In the most uneventful of years, banks face intense scrutiny from a host of regulators with overlapping mandates. Following presidential elections in the United States, all industries brace for a shift of priorities. But few expected the seismic shakeup promised in 2021 by the Biden Administration, its Department of Justice, and other components of the federal government. These announcements have, deservedly, received substantial attention, and their impact on financial institutions is summarized below. But seemingly unnoticed—though potentially just as consequential to banks—are a pair of 2021 opinions from the Second Circuit, a court that by virtue of its jurisdiction has impacted businesses more than any other. The decisions, Kaplan v. Lebanese Canadian Bank and United States v. Turkiye Halk Bankasi A.S. (Halkbank), strip protection from foreign banks, open them to private lawsuits, and impose unprecedented due diligence requirements.