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Category: Money Laundering & Terrorist Financing – General

November 30, 2021December 18, 2021

FinCEN Exchange – Participants May Soon Be Fully Authorized!

AML Regulations and Enforcement Actions by admin0 comments

The FinCEN Exchange has gone through two versions: the implied, pre-AML Act of 2020 version, and the codified, post-AML Act […]

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November 29, 2021November 29, 2021

Wyoming Shelf Companies are Flying Off the Shelf!

Beneficial Ownership & Customer Due Diligence by admin0 comments

“A growing niche in the shell business is shelf corporations. Like paper-only shells, which enable the secrecy-minded to hide real […]

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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 28, 2020December 28, 2020

Measuring Illicit Financial Flows – Getting Closer to a True Estimate of Global Money Laundering

Money Laundering & Terrorist Financing - General by admin0 comments

Over $1 trillion is laundered globally every year, and less than one per cent is seized. Where do these numbers […]

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December 13, 2020December 13, 2020

314(b) Information Sharing – a Valuable, but Underutilized Tool

AML Regulations and Enforcement Actions by admin0 comments

The AML Act of 2020 doesn’t directly change the voluntary information sharing provisions set out in section 314(b) of the […]

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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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October 3, 2020October 3, 2020

Don’t Blame FinCEN – Congress Has Left it Underfunded for Years

AML Regulations and Enforcement Actions by admin0 comments

In the last five years, FinCEN’s workload has gone up three times as much as its budget: if we care […]

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August 16, 2020August 16, 2020

A GAO Report on GTOs Reveals the Underlying Flaws In the Entire American BSA/AML Regime

AML Regulations and Enforcement Actions by admin0 comments

The General Accountability Office, or GAO, issued a Report on August 14, 2020 titled “FinCEN Should Enhance Procedures for Implementing […]

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April 27, 2020April 28, 2020

FinCEN’s Marijuana-Related SAR Data: By Not Including MSBs, Are We Under-Reporting Marijuana Businesses’ Access to Financial Services?

Cannabis/Marijuana by admin0 comments

Marijuana-Related Businesses may have greater access to financial services than is being reported, even if those services aren’t being provided […]

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April 22, 2020April 22, 2020

BSA/AML Compliance Programs are Important, but Providing Timely, Actionable Intelligence to Law Enforcement Should be the Goal

Money Laundering & Terrorist Financing - General by admin0 comments

Eighteen months ago I called for a renewal of the original purpose of the Bank Secrecy Act: with recent changes […]

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