Executive Summary of the AML Act of 2020 On December 3, 2020 the Senate and House jointly issued a Conference […]
Category: AML Regulations and Enforcement Actions
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 […]
What Does It Take to Run a BSA Program? Not Much, According to the FDIC
Unfortunately, the FDIC’s estimate of the time and effort it takes to run a BSA/AML compliance program is … laughable. […]
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 […]
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): […]
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 […]