The SAFE Banking Act, HR 1595, was approved by the House on September 25, 2019. As written, it is a […]
Category: AML Regulations and Enforcement Actions
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 […]
REAL ID Act of 2005 … REAL Beneficial Owners Act of 2019?
Can something like the REAL ID Act of 2005 be used to solve the beneficial ownership issue? Even with a […]
44% of UK Solicitors Tested Are Not Meeting ML/TF Regulatory Requirements – but Unlike Their American Counterparts, At Least They Have Regulatory Requirements
A review by the UK’s Solicitors Regulation Authority (SRA) results in 44% of solicitor firms tested will be subject to […]
Regulators Testify on BSA/AML
Sed quis custodiet ipsos Custodes But who will guard the guards themselves? – Roman poet and satirist Juvenal, c. 100 […]
FinCEN’s Advisories and Guidance – “Persuasive Precedential Effect”, Whatever That Means
US-based AML practitioners are familiar with FinCEN Guidance and Advisories. Most are probably not sure what the differences are between […]
FINRA’s list of AML Red Flags has gone from 25 to 97
FINRA Provides Guidance to Firms Regarding Suspicious Activity Monitoring and Reporting Obligations http://www.finra.org/sites/default/files/notice_doc_file_ref/Regulatory-Notice-19-18.pdf May 9, 2019 FINRA issued the Notice […]