The FinCEN Exchange has gone through two versions: the implied, pre-AML Act of 2020 version, and the codified, post-AML Act […]
Wyoming Shelf Companies are Flying Off the Shelf!
“A growing niche in the shell business is shelf corporations. Like paper-only shells, which enable the secrecy-minded to hide real […]
Disclaimers – If You’re Not Speaking For Your Institution, Why Am I Listening To You?
Disclaimer: The views expressed herein are my own and do not represent the views or opinions of my current or […]
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 […]
Crypto vs Fiat: Is One Or The Other More Of A Haven For Illicit Finance?
UPDATE: Since I published this article and posted it on LinkedIn about four hours ago, I’ve had many comments and […]
Effective AML Programs? How About Effective AML Laws and Regulations!
Demonstrating AML/CTF Effectiveness in the private sector requires (1) compliance with laws and regulations, (2) providing highly useful information to […]
PPP Round 2 – Why Will It Cost $6 billion More Than Round 1?
A couple of stealthy tweaks to the language in the rules for Round Paycheck Protection Program (PPP) loans will put […]
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 […]
Corporate Transparency Act: Shell Companies, Shelf Companies, and Front Companies (and SPACs)
Bad actors and nation states, such as China and Russia, are becoming more proficient in using our financial system to […]
Capital One’s $390,000,000 BSA/AML Penalty – Are We Asking the Right Questions?
Supervision [of banks] happens behind closed doors. It relies upon secrecy and involves a system of discretionary actions by supervisory […]