“Operationalizing the provisions of the Bank Secrecy Act and USA PATRIOT Act has been and continues to be a complex […]
Month: April 2018
Beneficial Ownership is less than a month away
I’m predicting some chaos, lots of gnashing of teeth and wringing of hands, Media and Social Media !WTF?! and Congressional !Calls to […]
Update on Backpage.com seizure and indictment
The Department of Justice has posted the Backpage.com indictment (https://www.justice.gov/file/1050276/download), a 93-count indictment against the seven individuals who ran Backpage.com […]
Backpage.com has been seized!
Following on the Senate Permanent Subcommittee on Investigation’s January 2017 report titled “Backpage.com’s Knowing Facilitation of Online Sex Trafficking”, it […]
FinCEN publishes FAQs on the new Customer Due Diligence/Beneficial Ownership Rule
FinCEN published the long-awaited, and much-anticipated, FAQs on the new customer due diligence/beneficial ownership rule, which comes into effect on […]
Ninth Circuit rules that the FFIEC BSA/AML Examination Manual has the force of regulation!
Upsetting the long-held belief that legislation is clarified by regulations that are clarified and explained by written guidance and modified […]