Jonathan V. Gould

Rule Changes

Leads OCC's GENIUS Act rulemaking

The Office of the Comptroller of the Currency published its GENIUS Act stablecoin rule in the Federal Register on October 23. From January 18, 2027, a company must be approved as a permitted issuer before it can issue a dollar-backed payment token in the United States.

Updated Oct 26

Rule Changes

Announced the OCC's cease-and-desist order and $350 million penalty against American Express National Bank on October 8, 2026

American Express National Bank agreed to pay a $350 million fine and overhaul its anti-money-laundering program after regulators found it processed roughly $13 billion in suspected trade-based money laundering from June 2014 to May 2025. The Office of the Comptroller of the Currency (OCC) issued a cease-and-desist order against the bank, while the Federal Reserve ordered parent companies American Express Co. and American Express Travel Related Services to fix financial-crimes risk management company-wide.

Updated Oct 25

Rule Changes

Named defendant in the ICBA lawsuit

A trade group for community banks sued the U.S. banking regulator on Oct. 2 over federal trust charters granted to crypto firms. The Independent Community Bankers of America says the Office of the Comptroller of the Currency has exceeded its authority under the National Bank Act.

Updated Oct 21

Rule Changes

As of May 2026: Leading federal investigation into bank debanking practices

Donald Trump banked with JPMorgan Chase for decades; after the January 6 Capitol attack, the bank gave him 60 days to move hundreds of millions of dollars. As sitting president, he's suing the bank and its CEO for $5 billion, alleging political discrimination.

Updated May 22

Rule Changes

As of May 2026: Regulator leading OCC’s withdrawal from leveraged-lending guidance

In March 2013, U.S. bank regulators issued joint supervisory guidance on leveraged lending to prevent a return of pre-2008-style underwriting excesses, with examiners informally anchoring scrutiny around a roughly six-times-EBITDA leverage benchmark. Over the next decade, banks' pullback shifted riskier deal finance toward private-credit funds, CLOs, and other nonbanks—expanding an opaque "shadow banking" ecosystem even as regulators maintained the guidance was supervisory, not a binding rule.

Updated May 9