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Month: April 2020

April 27, 2020April 28, 2020

FinCEN’s Marijuana-Related SAR Data: By Not Including MSBs, Are We Under-Reporting Marijuana Businesses’ Access to Financial Services?

Cannabis/Marijuana by Jim Richards0 comments

Marijuana-Related Businesses may have greater access to financial services than is being reported, even if those services aren’t being provided […]

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April 25, 2020April 25, 2020

Sponge Bob Square Pants, Alan Greenspan, Elton John, PPP Loans, and a Limited Safe Harbor

General Business, Risk, and Life by Jim Richards0 comments

On April 23rd the Treasury Department added a 31st question and answer to its series of Paycheck Protection Program (PPP) […]

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April 22, 2020April 22, 2020

BSA/AML Compliance Programs are Important, but Providing Timely, Actionable Intelligence to Law Enforcement Should be the Goal

Money Laundering & Terrorist Financing - General by Jim Richards0 comments

Eighteen months ago I called for a renewal of the original purpose of the Bank Secrecy Act: with recent changes […]

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April 22, 2020April 22, 2020

Dusting off the Congressional Version of an “Aged Shelf Company”

General Business, Risk, and Life by Jim Richards0 comments

On April 21, 2020, the United States Senate resolved “that the bill from the House of Representatives (H.R. 266) entitled […]

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April 18, 2020April 18, 2020

“Money Laundering/Terrorist Financing and Other Illicit Financial Activity” – a New BSA/AML Focus?

Money Laundering & Terrorist Financing - General by Jim Richards0 comments

If this is, in fact, a new standard for the assessment of U.S. financial institutions’ BSA/AML compliance programs, then I […]

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April 16, 2020April 17, 2020

The US BSA/AML Regime – Have We Just Gone From Aspiring to be “Effective” to Merely Being “Adequate”?

RegTech by Jim Richards0 comments

On April 15, 2020, federal and state banking agencies updated parts of the BSA/AML Examination Manual (“Manual”), a document that […]

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April 15, 2020April 15, 2020

CARES Act and PPP Loans – Has the SBA Actually “Approved” Any PPP Loans? Or Are Its Deputies Doin’ All the Approvin’?

General Business, Risk, and Life by Jim Richards0 comments

The Small Business Administration (SBA) has announced that as of April 15th it had “approved” about 1,300,000 Paycheck Protection Program […]

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April 14, 2020April 19, 2020

5 + 4 = 6 … Treasury’s New PPP Math Is Creating Unnecessary Confusion, & Here’s a Proposed Solution

Beneficial Ownership & Customer Due Diligence by Jim Richards0 comments

I’ve written two articles on the CARES Act’s Paycheck Protection Program (PPP) – the $350 billion, or $350,000,000,000, pot of […]

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April 7, 2020April 19, 2020

CARES Act PPP Loans – Is There A Loan “Dead Zone”?

General Business, Risk, and Life by Jim Richards0 comments

The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) was signed into law by the President on March 27, […]

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April 7, 2020April 13, 2020

The CARES Act and the Paycheck Protection Program – We Know A Surge of Fraud is Coming, Let’s Prevent it Now

Beneficial Ownership & Customer Due Diligence by Jim Richards0 comments

SBA’s disaster loan programs suffer increased vulnerability to fraud and unnecessary losses when loan transactions are expedited to provide quick […]

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