Merry Christmas! Section 6403 of the Corporate Transparency Act (CTA), enacted into law as part of the Anti-Money Laundering Act […]
BSA, Bittner, and FBARs – Forty Questions from The Supremes
This is the third article I’ve written on Bittner v United States, a case before the U.S. Supreme Court. In an […]
Beneficial Ownership Database – Now That We Know What Goes In, Let’s Turn to What Will Come Out
Access to the Database – None for the Public, Limited for Financial Institutions, Difficult for Law Enforcement On September 30, […]
Beneficial Ownership Information Reporting – Will it Reduce Financial Crimes?
On September 29, 2022, the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) published a final rule setting out the […]
BSA/AML Policies and Procedures – What Can We Learn From Mary Berra and the Founding Fathers?
According to a Quartz At Work article from July 2022, in 2015 General Motors’ Chair and CEO Mary Berra replaced […]
BSA, Bittner, and FBARs: the United States Supreme Court will soon decide, but does it have ALL the facts it needs?
In an article posted on June 22, 2022, $73 million penalty? Or $18.25 million? Or $118.25 million? The US Supreme Court […]
$73 billion penalty? Or $18.25 million penalty? Or $118.25 million?
The Supreme Court of the United States will soon decide … The US Supreme Court has taken up a very […]
Can Cryptocurrencies be Physically Transported? U.S. Law Says “Yes” … But How Will US Regulations Implement that Law?
Disclaimer – I know better than to use these deceptive images of shiny, gold “bitcoins” – see for example my […]
Richards Comments on FinCEN’s Request For Information on Reforming the BSA/AML Regime
On December 14, 2021 FinCEN published a Request For Information (RFI) soliciting comments on ways to modernize the risk-based AML/CFT […]
Beneficial Ownership Information Reporting Requirements – Richards Comments on FinCEN’s Proposed Rule
Re: Beneficial Ownership Information Reporting Requirements, Anti-Money Laundering Act of 2020 Notice of Proposed Rule Making, Docket Number FINCEN-2021-0005 and […]