore tax havens, the way tax shelters are promoted, how assets are "hidden" offshore, and, most recently, dividend tax abuse.  While it is not clear where the investigation will focus next, it is highly likely that it will continue.

Client Alert | September 22, 2008

Capital Markets in Crisis: The Government Formulates a Response

Gibson, Dunn & Crutcher Deploys a Team of ExpertsMany of our clients are facing new challenges because of the dramatic economic events that have occurred over the last two weeks and as a result of changes that in their scope and reach we have not seen since the Depression.  Financial markets are literally being reshaped in Washington on a real-time basis.  As the Administration and Congress move forward to address the liquidity crisis and related problems, we are positioned to keep our clients apprised of key developments and to ensure that their voices are heard in the debate about how to repair our financial infrastructure.To that end, Gibson, Dunn has assembled a team of attorneys with a broad range of experience in the securities, financial, corporate, real estate, tax, b

Client Alert | September 22, 2008

Internet Gambling Rules Would Enlist Banks to Fight Uphill Battle

Washington, D.C. Partner Amy Rudnick and New York Associate Anthony Mahajan are authors of "Internet Gambling Rules Would Enlist Banks to Fight Uphill Battle" [PDF] published in BNA's Banking Report.

Article | December 17, 2007

Treasury Issues New Bank Secrecy Act Guidance for Casinos and Card Clubs

On November 14, 2007, for the first time in several years, the Department of the Treasury, Financial Crimes Enforcement Network ("FinCEN"), issued Bank Secrecy Act ("BSA") compliance guidance for casinos and card clubs, Frequently Asked Questions:  Casino Recordkeeping, Reporting, and Compliance Program Requirements (FIN-2007-G005).  The guidance, which is in the form of twenty-three questions and answers, addresses questions about what types of gaming establishments are subject to the BSA requirements and questions about compliance with the BSA requirements by casinos and card clubs, including currency transaction reporting (31 C.F.R.

Client Alert | November 26, 2007

The Mixing of Banking and Commerce: A conference summary

Washington, D.C. partner C.F. Muckenfuss III was quoted in the article, "The Mixing of Banking and Commerce: A conference summary" [PDF] published in the November 2007 issue of The Federal Reserve Bank of Chicago's Chicago Fed Letter.

Client Alert | November 1, 2007

U.S. Treasury Department Formally Severs Ties Between U.S. Financial Institutions and Banco Delta Asia

On March 14, 2007, Stuart Levey, the Undersecretary for Terrorism and Financial Intelligence at the U.S. Treasury Department, announced the issuance of a final rule under Section 311 of the USA PATRIOT Act that, in 30 days, will bar U.S.

Client Alert | March 15, 2007

World Bank Announces New Voluntary Disclosure Program: Entities That Voluntarily Report Wrongdoing Will Not Face Sanctions

The World Bank has announced that its Board of Executive Directors has approved a new Voluntary Disclosure Program intended to encourage entities to report fraudulent and corrupt practices involving projects financed or supported by the World Bank.

Client Alert | October 3, 2006

2006 Bank Secrecy Act/Anti-Money Laundering Examination Manual Clarifies Elements of Effective OFAC Compliance Program for ACH Transactions

On July 28, 2006, the Federal Financial Institutions Examination Council (FFIEC) released the 2006 Bank Secrecy Act/Anti-Money Laundering Manual ("BSA/AML Manual").

Client Alert | September 11, 2006