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Month: December 2018

December 27, 2018May 26, 2019

“Extraordinary workloads” and “extraordinary steps” – What can we learn from these phrases? Unfortunately, not much

AML Regulations and Enforcement Actions by admin0 comments

The most recent AML-related public censure comes in the form of a FINRA “AWC” or Letter of Acceptance, Waiver and […]

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December 27, 2018May 26, 2019

2005 Banking Agencies’ MSB Guidance = 2019 Banking Agencies’ MRB Guidance?

Cannabis/Marijuana by admin0 comments

Here’s an idea to jump start the US banking agencies’ (inevitable) guidance on providing banking services for marijuana related businesses […]

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December 21, 2018May 26, 2019

CFTC Primer on “Smart Contracts” … which apparently aren’t necessarily “smart”

FinTech, Financial Crimes, and Risk Management by admin0 comments

The Commodity Futures Trading Commission (CFTC) recently published an excellent primer on Smart Contracts. I’ve reproduced most of the primer […]

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December 20, 2018May 26, 2019

Rules-Based Monitoring, Alert to SAR Ratios, and False Positive Rates – Are We Having The Right Conversations?

FinTech, Financial Crimes, and Risk Management by admin0 comments

There is a lot of conversation in the industry about the inefficiencies of “traditional” rules-based monitoring systems, Alert-to-SAR ratios, and […]

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December 20, 2018May 26, 2019

FinCrime FinTech Hype, Hubris, and Subject Matter Enthusiasm

FinTech, Financial Crimes, and Risk Management by admin0 comments

Two very recent fincrime fintech start-ups recently published marketing papers – one a self-styled “Report” the other a blog – […]

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December 14, 2018July 22, 2021

Flipping the Three AML Ratios with Machine Learning and Artificial Intelligence (why Bartenders and AML Analysts will survive the AI Apocalypse)

FinTech, Financial Crimes, and Risk Management by admin0 comments

Machine Learning and Artificial Intelligence proponents are convinced – and spend a lot of time trying to convince others – […]

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December 8, 2018May 26, 2019

Medical Marijuana – the DOJ Won’t Come Knocking … but Recreational Marijuana? Perhaps not so lucky …

Cannabis/Marijuana by admin0 comments

The November 29, 2018 US Tax Court decision in the Harborside case provides some excellent background on the state versus […]

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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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