On April 15, 2020, federal and state banking agencies updated parts of the BSA/AML Examination Manual (“Manual”), a document that […]
Author: Jim Richards
CARES Act and PPP Loans – Has the SBA Actually “Approved” Any PPP Loans? Or Are Its Deputies Doin’ All the Approvin’?
The Small Business Administration (SBA) has announced that as of April 15th it had “approved” about 1,300,000 Paycheck Protection Program […]
5 + 4 = 6 … Treasury’s New PPP Math Is Creating Unnecessary Confusion, & Here’s a Proposed Solution
I’ve written two articles on the CARES Act’s Paycheck Protection Program (PPP) – the $350 billion, or $350,000,000,000, pot of […]
CARES Act PPP Loans – Is There A Loan “Dead Zone”?
The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) was signed into law by the President on March 27, […]
The CARES Act and the Paycheck Protection Program – We Know A Surge of Fraud is Coming, Let’s Prevent it Now
SBA’s disaster loan programs suffer increased vulnerability to fraud and unnecessary losses when loan transactions are expedited to provide quick […]
Marijuana $475,000,000 in Tax Revenue? IRS Says “No Thanks, We Have Other Priorities”
On March 30, 2020 the Treasury Inspector General released a OIG Report titled “The Growth of the Marijuana Industry Warrants […]
“Descriptive & Memorable” – The Fed’s soon-to-be-published Pandemic Response Accountability Committee Website
The CARES Act, section 15010(g) (1) (A) requires that: “Not later than 30 days after the date of enactment of […]
The CARES Act of 2020: “Tall, Dark, or Handsome” and “Tall, Dark, and Handsome” in one bill
There is a big difference between someone who is tall, dark, and handsome – he is all three of those […]
The Perfect Storm: More Alerts, Fewer Investigators, & More False Positives
The Focus Has Always Been On the Increase in Fraud Natural disasters bring out the best in some people and […]
When it comes to BSA/AML compliance programs, success has a hundred fathers, but failure is, apparently, an orphan
“FinCEN Penalizes U.S. Bank Official for Corporate Anti-Money Laundering Failures” In 1961 President John F. Kennedy commented on the failed […]