Washington Report 360 | March 11, 2022

Executive Order on Digital Assets; Proposed cybersecurity disclosure reporting rules; FinCEN sanctions

Amy S. Matsuo

Amy S. Matsuo

Regulatory and ESG Insights Leader, KPMG US

+1 919-664-7100

Key Highlights

  • Cybersecurity. The SEC proposed cybersecurity disclosure reporting rules for public companies in i) risk management, ii) strategy, iii) governance, and iv) incident reporting. (See KPMG Regulatory Alert)
  • Sanctions. FinCEN issued an alert advising all financial institutions to be vigilant against potential efforts to evade sanctions and other U.S.-imposed restrictions, and detailing examples of red flags to help identify potential sanctions evasion activity. (See KPMG Regulatory Alert)
  • Digital Assets. The Administration issued an executive order on digital assets, directing several agencies (including SEC, CFTC, FRB, OCC, FDIC, CFPB, Treasury, and FSOC) to produce reports on the protection of consumers, investors, and businesses, financial stability, national security, and U.S. adoption of a central bank digital currency (CBDC). All of these reports are due within 180 days. 
  • Climate risk. SEC will meet on March 21 to consider proposed climate-related disclosures.   FRB, OCC, and FDIC are working to finalize principles on climate change risk management and develop more detailed guidance.
  • Community Reinvestment Act.  FRB, OCC, and FDIC are expected to issue a proposed rule on CRA by the end of March; the proposal includes climate-related disaster recovery and bank partnerships with nonbank lenders.

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