Bad actors and nation states, such as China and Russia, are becoming more proficient in using our financial system to […]
Category: Beneficial Ownership & Customer Due Diligence
The Corporate Transparency Act of 2020 … The Good, The Bad, and the Ugly
Corporate Transparency Act – There’s much that is Good, but there’s also some things that are Bad and other things […]
AML Act of 2020: Renewing America’s AML/CFT Regime
Executive Summary of the AML Act of 2020 On December 3, 2020 the Senate and House jointly issued a Conference […]
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 […]
5 + 4 = 6 … Treasury’s New PPP Math Is Creating Unnecessary Confusion, & Here’s a Proposed Solution
I’ve written two articles on the CARES Act’s Paycheck Protection Program (PPP) – the $350 billion, or $350,000,000,000, pot of […]
The CARES Act and the Paycheck Protection Program – We Know A Surge of Fraud is Coming, Let’s Prevent it Now
SBA’s disaster loan programs suffer increased vulnerability to fraud and unnecessary losses when loan transactions are expedited to provide quick […]
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. […]
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? Without a national […]
FinCEN Director Ken Blanco testifies on the new CDD/Beneficial Ownership Rule
House Financial Services Committee – FinCEN Director Blanco Written Testimony 5-16-18 What is interesting is what Director Blanco did not […]
Beneficial Ownership – a Centralized Registry is the Key!
Requiring financial institutions to collect the (one to five) names and PII of what may or may not be the […]