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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 admin0 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 admin0 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 admin0 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 admin0 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

  • BSA, Bittner, and FBARs: the United States Supreme Court will soon decide, but does it have ALL the facts it needs?
  • $73 billion penalty? Or $18.25 million penalty? Or $118.25 million?
  • Can Cryptocurrencies be Physically Transported? U.S. Law Says “Yes” … But How Will US Regulations Implement that Law?
  • Richards Comments on FinCEN’s Request For Information on Reforming the BSA/AML Regime
  • Beneficial Ownership Information Reporting Requirements – Richards Comments on FinCEN’s Proposed Rule

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