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Author: Jim Richards

December 20, 2018May 26, 2019

FinCrime FinTech Hype, Hubris, and Subject Matter Enthusiasm

FinTech, Financial Crimes, and Risk Management by Jim Richards0 comments

Two very recent fincrime fintech start-ups recently published marketing papers – one a self-styled “Report” the other a blog – […]

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December 14, 2018July 22, 2021

Flipping the Three AML Ratios with Machine Learning and Artificial Intelligence (why Bartenders and AML Analysts will survive the AI Apocalypse)

FinTech, Financial Crimes, and Risk Management by Jim Richards0 comments

Machine Learning and Artificial Intelligence proponents are convinced – and spend a lot of time trying to convince others – […]

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December 8, 2018May 26, 2019

Medical Marijuana – the DOJ Won’t Come Knocking … but Recreational Marijuana? Perhaps not so lucky …

Cannabis/Marijuana by Jim Richards0 comments

The November 29, 2018 US Tax Court decision in the Harborside case provides some excellent background on the state versus […]

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November 30, 2018May 26, 2019

Bucksnort, Marijuana, Thresholds, and “a little bit of tension”​ … Senate Banking Committee and BSA/AML

AML Regulations and Enforcement Actions by Jim Richards0 comments

https://www.banking.senate.gov/hearings/10/24/2018/combating-money-laundering-and-other-forms-of-illicit-finance-regulator-and-law-enforcement-perspectives-on-reform From obvious tension between FinCEN and the OCC, to patiently waiting for marijuana guidance, to missteps on CTR filings […]

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November 19, 2018May 26, 2019

Crypto ICOs, Cannabis, Beauty Queens, and Russian Technocrats

Crypto & Blockchain by Jim Richards0 comments

On November 16, 2018 the SEC settled an unregistered ICO case with the issuer, Paragon Coin. See https://www.sec.gov/litigation/admin/2018/33-10574.pdf. It doesn’t get […]

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November 19, 2018May 26, 2019

The Strip Club – Is Membership Now Closed?

AML Regulations and Enforcement Actions by Jim Richards0 comments

With today’s announcements from the US Attorney for the Southern District of New York, OFAC, Federal Reserve, New York State […]

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Central Bank Digital Currency?
November 15, 2018May 26, 2019

Central Bank Digital Currency?

Crypto & Blockchain by Jim Richards0 comments

Christine Largarde, Managing Director of the IMF, introduced the concept of a Central Bank Digital Currency, in a speech at […]

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September 18, 2018May 26, 2019

Swiss Regulator FINMA criticizes Societe General’s lack of an EVOC – Enterprise View of the Customer

AML Regulations and Enforcement Actions by Jim Richards0 comments

https://www.finma.ch/en/news/2018/09/20180917-mm-gwg-cs/ Not being able to impose monetary penalties, Swiss financial supervisor FINMA concluded two enforcement procedures against Credit Suisse AG. […]

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September 12, 2018May 26, 2019

Cannabis, Congress, and Courage – Why Banks are not Banking Marijuana Related Businesses

Cannabis/Marijuana by Jim Richards0 comments

In January 2018, Attorney General Sessions “revoked Obama-era guidance that had effectuated a hands-off approach to state-legalized cannabis businesses.” This […]

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September 11, 2018May 26, 2019

Veterans Medical Marijuana Safe Harbor Act introduced in U.S. Senate – September 5, 2018

Cannabis/Marijuana by Jim Richards0 comments

Democratic Senators Bill Nelson (Florida) and Brian Schatz (Hawaii) have introduced S3409 – the Veterans Medical Marijuana Safe Harbor Act. […]

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  • Richards Comments on Proposed Beneficial Ownership Access Rule – December 2022
  • BSA, Bittner, and FBARs – Forty Questions from The Supremes
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