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Category: AML Regulations and Enforcement Actions

December 11, 2020December 11, 2020

AML Act of 2020: Renewing America’s AML/CFT Regime

AML Regulations and Enforcement Actions by admin0 comments

Executive Summary of the AML Act of 2020 On December 3, 2020 the Senate and House jointly issued a Conference […]

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November 8, 2020November 8, 2020

FinCEN’s Proposed AML Program Effectiveness Rule – Comments of RegTech Consulting LLC

AML Regulations and Enforcement Actions by admin0 comments

The following comments to FinCEN’s Advance Notice of Proposed Rule Making (ANPRM) on AML Program Effectiveness were submitted by Jim […]

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October 3, 2020October 3, 2020

Don’t Blame FinCEN – Congress Has Left it Underfunded for Years

AML Regulations and Enforcement Actions by admin0 comments

In the last five years, FinCEN’s workload has gone up three times as much as its budget: if we care […]

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August 20, 2020August 20, 2020

Enforcing AML Laws: Significant Potential for Money Laundering? Or Potential for Significant Money Laundering?

AML Regulations and Enforcement Actions by admin0 comments

On August 13 the federal banking agencies issued a joint statement on updates to their guidance on enforcing BSA/AML requirements. […]

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August 16, 2020August 16, 2020

A GAO Report on GTOs Reveals the Underlying Flaws In the Entire American BSA/AML Regime

AML Regulations and Enforcement Actions by admin0 comments

The General Accountability Office, or GAO, issued a Report on August 14, 2020 titled “FinCEN Should Enhance Procedures for Implementing […]

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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 admin0 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 admin0 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 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 admin0 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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March 17, 2020

The Perfect Storm: More Alerts, Fewer Investigators, & More False Positives

AML Regulations and Enforcement Actions by admin0 comments

The Focus Has Always Been On the Increase in Fraud Natural disasters bring out the best in some people and […]

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March 9, 2020March 10, 2020

When it comes to BSA/AML compliance programs, success has a hundred fathers, but failure is, apparently, an orphan

AML Regulations and Enforcement Actions by admin0 comments

“FinCEN Penalizes U.S. Bank Official for Corporate Anti-Money Laundering Failures” In 1961 President John F. Kennedy commented on the failed […]

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