On December 20th the Treasury Department released its National Illicit Finance Strategy (something required under the Countering America’s Adversaries Through […]
Category: RegTech
CRA-like Evaluations for Banks’ BSA/AML Programs? Let’s Give Banks Some Credit for Building and Maintaining an Outstanding BSA Program!
The only time the public (and Congress) hears about a bank’s BSA program is when the program has failed and […]
“Extraordinary workloads” and “extraordinary steps” – What can we learn from these phrases? Unfortunately, not much
The most recent AML-related public censure comes in the form of a FINRA “AWC” or Letter of Acceptance, Waiver and […]
2005 Banking Agencies’ MSB Guidance = 2019 Banking Agencies’ MRB Guidance?
Here’s an idea to jump start the US banking agencies’ (inevitable) guidance on providing banking services for marijuana related businesses […]
CFTC Primer on “Smart Contracts” … which apparently aren’t necessarily “smart”
The Commodity Futures Trading Commission (CFTC) recently published an excellent primer on Smart Contracts. I’ve reproduced most of the primer […]
Rules-Based Monitoring, Alert to SAR Ratios, and False Positive Rates – Are We Having The Right Conversations?
There is a lot of conversation in the industry about the inefficiencies of “traditional” rules-based monitoring systems, Alert-to-SAR ratios, and […]
FinCrime FinTech Hype, Hubris, and Subject Matter Enthusiasm
Two very recent fincrime fintech start-ups recently published marketing papers – one a self-styled “Report” the other a blog – […]
Flipping the Three AML Ratios with Machine Learning and Artificial Intelligence (why Bartenders and AML Analysts will survive the AI Apocalypse)
Machine Learning and Artificial Intelligence proponents are convinced – and spend a lot of time trying to convince others – […]
Medical Marijuana – the DOJ Won’t Come Knocking … but Recreational Marijuana? Perhaps not so lucky …
The November 29, 2018 US Tax Court decision in the Harborside case provides some excellent background on the state versus […]
Bucksnort, Marijuana, Thresholds, and “a little bit of tension” … Senate Banking Committee and BSA/AML
https://www.banking.senate.gov/hearings/10/24/2018/combating-money-laundering-and-other-forms-of-illicit-finance-regulator-and-law-enforcement-perspectives-on-reform From obvious tension between FinCEN and the OCC, to patiently waiting for marijuana guidance, to missteps on CTR filings […]