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Category: Beneficial Ownership & Customer Due Diligence

January 20, 2021January 29, 2021

Corporate Transparency Act: Shell Companies, Shelf Companies, and Front Companies (and SPACs)

Beneficial Ownership & Customer Due Diligence by admin0 comments

Bad actors and nation states, such as China and Russia, are becoming more proficient in using our financial system to […]

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December 20, 2020December 20, 2020

The Corporate Transparency Act of 2020 … The Good, The Bad, and the Ugly

AML Regulations and Enforcement Actions by admin0 comments

Corporate Transparency Act – There’s much that is Good, but there’s also some things that are Bad and other things […]

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December 11, 2020December 11, 2020

AML Act of 2020: Renewing America’s AML/CFT Regime

AML Regulations and Enforcement Actions by admin0 comments

Executive Summary of the AML Act of 2020 On December 3, 2020 the Senate and House jointly issued a Conference […]

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July 3, 2020July 4, 2020

Anti-Money Laundering Act of 2020 – “Pay to Play” Arrives and Perhaps We Have An Answer to the Whereabouts of Section 314(d)

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The Senate Banking Committee’s top Republican (Senator Crapo from Idaho) and top Democrat (Senator Brown from Ohio) have joined forces […]

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April 14, 2020April 19, 2020

5 + 4 = 6 … Treasury’s New PPP Math Is Creating Unnecessary Confusion, & Here’s a Proposed Solution

Beneficial Ownership & Customer Due Diligence by admin0 comments

I’ve written two articles on the CARES Act’s Paycheck Protection Program (PPP) – the $350 billion, or $350,000,000,000, pot of […]

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April 7, 2020April 13, 2020

The CARES Act and the Paycheck Protection Program – We Know A Surge of Fraud is Coming, Let’s Prevent it Now

Beneficial Ownership & Customer Due Diligence by admin0 comments

SBA’s disaster loan programs suffer increased vulnerability to fraud and unnecessary losses when loan transactions are expedited to provide quick […]

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February 13, 2020

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

AML Regulations and Enforcement Actions by admin0 comments

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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June 10, 2019June 10, 2019

REAL ID Act of 2005 … REAL Beneficial Owners Act of 2019?

AML Regulations and Enforcement Actions by admin0 comments

Can something like the REAL ID Act of 2005 be used to solve the beneficial ownership issue? Without a national […]

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May 16, 2018May 26, 2019

FinCEN Director Ken Blanco testifies on the new CDD/Beneficial Ownership Rule

Beneficial Ownership & Customer Due Diligence by admin0 comments

House Financial Services Committee – FinCEN Director Blanco Written Testimony 5-16-18 What is interesting is what Director Blanco did not […]

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May 8, 2018May 26, 2019

Beneficial Ownership – a Centralized Registry is the Key!

Beneficial Ownership & Customer Due Diligence by admin0 comments

Requiring financial institutions to collect the (one to five) names and PII of what may or may not be the […]

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Recent Posts

  • Corporate Transparency Act: Shell Companies, Shelf Companies, and Front Companies (and SPACs)
  • Capital One’s $390,000,000 BSA/AML Penalty – Are We Asking the Right Questions?
  • Measuring Illicit Financial Flows – Getting Closer to a True Estimate of Global Money Laundering
  • The Corporate Transparency Act of 2020 … The Good, The Bad, and the Ugly
  • 314(b) Information Sharing – a Valuable, but Underutilized Tool

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