Demonstrating AML/CTF Effectiveness in the private sector requires (1) compliance with laws and regulations, (2) providing highly useful information to […]
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PPP Round 2 – Why Will It Cost $6 billion More Than Round 1?
A couple of stealthy tweaks to the language in the rules for Round Paycheck Protection Program (PPP) loans will put […]
Bank Directors: What the Regulators, and Your Consultants, Aren’t Telling You About How to Satisfy Your AML/CFT Program Responsibilities
Fifteen Directors’ Tips In a recent LinkedIn post, a consulting firm published a blog titled “The Importance of a Board-level […]
Corporate Transparency Act: Shell Companies, Shelf Companies, and Front Companies (and SPACs)
Bad actors and nation states, such as China and Russia, are becoming more proficient in using our financial system to […]
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 […]