Disclaimer – I know better than to use these deceptive images of shiny, gold “bitcoins” – see for example my […]
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Richards Comments on FinCEN’s Request For Information on Reforming the BSA/AML Regime
On December 14, 2021 FinCEN published a Request For Information (RFI) soliciting comments on ways to modernize the risk-based AML/CFT […]
Beneficial Ownership Information Reporting Requirements – Richards Comments on FinCEN’s Proposed Rule
Re: Beneficial Ownership Information Reporting Requirements, Anti-Money Laundering Act of 2020 Notice of Proposed Rule Making, Docket Number FINCEN-2021-0005 and […]
FinCEN Exchange – Participants May Soon Be Fully Authorized!
The FinCEN Exchange has gone through two versions: the implied, pre-AML Act of 2020 version, and the codified, post-AML Act […]
Wyoming Shelf Companies are Flying Off the Shelf!
“A growing niche in the shell business is shelf corporations. Like paper-only shells, which enable the secrecy-minded to hide real […]
Disclaimers – If You’re Not Speaking For Your Institution, Why Am I Listening To You?
Disclaimer: The views expressed herein are my own and do not represent the views or opinions of my current or […]
OpenCorporates’ Database of 200 Million Global Companies – A Valuable Anti-Financial Crime Tool
The U.S. Treasury Department has tapped into the largest open database of companies in the world, but that database does […]
Crypto vs Fiat: Is One Or The Other More Of A Haven For Illicit Finance?
UPDATE: Since I published this article and posted it on LinkedIn about four hours ago, I’ve had many comments and […]
Effective AML Programs? How About Effective AML Laws and Regulations!
Demonstrating AML/CTF Effectiveness in the private sector requires (1) compliance with laws and regulations, (2) providing highly useful information to […]
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 […]