According to a Quartz At Work article from July 2022, in 2015 General Motors’ Chair and CEO Mary Berra replaced […]
Category: Money Laundering & Terrorist Financing – General
FinCEN Exchange – Participants May Soon Be Fully Authorized!
The FinCEN Exchange has gone through two versions: the implied, pre-AML Act of 2020 version, and the codified, post-AML Act […]
Wyoming Shelf Companies are Flying Off the Shelf!
“A growing niche in the shell business is shelf corporations. Like paper-only shells, which enable the secrecy-minded to hide real […]
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 […]
Measuring Illicit Financial Flows – Getting Closer to a True Estimate of Global Money Laundering
Over $1 trillion is laundered globally every year, and less than one per cent is seized. Where do these numbers […]
314(b) Information Sharing – a Valuable, but Underutilized Tool
The AML Act of 2020 doesn’t directly change the voluntary information sharing provisions set out in section 314(b) of the […]
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 […]
Don’t Blame FinCEN – Congress Has Left it Underfunded for Years
In the last five years, FinCEN’s workload has gone up three times as much as its budget: if we care […]
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 […]
FinCEN’s Marijuana-Related SAR Data: By Not Including MSBs, Are We Under-Reporting Marijuana Businesses’ Access to Financial Services?
Marijuana-Related Businesses may have greater access to financial services than is being reported, even if those services aren’t being provided […]