Lewis Roca Blog

In an effort to keep you apprised of the rapid developments surrounding COVID-19, we wanted to share with you further guidance on the Financial Services Sector Essential Critical Infrastructure Workers from the U.S. Department of the Treasury.  As always, please let us know how we can help you. Thank you.

The U.S. Department of the Treasury | Press Release |

March 22, 2020 
MEMORANDUM FOR FINANCIAL SERVICES SECTOR 
 

FROM: Secretary Steven T. Mnuchin
 

SUBJECT: Financial Services Sector Essential Critical Infrastructure Workers 
The financial services sector is identified as Critical Infrastructure Sector by the Department of Homeland Security (OHS). The attached OHS guidance, dated, March 19, 2020, identifies the essential critical infrastructure workers during the COVID-19 response emergency, and provides guidance to State and local officials as they work to protect their communities while ensuring continuity of critical functions to public health and safety, as well as economic and national security. 
 

Consistent with the President's guidelines, "if you work in a critical infrastructure sector, as defined by the Department of Homeland Security, you have a special responsibility to maintain your normal work schedule. " The Essential Critical Infrastructure Workforce for the financial services sector includes workers who are needed to process and maintain systems for processing financial transactions and services, such as payment, clearing and settlement services, wholesale funding, insurance services, and capital markets activities; to provide consumer access to banking and lending services, including A TMs, movement of currency ( e.g. armored cash carriers); support financial operations, such as those staffing data and security operations centers; and, key third party providers who deliver core services. These individuals are critical to maintaining safe and efficient financial services and ensuring citizens have access to these services that are necessary to conduct their daily lives.

Companies aligned to the essential critical infrastructure worker definition are expected to maintain their operations and work schedules. Everyone should follow guidance from the Centers for Disease Control and Prevention as well as State and local officials regarding strategies to limit disease spread. We are dedicated to working closely with all of you to ensure the safety of the workforce and ensure the continued operations of the financial services sector in support of our Nation's economy.

As issues surrounding COVID-19 are fluid and rapidly changing, the information in this alert should not be construed as legal advice. It is intended to provide information as it is currently available.

This material has been prepared by Lewis Roca Rothgerber Christie LLP for informational purposes only and is not legal advice. Readers should not act upon any information without seeking professional legal advice. Any communication you may have with a Lewis Roca Rothgerber Christie LLP, though this announcement or otherwise, should not be understood by you to be attorney-client communication unless and until you and the firm agree to enter into an attorney-client relationship.