“A growing niche in the shell business is shelf corporations. Like paper-only shells, which enable the secrecy-minded to hide real […]
Category: Beneficial Ownership & Customer Due Diligence
OpenCorporates’ Database of 200 Million Global Companies – A Valuable Anti-Financial Crime Tool
The U.S. Treasury Department has tapped into the largest open database of companies in the world, but that database does […]
Corporate Transparency Act: Shell Companies, Shelf Companies, and Front Companies (and SPACs)
Bad actors and nation states, such as China and Russia, are becoming more proficient in using our financial system to […]
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 […]