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Author: Jim Richards

August 6, 2020August 6, 2020

What Does It Take to Run a BSA Program? Not Much, According to the FDIC

AML Regulations and Enforcement Actions by Jim Richards0 comments

Unfortunately, the FDIC’s estimate of the time and effort it takes to run a BSA/AML compliance program is … laughable. […]

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July 3, 2020July 4, 2020

Anti-Money Laundering Act of 2020 – “Pay to Play” Arrives and Perhaps We Have An Answer to the Whereabouts of Section 314(d)

AML Regulations and Enforcement Actions by Jim Richards0 comments

The Senate Banking Committee’s top Republican (Senator Crapo from Idaho) and top Democrat (Senator Brown from Ohio) have joined forces […]

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June 14, 2020

AML360 Podcast – Jim Richards with Stephen Platt

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

On June 12, 2020 I enjoyed an hour with AML360 talk show host Stephen Platt. For an hour – live! […]

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June 2, 2020February 22, 2021

FinCEN’s Estimate of the Costs and Burden of Filing SARs Is Evolving, But Needs Private Sector Input

AML Regulations and Enforcement Actions by Jim Richards0 comments

For years, FinCEN has used a one-size-fits-all-SARs method of determining the costs and burden of filing Suspicious Activity Reports (SARs): […]

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May 14, 2020

FinCEN Director Ken Blanco is Crystal Clear on Virtual Currency Risks & Requirements

Crypto & Blockchain by Jim Richards0 comments

FinCEN Director Kenneth A. Blanco, delivered Prepared Remarks at the Consensus Blockchain Conference on May 13, 2020. They are available at Prepared […]

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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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  • BSA, Bittner, and FBARs – Forty Questions from The Supremes
  • Beneficial Ownership Database – Now That We Know What Goes In, Let’s Turn to What Will Come Out
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