Unfortunately, the FDIC’s estimate of the time and effort it takes to run a BSA/AML compliance program is … laughable. […]
Category: AML Regulations and Enforcement Actions
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 […]
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. […]