The FinCEN Exchange has gone through two versions: the implied, pre-AML Act of 2020 version, and the codified, post-AML Act […]
Category: FinTech, Financial Crimes, and Risk Management
Crypto vs Fiat: Is One Or The Other More Of A Haven For Illicit Finance?
UPDATE: Since I published this article and posted it on LinkedIn about four hours ago, I’ve had many comments and […]
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 […]
A GAO Report on GTOs Reveals the Underlying Flaws In the Entire American BSA/AML Regime
The General Accountability Office, or GAO, issued a Report on August 14, 2020 titled “FinCEN Should Enhance Procedures for Implementing […]
AML360 Podcast – Jim Richards with Stephen Platt
On June 12, 2020 I enjoyed an hour with AML360 talk show host Stephen Platt. For an hour – live! […]
FinCEN’s Estimate of the Costs and Burden of Filing SARs Is Evolving, But Needs Private Sector Input
For years, FinCEN has used a one-size-fits-all-SARs method of determining the costs and burden of filing Suspicious Activity Reports (SARs): […]
FinCEN Director Ken Blanco is Crystal Clear on Virtual Currency Risks & Requirements
FinCEN Director Kenneth A. Blanco, delivered Prepared Remarks at the Consensus Blockchain Conference on May 13, 2020. They are available at Prepared […]
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 […]
The Perfect Storm: More Alerts, Fewer Investigators, & More False Positives
The Focus Has Always Been On the Increase in Fraud Natural disasters bring out the best in some people and […]
When it comes to BSA/AML compliance programs, success has a hundred fathers, but failure is, apparently, an orphan
“FinCEN Penalizes U.S. Bank Official for Corporate Anti-Money Laundering Failures” In 1961 President John F. Kennedy commented on the failed […]