Unfortunately, the FDIC’s estimate of the time and effort it takes to run a BSA/AML compliance program is … laughable. […]
Author: Jim Richards
Anti-Money Laundering Act of 2020 – “Pay to Play” Arrives and Perhaps We Have An Answer to the Whereabouts of Section 314(d)
The Senate Banking Committee’s top Republican (Senator Crapo from Idaho) and top Democrat (Senator Brown from Ohio) have joined forces […]
AML360 Podcast – Jim Richards with Stephen Platt
On June 12, 2020 I enjoyed an hour with AML360 talk show host Stephen Platt. For an hour – live! […]
FinCEN’s Estimate of the Costs and Burden of Filing SARs Is Evolving, But Needs Private Sector Input
For years, FinCEN has used a one-size-fits-all-SARs method of determining the costs and burden of filing Suspicious Activity Reports (SARs): […]
FinCEN Director Ken Blanco is Crystal Clear on Virtual Currency Risks & Requirements
FinCEN Director Kenneth A. Blanco, delivered Prepared Remarks at the Consensus Blockchain Conference on May 13, 2020. They are available at Prepared […]
FinCEN’s Marijuana-Related SAR Data: By Not Including MSBs, Are We Under-Reporting Marijuana Businesses’ Access to Financial Services?
Marijuana-Related Businesses may have greater access to financial services than is being reported, even if those services aren’t being provided […]
Sponge Bob Square Pants, Alan Greenspan, Elton John, PPP Loans, and a Limited Safe Harbor
On April 23rd the Treasury Department added a 31st question and answer to its series of Paycheck Protection Program (PPP) […]
BSA/AML Compliance Programs are Important, but Providing Timely, Actionable Intelligence to Law Enforcement Should be the Goal
Eighteen months ago I called for a renewal of the original purpose of the Bank Secrecy Act: with recent changes […]
Dusting off the Congressional Version of an “Aged Shelf Company”
On April 21, 2020, the United States Senate resolved “that the bill from the House of Representatives (H.R. 266) entitled […]
“Money Laundering/Terrorist Financing and Other Illicit Financial Activity” – a New BSA/AML Focus?
If this is, in fact, a new standard for the assessment of U.S. financial institutions’ BSA/AML compliance programs, then I […]