Eighteen months ago I called for a renewal of the original purpose of the Bank Secrecy Act: with recent changes […]
Category: Money Laundering & Terrorist Financing – General
“Money Laundering/Terrorist Financing and Other Illicit Financial Activity” – a New BSA/AML Focus?
If this is, in fact, a new standard for the assessment of U.S. financial institutions’ BSA/AML compliance programs, then I […]
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 […]
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. […]
Chinese Money Brokers – The First US Case Involving An Identified Threat to the US Financial System?
February 6, 2020 – US Warns of Chinese Money Brokers Integrating Illicit Cash Proceeds through Trade Based Money Laundering, or […]
PETITION DENIED – The US Supreme Court Defends the SAR Safe Harbor!
Updated February 24, 2020 – The US Supreme Court denied a petition that challenged the SAR Safe Harbor On September […]
Proceeds of Crime and GDP – Are We Comparing Apples to Oranges?
The Estimate for US Money Laundering – $300 billion a year, or 2% of GDP The 2015 National Money Laundering […]
FinCEN’s BSA Value Project is A Year Old … How Is It Going?
In January 2019, FinCEN launched its “BSA Value Project” – an effort to “catalogue the value of BSA reporting across […]
Business Email Compromise – New FinCEN Advisory and Trend Analysis
FinCEN has issued an updated advisory on Business Email Compromise (BEC) fraud schemes: FinCEN 2019 BEC Advisory . At the same […]
FATF Terrorist Financing Risk Assessment Guidance
Is the United States a jurisdiction with no or very few known (or suspected) terrorism or TF cases? The Financial […]