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Category: AML Regulations and Enforcement Actions

February 13, 2020

Lack of Beneficial Ownership Information: a “Glaring Hole in our System” Says Treasury Secretary

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On February 12, 2020, Treasury Secretary Mnuchin testified before the Senate Finance Committee on the President’s Fiscal Year 2021 budget. […]

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February 5, 2020February 5, 2020

OCC Comptroller Talks About AML “False Negatives” and Technology

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Whether “False Negatives” or “False Positives”, the Answer May Not Lie Just in New or Improved Technologies, but in an […]

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January 31, 2020February 24, 2020

PETITION DENIED – The US Supreme Court Defends the SAR Safe Harbor!

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Updated February 24, 2020 – The US Supreme Court denied a petition that challenged the SAR Safe Harbor On September […]

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January 8, 2020January 8, 2020

Proceeds of Crime and GDP – Are We Comparing Apples to Oranges?

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The Estimate for US Money Laundering – $300 billion a year, or 2% of GDP The 2015 National Money Laundering […]

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November 21, 2019November 21, 2019

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?

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“Well, I’m here in the freezing cold getting’ free chicken sandwiches. Because the food tastes great. I mean, it’s chicken. […]

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September 27, 2019

SAFE Banking Act of 2019 – Some Suggestions for the Senate

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The SAFE Banking Act, HR 1595, was approved by the House on September 25, 2019. As written, it is a […]

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August 19, 2019August 19, 2019

FinCEN’s BSA Value Project – An Effort to Provide Actionable Information for SAR Filers

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Two Million SARs are Filed Every Year … But Which Ones Provide Tactical or Strategic Value to Law Enforcement? On […]

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August 7, 2019August 7, 2019

A Better Way to Fight Money Laundering – American Banker quotes Jim Richards and Others

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Jim Richards was quoted in an August 2019 American Banker article titled “Is There a Better Way to Fight Money […]

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July 30, 2019July 30, 2019

SAR Feedback? What Ever Happened to Section 314(d)?

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Wouldn’t it be great if Treasury published a report, perhaps semi-annually, that contained a detailed analysis identifying patterns of suspicious […]

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June 25, 2019

A Contempt Fine of $50,000 a Day for “Stashing Documents” But Not Producing Them

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Three Chinese “multi-billion dollar banks disregarding an order to produce records or a witness essential to an investigation into a […]

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  • BSA, Bittner, and FBARs: the United States Supreme Court will soon decide, but does it have ALL the facts it needs?
  • $73 billion penalty? Or $18.25 million penalty? Or $118.25 million?
  • Can Cryptocurrencies be Physically Transported? U.S. Law Says “Yes” … But How Will US Regulations Implement that Law?
  • Richards Comments on FinCEN’s Request For Information on Reforming the BSA/AML Regime
  • Beneficial Ownership Information Reporting Requirements – Richards Comments on FinCEN’s Proposed Rule

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