On February 12, 2020, Treasury Secretary Mnuchin testified before the Senate Finance Committee on the President’s Fiscal Year 2021 budget. […]
Category: AML Regulations and Enforcement Actions
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 […]
A Better Way to Fight Money Laundering – American Banker quotes Jim Richards and Others
Jim Richards was quoted in an August 2019 American Banker article titled “Is There a Better Way to Fight Money […]
SAR Feedback? What Ever Happened to Section 314(d)?
Wouldn’t it be great if Treasury published a report, perhaps semi-annually, that contained a detailed analysis identifying patterns of suspicious […]
A Contempt Fine of $50,000 a Day for “Stashing Documents” But Not Producing Them
Three Chinese “multi-billion dollar banks disregarding an order to produce records or a witness essential to an investigation into a […]