Laurel Loomis Rimon is a partner with the law firm Jenner & Block. She serves as a co-chair of the firm's Fintech and Crypto Assets practice, and is the founder of its Payments practice. She is a former federal prosecutor.
Before holding financial institutions accountable for new regulatory expectations, clearer guidance is needed on what constitutes appropriate risk-based decision-making versus impermissible "debanking."
For cryptocurrency entrepreneurs in particular, many of whom are just developing the anti-money laundering programs they are required to have under other FinCEN rules, the CDD rule is worth taking note of, writes Laurel Loomis Rimon, senior counsel at O'Melveny & Myers LLP.