Disclaimer – I know better than to use these deceptive images of shiny, gold “bitcoins” – see for example my […]
Category: RegTech
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 […]
Bank Directors: What the Regulators, and Your Consultants, Aren’t Telling You About How to Satisfy Your AML/CFT Program Responsibilities
Fifteen Directors’ Tips In a recent LinkedIn post, a consulting firm published a blog titled “The Importance of a Board-level […]
Biden or Trump? Possible Impacts of a New Administration on Financial Crimes Compliance
And does FinCEN have a 95 percent “false positive rate” it needs to address? The U.S. election is Tuesday, November […]
FinCEN Files – Reforming AML Regimes Through TSV SARs (Tactical or Strategic Value Suspicious Activity Reports)
The Public/Private AML Industry is Fifty Years Old and is Long Overdue for a Makeover: Let’s Start with Better Public […]
The US BSA/AML Regime – Have We Just Gone From Aspiring to be “Effective” to Merely Being “Adequate”?
On April 15, 2020, federal and state banking agencies updated parts of the BSA/AML Examination Manual (“Manual”), a document that […]
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 of 2020: “Tall, Dark, or Handsome” and “Tall, Dark, and Handsome” in one bill
There is a big difference between someone who is tall, dark, and handsome – he is all three of those […]
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 […]
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 […]