For years, FinCEN has used a one-size-fits-all-SARs method of determining the costs and burden of filing Suspicious Activity Reports (SARs): […]
Category: AML Regulations and Enforcement Actions
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 […]
Lack of Beneficial Ownership Information: a “Glaring Hole in our System” Says Treasury Secretary
On February 12, 2020, Treasury Secretary Mnuchin testified before the Senate Finance Committee on the President’s Fiscal Year 2021 budget. […]
OCC Comptroller Talks About AML “False Negatives” and Technology
Whether “False Negatives” or “False Positives”, the Answer May Not Lie Just in New or Improved Technologies, but in an […]
PETITION DENIED – The US Supreme Court Defends the SAR Safe Harbor!
Updated February 24, 2020 – The US Supreme Court denied a petition that challenged the SAR Safe Harbor On September […]
Proceeds of Crime and GDP – Are We Comparing Apples to Oranges?
The Estimate for US Money Laundering – $300 billion a year, or 2% of GDP The 2015 National Money Laundering […]
Like Sam Loves Free Fried Chicken, Law Enforcement Loves “Free” Suspicious Activity Reports … But What If Law Enforcement Had to Earn the Right to Use the Private Sector’s “Free” SARs?
“Well, I’m here in the freezing cold getting’ free chicken sandwiches. Because the food tastes great. I mean, it’s chicken. […]
SAFE Banking Act of 2019 – Some Suggestions for the Senate
The SAFE Banking Act, HR 1595, was approved by the House on September 25, 2019. As written, it is a […]
FinCEN’s BSA Value Project – An Effort to Provide Actionable Information for SAR Filers
Two Million SARs are Filed Every Year … But Which Ones Provide Tactical or Strategic Value to Law Enforcement? On […]