Bad actors and nation states, such as China and Russia, are becoming more proficient in using our financial system to […]
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Capital One’s $390,000,000 BSA/AML Penalty – Are We Asking the Right Questions?
Supervision [of banks] happens behind closed doors. It relies upon secrecy and involves a system of discretionary actions by supervisory […]
Measuring Illicit Financial Flows – Getting Closer to a True Estimate of Global Money Laundering
Over $1 trillion is laundered globally every year, and less than one per cent is seized. Where do these numbers […]
The Corporate Transparency Act of 2020 … The Good, The Bad, and the Ugly
Corporate Transparency Act – There’s much that is Good, but there’s also some things that are Bad and other things […]
314(b) Information Sharing – a Valuable, but Underutilized Tool
The AML Act of 2020 doesn’t directly change the voluntary information sharing provisions set out in section 314(b) of the […]
AML Act of 2020: Renewing America’s AML/CFT Regime
Executive Summary of the AML Act of 2020 On December 3, 2020 the Senate and House jointly issued a Conference […]
FinCEN’s Proposed AML Program Effectiveness Rule – Comments of RegTech Consulting LLC
The following comments to FinCEN’s Advance Notice of Proposed Rule Making (ANPRM) on AML Program Effectiveness were submitted by Jim […]
Biden or Trump? Possible Impacts of a New Administration on Financial Crimes Compliance
And does FinCEN have a 95 percent “false positive rate” it needs to address? The U.S. election is Tuesday, November […]
Don’t Blame FinCEN – Congress Has Left it Underfunded for Years
In the last five years, FinCEN’s workload has gone up three times as much as its budget: if we care […]
FinCEN Files – Reforming AML Regimes Through TSV SARs (Tactical or Strategic Value Suspicious Activity Reports)
The Public/Private AML Industry is Fifty Years Old and is Long Overdue for a Makeover: Let’s Start with Better Public […]