The FinCEN Exchange has gone through two versions: the implied, pre-AML Act of 2020 version, and the codified, post-AML Act […]
Category: AML Regulations and Enforcement Actions
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 […]
Capital One’s $390,000,000 BSA/AML Penalty – Are We Asking the Right Questions?
Supervision [of banks] happens behind closed doors. It relies upon secrecy and involves a system of discretionary actions by supervisory […]
The Corporate Transparency Act of 2020 … The Good, The Bad, and the Ugly
Corporate Transparency Act – There’s much that is Good, but there’s also some things that are Bad and other things […]
314(b) Information Sharing – a Valuable, but Underutilized Tool
The AML Act of 2020 doesn’t directly change the voluntary information sharing provisions set out in section 314(b) of the […]
AML Act of 2020: Renewing America’s AML/CFT Regime
Executive Summary of the AML Act of 2020 On December 3, 2020 the Senate and House jointly issued a Conference […]
FinCEN’s Proposed AML Program Effectiveness Rule – Comments of RegTech Consulting LLC
The following comments to FinCEN’s Advance Notice of Proposed Rule Making (ANPRM) on AML Program Effectiveness were submitted by Jim […]
Don’t Blame FinCEN – Congress Has Left it Underfunded for Years
In the last five years, FinCEN’s workload has gone up three times as much as its budget: if we care […]
Enforcing AML Laws: Significant Potential for Money Laundering? Or Potential for Significant Money Laundering?
On August 13 the federal banking agencies issued a joint statement on updates to their guidance on enforcing BSA/AML requirements. […]
A GAO Report on GTOs Reveals the Underlying Flaws In the Entire American BSA/AML Regime
The General Accountability Office, or GAO, issued a Report on August 14, 2020 titled “FinCEN Should Enhance Procedures for Implementing […]