Marijuana-Related Businesses may have greater access to financial services than is being reported, even if those services aren’t being provided […]
Month: April 2020
Sponge Bob Square Pants, Alan Greenspan, Elton John, PPP Loans, and a Limited Safe Harbor
On April 23rd the Treasury Department added a 31st question and answer to its series of Paycheck Protection Program (PPP) […]
BSA/AML Compliance Programs are Important, but Providing Timely, Actionable Intelligence to Law Enforcement Should be the Goal
Eighteen months ago I called for a renewal of the original purpose of the Bank Secrecy Act: with recent changes […]
Dusting off the Congressional Version of an “Aged Shelf Company”
On April 21, 2020, the United States Senate resolved “that the bill from the House of Representatives (H.R. 266) entitled […]
“Money Laundering/Terrorist Financing and Other Illicit Financial Activity” – a New BSA/AML Focus?
If this is, in fact, a new standard for the assessment of U.S. financial institutions’ BSA/AML compliance programs, then I […]
The US BSA/AML Regime – Have We Just Gone From Aspiring to be “Effective” to Merely Being “Adequate”?
On April 15, 2020, federal and state banking agencies updated parts of the BSA/AML Examination Manual (“Manual”), a document that […]
CARES Act and PPP Loans – Has the SBA Actually “Approved” Any PPP Loans? Or Are Its Deputies Doin’ All the Approvin’?
The Small Business Administration (SBA) has announced that as of April 15th it had “approved” about 1,300,000 Paycheck Protection Program […]
5 + 4 = 6 … Treasury’s New PPP Math Is Creating Unnecessary Confusion, & Here’s a Proposed Solution
I’ve written two articles on the CARES Act’s Paycheck Protection Program (PPP) – the $350 billion, or $350,000,000,000, pot of […]
CARES Act PPP Loans – Is There A Loan “Dead Zone”?
The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) was signed into law by the President on March 27, […]
The CARES Act and the Paycheck Protection Program – We Know A Surge of Fraud is Coming, Let’s Prevent it Now
SBA’s disaster loan programs suffer increased vulnerability to fraud and unnecessary losses when loan transactions are expedited to provide quick […]