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Month: November 2018

November 30, 2018May 26, 2019

Bucksnort, Marijuana, Thresholds, and “a little bit of tension”​ … Senate Banking Committee and BSA/AML

AML Regulations and Enforcement Actions by Jim Richards0 comments

https://www.banking.senate.gov/hearings/10/24/2018/combating-money-laundering-and-other-forms-of-illicit-finance-regulator-and-law-enforcement-perspectives-on-reform From obvious tension between FinCEN and the OCC, to patiently waiting for marijuana guidance, to missteps on CTR filings […]

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November 19, 2018May 26, 2019

Crypto ICOs, Cannabis, Beauty Queens, and Russian Technocrats

Crypto & Blockchain by Jim Richards0 comments

On November 16, 2018 the SEC settled an unregistered ICO case with the issuer, Paragon Coin. See https://www.sec.gov/litigation/admin/2018/33-10574.pdf. It doesn’t get […]

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November 19, 2018May 26, 2019

The Strip Club – Is Membership Now Closed?

AML Regulations and Enforcement Actions by Jim Richards0 comments

With today’s announcements from the US Attorney for the Southern District of New York, OFAC, Federal Reserve, New York State […]

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Central Bank Digital Currency?
November 15, 2018May 26, 2019

Central Bank Digital Currency?

Crypto & Blockchain by Jim Richards0 comments

Christine Largarde, Managing Director of the IMF, introduced the concept of a Central Bank Digital Currency, in a speech at […]

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Recent Posts

  • Richards Comments on Proposed Beneficial Ownership Access Rule – December 2022
  • BSA, Bittner, and FBARs – Forty Questions from The Supremes
  • Beneficial Ownership Database – Now That We Know What Goes In, Let’s Turn to What Will Come Out
  • Beneficial Ownership Information Reporting – Will it Reduce Financial Crimes?
  • BSA/AML Policies and Procedures – What Can We Learn From Mary Berra and the Founding Fathers?

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