Insights · Looking Back

Financial Services

The Looking Back articles on financial services, in order.

101 articles

January 2020

  1. Week of 6 January 2020

    Travelex’s outage was every white-label bank’s outage

    When ransomware took Travelex offline, banks that sold its travel money under their own brands had no service and little to say. White-label dependencies carry the bank’s reputation, so they need the bank’s controls: communication, contract terms and concentration planning.

    • Financial Services
    • Economics & Procurement
    • 5 min read

February 2020

  1. Week of 10 February 2020

    What the Equifax indictment changed for banks, and what it did not

    The Justice Department charged four Chinese military officers over the 2017 Equifax breach. For banks, the indictment settled who did it and changed nothing that mattered operationally: the data stayed exposed, the entry point stayed ordinary and accountability stayed with the data holder.

    • Financial Services
    • Security & Resilience
    • 5 min read
  2. Week of 17 February 2020

    Morgan Stanley and E*Trade: wealth scale is a client-data problem

    Morgan Stanley’s deal for E*Trade, months after Schwab agreed to buy TD Ameritrade, bet on joining self-directed, advised and workplace channels. Whether such scale pays depends on three layers of integration, and the client layer comes first for firms of any size.

    • Financial Services
    • Platforms & Architecture
    • 5 min read

March 2020

  1. Week of 2 March 2020

    Why the FFIEC’s pandemic statement was an evidence checklist

    The FFIEC’s March 6, 2020, statement restated pandemic expectations from the avian flu era. Its value lay in what examiners would later ask institutions to show: staged decisions, critical operations run with fewer people, and service providers coping with the same disruption.

    • Financial Services
    • Regulation & Compliance
    • 5 min read
  2. Week of 23 March 2020

    Forbearance on request: what the CARES Act asked of loan servicers

    The CARES Act gave borrowers with federally backed mortgages forbearance on request and told lenders how to report accommodated accounts. Servicing built for case-by-case exceptions had to run intake, credit reporting and exit planning at volume, mostly from home.

    • Financial Services
    • Customer & Citizen Experience
    • 5 min read

April 2020

  1. Week of 6 April 2020

    Paycheck Protection: capital was easy, intake was hard

    When the Paycheck Protection Program opened on April 3, 2020, the guarantee and the Fed facility solved funding. Lenders’ capacity was set instead by intake, verification and submission to SBA, and by how fast they could redeploy staff into a standardized process.

    • Financial Services
    • Operations & Workforce
    • 5 min read

May 2020

  1. Week of 18 May 2020

    Small-dollar loans, alternative data and the governance attached

    The May 2020 interagency principles invited banks and credit unions back into small-dollar lending and accepted new data and technology in underwriting. Using cash-flow data responsibly required three disciplines: consented data access, model risk management and fair lending controls for automated decisions.

    • Financial Services
    • Data & AI
    • 5 min read
  2. Week of 25 May 2020

    Why valid when made left bank-fintech lenders two open questions

    The OCC’s May 29, 2020, rule said a national bank loan’s permissible interest survives its sale. That settled one question for bank-fintech lending. It left open who the true lender is, and how the bank proves it oversees the program.

    • Financial Services
    • Regulation & Compliance
    • 5 min read

June 2020

  1. Week of 15 June 2020

    What due diligence cannot outsource, as Wirecard’s partners found

    Wirecard had audited accounts, licenses and blue-chip clients, and €1.9 billion of its cash probably never existed. Partners relying on those signals learned that three checks cannot be delegated: where the money comes from, whether customer funds are visible, and how to leave.

    • Financial Services
    • Economics & Procurement
    • 5 min read
  2. Week of 29 June 2020

    Why Form CRS was the easy part of Regulation Best Interest

    Broker-dealers had to comply with Regulation Best Interest and deliver Form CRS from June 30, 2020. The disclosure document was a contained project. Showing that each recommendation met the standard, and that conflicts were controlled, required data most firms did not capture.

    • Financial Services
    • Regulation & Compliance
    • 5 min read

August 2020

  1. Week of 3 August 2020

    Capital One’s cloud penalty was a verdict on sequencing

    The OCC’s $80 million penalty did not say the cloud was unsafe. It said a bank moved critical operations before its risk management could describe, test and monitor them, and it priced that gap.

    • Financial Services
    • Platforms & Architecture
    • 5 min read
  2. Week of 24 August 2020

    Low for long: the rate forecast hidden in bank technology budgets

    The Fed’s August 2020 framework change gave banks a credible reason to plan for years of near-zero rates. Many technology business cases quietly assumed it, in deposit forecasts, channel metrics and contract terms that later came due.

    • Financial Services
    • Economics & Procurement
    • 5 min read

September 2020

  1. Week of 14 September 2020

    Filing is not finding: FinCEN’s effectiveness question meets the FinCEN Files

    In one September week, FinCEN asked how to define an effective AML program and leaked reports showed banks filing dutifully while flagged activity continued. The gap between volume, usefulness and action was a data and decision problem that compliance metrics hid.

    • Financial Services
    • Regulation & Compliance
    • 5 min read

October 2020

  1. Week of 5 October 2020

    Citi’s orders put data lineage on the safety and soundness agenda

    The October 2020 actions against Citigroup treated weak data governance as a safety and soundness failure, alongside risk management and controls. Every bank inherited the expectation that it can show where its important numbers come from and who answers for them.

    • Financial Services
    • Data & AI
    • 5 min read

December 2020

  1. Week of 28 December 2020

    Why the ownership registry never replaced the bank’s own file

    The Anti-Money Laundering Act of 2020 promised banks a federal register of who owns companies. The register was later cut back, the bank’s own due diligence duty stayed, and a new whistleblower channel changed who could report weak programs.

    • Financial Services
    • Regulation & Compliance
    • 5 min read

January 2021

  1. Week of 11 January 2021

    Before the 36-hour clock: deciding which bank incidents count

    The banking agencies’ proposed notification rule looked like a deadline. The harder work sat upstream of it: a named judgment about what counts as material disruption, and vendor notices that reach the people making that judgment in time.

    • Financial Services
    • Security & Resilience
    • 5 min read
  2. Week of 25 January 2021

    GameStop’s buy button was switched off in the clearinghouse

    When retail brokers stopped customers buying GameStop on January 28, 2021, the cause sat in clearing and settlement. The episode showed that a broker’s settlement exposure, its treasury playbook and its app are one system, though three teams own them.

    • Financial Services
    • Platforms & Architecture
    • 5 min read

February 2021

  1. Week of 22 February 2021

    A few hours without Fedwire, and the bank promises with no fallback

    The Federal Reserve’s February 24, 2021 outage caused little lasting harm. It still showed how few banks had mapped which customer commitments rest on a single central rail, rehearsed the narrow manual alternatives, or planned for the backlog afterward.

    • Financial Services
    • Platforms & Architecture
    • 5 min read

March 2021

  1. Week of 15 March 2021

    Why business email compromise belongs to the payments team

    The FBI’s 2020 crime report again put business email compromise at the top of its loss table. For banks and credit unions, the controls that decide those losses sit at three points in payment operations, and the inbox is only the first.

    • Financial Services
    • Security & Resilience
    • 5 min read
  2. Week of 22 March 2021

    Each Archegos lender already held enough data to act

    Archegos is usually told as a story of positions hidden across many prime brokers. The costlier failure sat inside individual banks, in three layers: what each could see of its own exposure, what it could infer about the rest, and whether anyone acted.

    • Financial Services
    • Data & AI
    • 5 min read
  3. Week of 29 March 2021

    Five regulators’ AI questions read like an exam plan

    The March 2021 interagency request for information on AI produced no new rule. Its questions mapped onto four supervisory tests that existing rules already imposed, and that examiners still apply to any model in a bank or credit union.

    • Financial Services
    • Regulation & Compliance
    • 5 min read

June 2021

  1. Week of 7 June 2021

    Why Basel’s 1,250% risk weight pointed banks toward custody

    The Basel Committee’s June 2021 consultation made holding bitcoin on a bank balance sheet prohibitively expensive in capital. That split the bank crypto question into three businesses with different economics, holding, safeguarding and moving value, and only one was priced out.

    • Financial Services
    • Economics & Procurement
    • 5 min read
  2. Week of 14 June 2021

    Juneteenth tested how many calendars a bank really runs

    Juneteenth became a federal holiday with one day’s notice in June 2021. For banks and credit unions, it showed that a business day is defined in three places, payment rails, customer commitments and the workforce, usually owned by different teams.

    • Financial Services
    • Operations & Workforce
    • 5 min read
  3. Week of 21 June 2021

    TransUnion won Ramirez, and name-only matching still lost

    The Supreme Court’s June 2021 ruling narrowed who can sue over inaccurate credit file flags. The facts underneath were an entity resolution failure that banks and fintechs share, and the ruling changed none of the three things that govern it.

    • Financial Services
    • Data & AI
    • 5 min read

July 2021

  1. Week of 5 July 2021

    Why community banks’ open banking experience sat with their core vendors

    The July 2021 competition order pushed the CFPB toward a data access rule. For community banks and credit unions, the customer’s experience of sharing data was already being decided elsewhere: by core and digital banking vendors, in three moments the institution only partly controlled.

    • Financial Services
    • Customer & Citizen Experience
    • 5 min read

August 2021

  1. Week of 9 August 2021

    Who counts as a crypto broker mattered less than what brokers could not know

    The Senate’s August 2021 fight over the infrastructure bill’s crypto provision was about who counts as a broker. For banks and brokerages, scope was never in doubt. The hard part was three kinds of data they did not hold: cost, movement and counterparties.

    • Financial Services
    • Regulation & Compliance
    • 5 min read

September 2021

  1. Week of 20 September 2021

    What sanctioning SUEX changed for banks that serve crypto firms

    Treasury’s September 2021 designation of SUEX moved sanctions pressure from the ransom payment to the cash-out. Because SUEX worked through other exchanges, banks serving crypto businesses had to decide how far down three layers of exposure to look, and pay for it.

    • Financial Services
    • Economics & Procurement
    • 5 min read

October 2021

  1. Week of 11 October 2021

    FinCEN’s ransomware analysis turned well-written SARs into threat intelligence

    FinCEN’s October 2021 trend analysis showed that suspicious activity reports can map a criminal economy, but only when filers record cyber indicators in usable form. That choice, made at the investigator’s desk, decides the data’s value inside the bank too.

    • Financial Services
    • Data & AI
    • 5 min read
  2. Week of 25 October 2021

    Non-bank lenders got bank-grade security rules and a named person to answer for them

    The FTC’s amended Safeguards Rule gave mortgage brokers, auto dealers, finance companies and tax preparers specific security controls. The harder change was governance: one qualified individual, a written report to the board, and evidence that the program ran.

    • Financial Services
    • Regulation & Compliance
    • 5 min read

November 2021

  1. Week of 8 November 2021

    Robinhood’s phone-call breach argues for support access sized to one customer

    In November 2021, one socially engineered support employee gave an attacker reach into millions of customer records at a retail brokerage. The fix sits in three places: the agent on the phone, the tools behind them, and what customers are taught to trust.

    • Financial Services
    • Customer & Citizen Experience
    • 5 min read
  2. Week of 29 November 2021

    Inflation’s first casualty in bank IT was the change budget

    When the Fed dropped “transitory” in late November 2021, bank and credit union technology budgets faced a quiet squeeze. Run costs rose automatically through contracts, wages and usage pricing, so the money for modernization absorbed the difference.

    • Financial Services
    • Economics & Procurement
    • 5 min read

February 2022

  1. Week of 7 February 2022

    Bitfinex’s six-year trace ran through records that banks keep

    Investigators followed bitcoin stolen in 2016 to a $3.6 billion seizure in 2022 because the ledger never forgets. The decisive links sat at regulated firms, so banks’ own records of crypto-linked activity need to be built to be read years later.

    • Financial Services
    • Data & AI
    • 5 min read
  2. Week of 14 February 2022

    In Ukraine’s bank DDoS, the rumor outran the outage

    The February 2022 denial-of-service attacks on Ukrainian state banks caused short disruptions, paired with false texts saying ATMs had failed. A bank’s availability in a crisis includes what customers believe about their money, so communication and alternative channels belong in the resilience plan.

    • Financial Services
    • Customer & Citizen Experience
    • 5 min read
  3. Week of 28 February 2022

    Russia’s sanctions tested banks’ ownership data more than their name lists

    The sanctions on Russia from late February 2022 came in fast waves, from several governments, against sprawling corporate groups. Screening names against lists caught the obvious cases. Exposure sat in unnamed subsidiaries, effective dates and jurisdiction-specific rules, all of them data problems.

    • Financial Services
    • Data & AI
    • 5 min read

April 2022

  1. Week of 18 April 2022

    TraderTraitor aimed fake job offers at the engineers who hold the keys

    An April 2022 federal advisory described North Korean operators courting crypto-firm engineers with fake recruiting and trojanized apps. For any financial firm, a job approach reaches the people with the most access through a channel security rarely watches, so controls must assume one will succeed.

    • Financial Services
    • Security & Resilience
    • 5 min read
  2. Week of 25 April 2022

    Why the CFPB’s dormant authority put fintech partners on the exam calendar

    By reviving a rarely used power to supervise nonbanks whose conduct poses risks to consumers, the CFPB made exam readiness something fintechs had to build before scale, and something their sponsor banks had to check.

    • Financial Services
    • Regulation & Compliance
    • 5 min read

May 2022

  1. Week of 9 May 2022

    Stable is a claim: what TerraUSD asked of bank front lines

    Few banks held TerraUSD, but its collapse reached them through customers: scams riding on the losses, disputes over transfers customers had authorized, and confusion about which products near a deposit were actually protected.

    • Financial Services
    • Customer & Citizen Experience
    • 5 min read

July 2022

  1. Week of 4 July 2022

    Rogers: the bank outage that started at someone else’s carrier

    When one Canadian carrier failed for most of a day, debit payments failed nationwide, including for banks that never bought a Rogers circuit. Telecom dependency hides in three places a bank’s dual-carrier policy does not reach: shared payment utilities, thinly connected channels, and customers’ phones.

    • Financial Services
    • Security & Resilience
    • 5 min read

August 2022

  1. Week of 8 August 2022

    Tornado Cash and the transfers nobody asked for

    Sanctioning a mixer’s smart contracts meant sanctioned funds could arrive uninvited, and the parties a bank would normally screen did not exist. Sanctions programs touching crypto had to handle unsolicited receipts, exposure several hops away, and a designation under legal attack.

    • Financial Services
    • Regulation & Compliance
    • 5 min read

September 2022

  1. Week of 19 September 2022

    What a stolen license number proves, and what banks treated it as proving

    The Optus breach put millions of identity document numbers in criminals’ hands. Banks had used those numbers as proof of identity at account opening, in the contact center and in their own files. Each use needed a different fix.

    • Financial Services
    • Customer & Citizen Experience
    • 5 min read
  2. Week of 26 September 2022

    Recordkeeping fails where the approved channel is slower than a text

    The SEC and CFTC fined large Wall Street firms over employees’ business texts on personal phones. The rules were old and capture tools existed. The failures came from convenience, and fixing them meant channels, supervision and capture assurance moving together.

    • Financial Services
    • Operations & Workforce
    • 5 min read

October 2022

  1. Week of 17 October 2022

    If the CFPB’s funding fell, the statutes would still stand

    A federal appeals court called the consumer bureau’s funding unconstitutional, and for eighteen months every CFPB rule carried a question mark. Compliance teams had to sort the bureau’s past orders, current rules and pending rules, because each faced a different risk.

    • Financial Services
    • Regulation & Compliance
    • 5 min read
  2. Week of 24 October 2022

    For credit unions, the 1033 outline was a question for the core processor

    The CFPB’s first open banking outline opened a small business review. For small banks and credit unions, compliance would arrive as a product from their core and digital banking vendors, so their decisions were about coverage, cost and contracts.

    • Financial Services
    • Economics & Procurement
    • 5 min read

November 2022

  1. Week of 7 November 2022

    Who checked the people who moved FTX’s money

    FTX’s banks, investors and partners had studied its growth. Few had asked three plain governance questions: who can move the money, who checks them, and whose money it is. Financial institutions can ask those questions of every fast-growing counterparty.

    • Financial Services
    • Economics & Procurement
    • 5 min read

December 2022

  1. Week of 12 December 2022

    FTX’s favored account was a setting in the code, and banks have settings too

    The FTX charges described control failures that regulated firms believe they solved long ago. What made them possible was a small engineering group able to change how the platform treated one account. Banks and broker-dealers now run their own controls the same way.

    • Financial Services
    • Operations & Workforce
    • 5 min read

January 2023

  1. Week of 2 January 2023

    Few banks held crypto. Many held crypto deposits.

    The January 2023 joint statement was read as a verdict on what banks could do with crypto. Its sharper warning was about exposure banks already had through depositors, partners and customers, which most could not measure from their own data.

    • Financial Services
    • Regulation & Compliance
    • 5 min read
  2. Week of 16 January 2023

    DORA’s two-year runway, measured in contract renewals

    DORA gave EU financial firms two years to comply, with no carve-out for existing ICT contracts. For most firms the binding constraint was not policy writing or testing but the calendar on which they could reopen agreements with technology providers.

    • Financial Services
    • Economics & Procurement
    • 5 min read
  3. Week of 30 January 2023

    ION’s outage exposed a vendor no board had on its critical list

    The ransomware attack on ION’s cleared derivatives software showed that sector-wide disruption often starts at specialized post-trade vendors that many firms share and few rank as critical. Finding them, grading them and rehearsing life without them are three separate jobs.

    • Financial Services
    • Security & Resilience
    • 5 min read

February 2023

  1. Week of 20 February 2023

    Banks blocked ChatGPT over leaks; recordkeeping set the longer limit

    When large banks restricted ChatGPT, the stated worry was confidential data leaving the firm. That problem yielded to contracts within a year. The obligations to keep and supervise records, and to explain decisions, set the slower pace of adoption.

    • Financial Services
    • Data & AI
    • 5 min read

March 2023

  1. Week of 6 March 2023

    SVB’s depositors learned their bank was an unassessed supplier

    Silicon Valley Bank is remembered as a liquidity and supervision failure. For the fintechs, broker-dealers and companies that banked there, it was a supplier failure: cash, payment flows and dependent services all ran through one provider nobody had assessed as critical.

    • Financial Services
    • Economics & Procurement
    • 5 min read
  2. Week of 13 March 2023

    Three SEC cyber proposals, three audiences, one rule adopted

    Amid the bank failures, the SEC proposed a cyber rule for market entities, amendments to Regulation S-P and a wider Regulation SCI on one day. Each answered a different audience: the regulator, the customer and the market. Only the customer rule was adopted.

    • Financial Services
    • Regulation & Compliance
    • 5 min read

May 2023

  1. Week of 1 May 2023

    First Republic’s white-glove service had no answer for an uninsured balance

    First Republic’s clients were loyal until the question became whether money above the insurance limit was safe. In a confidence crisis, client experience means three capabilities most banks lacked: seeing each client’s insured position, changing it fast, and saying something specific.

    • Financial Services
    • Customer & Citizen Experience
    • 5 min read

July 2023

  1. Week of 3 July 2023

    Before the bias audit, the inventory: what New York City’s hiring-tool law asked of employers

    New York City’s Local Law 144 made bias audits the headline. For banks, insurers and asset managers hiring in the city, the harder prerequisite was finding every tool that scores candidates, deciding which were in scope, and naming an owner for each.

    • Financial Services
    • Operations & Workforce
    • 5 min read
  2. Week of 17 July 2023

    Why FedNow was a core-processor decision for community banks and credit unions

    The Federal Reserve’s instant payment service went live in July 2023. For community banks and credit unions, joining turned on what their core processor could do in real time, all year round, and on fraud controls for payments that cannot be recalled.

    • Financial Services
    • Platforms & Architecture
    • 5 min read

August 2023

  1. Week of 7 August 2023

    After Moody’s downgrades, regional bank technology had to argue in unit costs

    Moody’s August 2023 rating actions confirmed that the spring’s bank stress would become a lasting earnings squeeze. Regional bank technology budgets had to be defended in the CFO’s terms: cost per account, faster liquidity data, and vendor contracts priced for a smaller margin.

    • Financial Services
    • Economics & Procurement
    • 5 min read
  2. Week of 21 August 2023

    Triage for a rule that might not survive: the SEC’s private fund adviser package

    The private fund adviser rules adopted in August 2023 were vacated ten months later. Advisers that sorted the work into what investors would demand, what existing law already required and what only the rule required spent little that was wasted.

    • Financial Services
    • Regulation & Compliance
    • 5 min read

September 2023

  1. Week of 11 September 2023

    For banks, the MGM and Caesars intrusions were about the few accounts that run the identity platform

    The September 2023 casino attacks used help desk calls to reach identity administrators. For banks, the priority was a small set of control-plane accounts: how they are recovered, who is allowed to recover them, and how a takeover of the identity platform would be spotted.

    • Financial Services
    • Security & Resilience
    • 5 min read

October 2023

  1. Week of 16 October 2023

    Free, measured and always on: the open banking interface the CFPB proposed and banks could not price

    The October 2023 Section 1033 proposal turned a bank’s data interface into a service with performance targets and no access fees. For banks and credit unions, the questions were what they had to deliver, what they could not recover, and what they still controlled.

    • Financial Services
    • Economics & Procurement
    • 5 min read

November 2023

  1. Week of 6 November 2023

    Three seats at ICBC’s ransomware attack, and the plan each one needed

    When LockBit hit ICBC’s U.S. broker-dealer in November 2023, Treasury trades still had to settle. Every market participant could have been in any of three seats, and each seat needed a different plan written before the day.

    • Financial Services
    • Security & Resilience
    • 5 min read
  2. Week of 13 November 2023

    A credit union’s first report of a vendor breach may come from the attacker

    When ALPHV publicized its SEC complaint against MeridianLink in November 2023, the vendor’s bank and credit union customers faced their own notification questions with only an attacker’s claim and a vendor statement to go on. Their work split into facts, regulators and customers.

    • Financial Services
    • Regulation & Compliance
    • 5 min read

January 2024

  1. Week of 15 January 2024

    Major incident, by formula: DORA’s first standards moved the call from judgment to data

    DORA’s January 2024 standards defined a major ICT incident as a calculation over clients, transactions, downtime, data and cost. Banks that left those inputs outside their incident tooling could not classify on time, however good their playbooks.

    • Financial Services
    • Regulation & Compliance
    • 5 min read

February 2024

  1. Week of 12 February 2024

    Convincing faces, unauthenticated seats: the Hong Kong deepfake was a meeting-identity failure

    The deepfaked video call that moved about US$25 million beat a meeting, not a payment system. Most firms let staff treat a face on screen as identity. Banks need controls at the invitation, inside the meeting, and at the handoff to money.

    • Financial Services
    • Security & Resilience
    • 5 min read

March 2024

  1. Week of 11 March 2024

    Why the AI Act left bank credit models with the supervisor they already had

    The AI Act text adopted in March 2024 routed high-risk credit scoring through banking supervision and let existing governance satisfy some duties. For banks, the work was separating what model risk management already met from what it never covered.

    • Financial Services
    • Data & AI
    • 5 min read

May 2024

  1. Week of 13 May 2024

    The vendor clock: amended Regulation S-P rests on a 72-hour promise someone else makes

    The SEC’s 2024 Regulation S-P amendments gave customers a 30-day breach notice and required service providers to report within 72 hours. For broker-dealers and advisers whose customer data sits mostly with vendors, that second clock decides how well the first one works.

    • Financial Services
    • Regulation & Compliance
    • 5 min read
  2. Week of 27 May 2024

    Snowflake’s stolen logins put the contractor’s laptop inside the bank’s perimeter

    The 2024 campaign against Snowflake customers broke no platform. It used passwords stolen from infected machines, often contractors’, and walked out with bulk data. Each stage, from theft to login to extraction, was a control point the customer owned.

    • Financial Services
    • Platforms & Architecture
    • 5 min read

June 2024

  1. Week of 10 June 2024

    Why banking-as-a-service margins never covered the cost of knowing whose money it was

    The Fed’s order against Evolve showed that sponsor-bank revenue grew with balances while the costs of reconciliation, oversight and partner failure grew with the number of programs. Banks that priced only the first side carried the second.

    • Financial Services
    • Economics & Procurement
    • 5 min read

July 2024

  1. Week of 8 July 2024

    A credit union’s promises in an outage are set by its architecture, years before the attack

    Patelco’s members met its ransomware attack as four questions: can I use my money, what happened to my data, how do I get back in, who pays. Each answer was largely fixed by design and policy choices made long before June 2024.

    • Financial Services
    • Customer & Citizen Experience
    • 6 min read

August 2024

  1. Week of 5 August 2024

    How the August 2024 selloff found brokerages’ capacity limit before the first trade

    On August 5, 2024, customers of large retail brokerages struggled to log in and see balances. The strain sat in the pre-trade path, in three layers with different owners: identity checks, account views and shared vendors. No rule set the target.

    • Financial Services
    • Platforms & Architecture
    • 5 min read

October 2024

  1. Week of 14 October 2024

    NYDFS wrote no AI rule, and made AI risk part of what the CEO certifies

    New York’s October 2024 letter on AI and cybersecurity added no requirements. Because Part 500 already demands an annual compliance certification signed by the CEO and CISO, it turned four AI risks into evidence those signers must be able to produce.

    • Financial Services
    • Security & Resilience
    • 5 min read
  2. Week of 21 October 2024

    Final and already in court: sorting open banking work by how much you would regret it

    The CFPB’s Section 1033 rule was sued the day it was issued. Banks could not wait out the litigation or comply blindly. The workable approach was to split the program into no-regret work, rule-specific work and work hinging on the contested terms.

    • Financial Services
    • Platforms & Architecture
    • 5 min read

November 2024

  1. Week of 11 November 2024

    FinCEN’s deepfake alert was a job-design problem for three groups of staff

    FinCEN’s November 2024 alert read like a list of red flags for compliance teams. Its harder implication was for the people whose jobs let them act on recognition: onboarding reviewers, service agents and payment operators each needed new decision rights, incentives and escalation paths.

    • Financial Services
    • Operations & Workforce
    • 5 min read
  2. Week of 18 November 2024

    The CFPB reached for payment apps while the customer’s money sat at partner banks

    The larger-participant rule gave federal examiners access to big payment apps and lasted under six months. With Synapse’s collapse fresh, the more durable exposure sat elsewhere: in the law apps already owed and in the banks holding their customers’ funds.

    • Financial Services
    • Regulation & Compliance
    • 5 min read

December 2024

  1. Week of 16 December 2024

    CISA’s encryption advice and the SEC’s recordkeeping cases asked for the same channel

    After the Salt Typhoon telecom intrusions, CISA told targeted people to use end-to-end encrypted messaging, just as off-channel penalties weighed on broker-dealers. The two demands conflict only on channels the firm does not control. An approved channel must be encrypted, captured and usable.

    • Financial Services
    • Regulation & Compliance
    • 5 min read

January 2025

  1. Week of 13 January 2025

    DORA’s register of information made every bank a data supplier to EU oversight of its vendors

    DORA’s register of ICT third-party arrangements looked like paperwork. It was a dataset supervisors would aggregate to find concentration and designate critical providers, so its quality rested on three data problems most vendor programs had never solved: identity, dependency and depth.

    • Financial Services
    • Economics & Procurement
    • 5 min read

February 2025

  1. Week of 10 February 2025

    With the CFPB paused, banks lost the outside signals their customer programs relied on

    The February 2025 stop-work order did not change consumer law. It removed three things the Bureau had supplied to firms almost for free: exam deadlines that forced fixes, published findings about peers, and federal follow-up on complaints. Firms had to replace each themselves.

    • Financial Services
    • Customer & Citizen Experience
    • 5 min read
  2. Week of 17 February 2025

    Bybit’s signers approved what their screens showed, which was not what they signed

    The largest crypto theft on record defeated multi-signature approval without breaking it, by altering the interface the signers trusted. Banks approving payments through software face the same risk at four points: how the interface is built, what approvers see, how payments are verified, and recovery.

    • Financial Services
    • Security & Resilience
    • 5 min read

April 2025

  1. Week of 7 April 2025

    Supervisory correspondence: a bank’s most candid file, held in a system it cannot assess

    The OCC’s email breach showed that a bank’s frankest account of its own weaknesses sits with a regulator it cannot audit or replace. Banks still control what they write, how it travels, and how they respond to a breach.

    • Financial Services
    • Security & Resilience
    • 5 min read
  2. Week of 21 April 2025

    A new SEC chair rewrites the agenda, not the compliance calendar

    Paul Atkins arrived at the SEC promising a lighter touch. For broker-dealers and advisers, what mattered was each rule’s legal status: proposals could vanish quickly, adopted rules kept their dates, and examinations kept running.

    • Financial Services
    • Regulation & Compliance
    • 5 min read
  3. Week of 28 April 2025

    Iberia’s blackout put payment resilience back at the shop counter

    When the Iberian grid failed in April 2025, bank systems largely held and customers still could not pay. Payment resilience is set at the terminal, the network link, the offline rules and the cash fallback, and banks can shape all four.

    • Financial Services
    • Customer & Citizen Experience
    • 5 min read

May 2025

  1. Week of 12 May 2025

    Cheap contracts, valuable access: the market behind Coinbase’s bribed agents

    Coinbase’s May 2025 disclosure showed criminals buying data from outsourced support staff who could already see it. Insider risk in support operations behaves like a market, and financial institutions set its terms through how they buy and govern outsourced labor.

    • Financial Services
    • Operations & Workforce
    • 5 min read

June 2025

  1. Week of 9 June 2025

    Google Cloud’s June outage moved bank cloud diligence from uptime to change safety

    Google Cloud’s June 2025 outage started with a routine policy update that reached every region at once. Banks learn more from asking how a provider releases code and configuration than from its uptime commitment.

    • Financial Services
    • Platforms & Architecture
    • 5 min read
  2. Week of 16 June 2025

    Why Scattered Spider’s turn to insurers should have set a deadline for the rest of finance

    When a group that works one industry at a time reached U.S. insurers in June 2025, threat intelligence turned into a date. Institutions needed a pre-agreed surge mode: a named trigger, tighter help-desk rules for weeks, and containment planned around compromised identity.

    • Financial Services
    • Security & Resilience
    • 5 min read

August 2025

  1. Week of 18 August 2025

    How a fee question pulled open banking off the rulebook and onto the rate card

    By asking whether banks may charge for data access, the CFPB’s August 2025 notice shifted open banking terms from regulation into contracts. Large banks could set prices, smaller institutions would inherit them through vendors, and data users would have to redesign around them.

    • Financial Services
    • Economics & Procurement
    • 5 min read

September 2025

  1. Week of 1 September 2025

    The CAT’s retirement freed the framework and orphaned the risk profile

    When the FFIEC retired its Cybersecurity Assessment Tool on August 31, 2025, attention went to picking a replacement framework. The harder loss was the inherent risk profile, the step that told a bank how much security it needed.

    • Financial Services
    • Regulation & Compliance
    • 5 min read
  2. Week of 8 September 2025

    Why bank change control never saw the npm hijack

    Malicious versions of widely used JavaScript packages were live for about two hours in September 2025. Bank change control approves code people write; this attack arrived in code the build pipeline fetched on its own, which nobody approves.

    • Financial Services
    • Platforms & Architecture
    • 5 min read

October 2025

  1. Week of 20 October 2025

    One region failed, many financial apps stalled: concentration risk sat in the dependencies

    The October 2025 us-east-1 outage hit financial apps whose own designs looked resilient. The exposure lay in shared services and recovery backlogs, so the response is dependency mapping and tested degraded modes, not reflexive multi-cloud.

    • Financial Services
    • Platforms & Architecture
    • 5 min read
  2. Week of 27 October 2025

    NYDFS’s final Part 500 deadline put the asset inventory underneath every other control

    New York’s last amended cybersecurity deadline, November 1, 2025, paired universal MFA with a maintained asset inventory. MFA drew the attention. The inventory was harder, and the executive certification made both personal.

    • Financial Services
    • Regulation & Compliance
    • 5 min read

November 2025

  1. Week of 17 November 2025

    For EU consumer lenders, the credit-scoring deadline that mattered was never the AI Act’s

    The Commission’s proposal to delay high-risk AI obligations looked like relief for credit scoring. For consumer lenders, the binding constraints were the GDPR as the EU’s top court had read it and the Consumer Credit Directive’s November 2026 date.

    • Financial Services
    • Data & AI
    • 5 min read
  2. Week of 24 November 2025

    SitusAMC turned a mid-tier mortgage vendor into a top-tier bank exposure

    The SitusAMC breach reached some of the largest U.S. banks through a real estate finance services provider. Vendor tiering built on spend and operational criticality missed a firm that held sensitive data for many institutions at once.

    • Financial Services
    • Economics & Procurement
    • 5 min read

December 2025

  1. Week of 1 December 2025

    Under Regulation S-P, the firm that knows least about a breach tells the most customers

    When the amended Regulation S-P took effect for larger firms on December 3, 2025, notice became the default. Whether a firm could notify narrowly depended on evidence it had to keep before any incident.

    • Financial Services
    • Regulation & Compliance
    • 5 min read
  2. Week of 15 December 2025

    Crypto trust charters and community banks: the binding decision sits in the core

    The OCC’s conditional charters made federally supervised digital-asset custodians a realistic option for smaller banks and credit unions. The harder decision was how any of it would reconcile to the general ledger, statements and reports their core platforms produce.

    • Financial Services
    • Platforms & Architecture
    • 5 min read

January 2026

  1. Week of 19 January 2026

    The easiest part of a card rate cap is cutting the rate

    The proposed 10% cap on credit card interest had no legal mechanism, and January 20 passed without one. For issuers, the episode showed that the customer and compliance risk of any cap lies in the offsetting changes, not in the rate itself.

    • Financial Services
    • Customer & Citizen Experience
    • 5 min read

March 2026

  1. Week of 2 March 2026

    Iran’s war tested banks’ decision rights more than their defenses

    The cyber warnings after the strikes on Iran named old techniques banks knew how to stop. The harder test was deciding, amid market stress and thin federal support, what to fix first, who could break a change freeze, and what to demand of providers.

    • Financial Services
    • Security & Resilience
    • 5 min read

April 2026

  1. Week of 6 April 2026

    When AI made flaws cheap to find, banks’ patch queues set the pace

    Few banks had access to the model officials warned them about. For most, faster AI-driven discovery would arrive as a surge of fixes from vendors and open-source maintainers, so the constraint was how fast they could absorb patches.

    • Financial Services
    • Security & Resilience
    • 5 min read

May 2026

  1. Week of 18 May 2026

    Searching by balance: how bribed bank insiders choose their targets

    Bank insider cases prosecuted in 2026 show bribed employees selling three things: the search that finds valuable customers, the screens that expose them, and the overrides that open doors. Each can be controlled without first catching the insider.

    • Financial Services
    • Security & Resilience
    • 5 min read
  2. Week of 25 May 2026

    Faster settlement, longer nights: what two years of T+1 tell Europe’s operations desks

    The US move to one-day settlement held because firms automated trade-date matching and redesigned who works when. Europe and the UK move in October 2027, and the shift pattern and funding model will be harder to build than the software.

    • Financial Services
    • Operations & Workforce
    • 5 min read

June 2026

  1. Week of 1 June 2026

    For a small adviser, Regulation S-P compliance is bought before the breach

    When amended Regulation S-P reached smaller advisers and broker-dealers on June 3, 2026, most of them had no in-house incident team. For them, compliance is a set of purchases made in advance: response capacity, evidence and the means to notify.

    • Financial Services
    • Economics & Procurement
    • 6 min read
  2. Week of 22 June 2026

    Why Europe’s accessibility law turns every bank release into evidence

    A year after the European Accessibility Act began to apply, banks serving EU consumers have learned that conformance decays with every release, template change and vendor update. The durable answer is a running body of evidence across four parts of the service.

    • Financial Services
    • Customer & Citizen Experience
    • 5 min read

July 2026

  1. Week of 13 July 2026

    Fedwire’s ISO 20022 switch gave banks rich payment data their core systems still truncate

    A year after Fedwire moved to ISO 20022, the structured message reached most US banks intact. Its value did not, because data was lost at origination, inside banks’ own systems, or in screening and fraud tools never set up to use it.

    • Financial Services
    • Data & AI
    • 5 min read
  2. Week of 20 July 2026

    Stablecoin rules late, statutory clock on time: the GENIUS Act’s awkward first year

    Regulators missed the GENIUS Act’s July 2026 rulemaking deadline, but the law’s January 2027 backstop date did not move. Banks could not wait for final text to decide which role to play, and the funding question cut across every choice.

    • Financial Services
    • Regulation & Compliance
    • 5 min read

August 2026

  1. Week of 31 August 2026

    Bank cyber gaps now arrive as observations the board never has to see

    The OCC and FDIC limited matters requiring attention to material financial harm, a year after the FFIEC retired its common cyber assessment. Many cyber weaknesses will now reach banks as informal observations, so banks must set their own escalation rules.

    • Financial Services
    • Security & Resilience
    • 5 min read