The size of an NHL ice surface – 200 feet by 85 feet – hasn’t changed in 100 years. Yet […]
News
Managing Through Change – How to Survive and Succeed
“If you don’t like change, you’re going to like irrelevance even less.” – General Eric Shinseki “New ideas pass through […]
Managing Meetings – How to Increase Your Effective Staffing Level by 25% … Without Adding Any Staff!
How many of us dread those needless conference calls where the first ten minutes are spent re-capping what was just […]
California Chaos – Not Only do California’s Cannabis Regulations Make Banking Cannabis Businesses Almost Impossible, They Squandered a Perfect Opportunity to Embrace Regulatory Innovation
There is a big push in the FinTech/RegTech (SupTech) space to digitize regulations. One of the biggest hurdles to doing […]
2018 National Money Laundering Risk Assessment – AML 2018 Looks Very Similar to AML 2015
On December 20th the Treasury Department released its National Illicit Finance Strategy (something required under the Countering America’s Adversaries Through […]
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 […]