And does FinCEN have a 95 percent “false positive rate” it needs to address? The U.S. election is Tuesday, November […]
News
Don’t Blame FinCEN – Congress Has Left it Underfunded for Years
In the last five years, FinCEN’s workload has gone up three times as much as its budget: if we care […]
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 […]
Enforcing AML Laws: Significant Potential for Money Laundering? Or Potential for Significant Money Laundering?
On August 13 the federal banking agencies issued a joint statement on updates to their guidance on enforcing BSA/AML requirements. […]
A GAO Report on GTOs Reveals the Underlying Flaws In the Entire American BSA/AML Regime
The General Accountability Office, or GAO, issued a Report on August 14, 2020 titled “FinCEN Should Enhance Procedures for Implementing […]
What Does It Take to Run a BSA Program? Not Much, According to the FDIC
Unfortunately, the FDIC’s estimate of the time and effort it takes to run a BSA/AML compliance program is … laughable. […]
Anti-Money Laundering Act of 2020 – “Pay to Play” Arrives and Perhaps We Have An Answer to the Whereabouts of Section 314(d)
The Senate Banking Committee’s top Republican (Senator Crapo from Idaho) and top Democrat (Senator Brown from Ohio) have joined forces […]
AML360 Podcast – Jim Richards with Stephen Platt
On June 12, 2020 I enjoyed an hour with AML360 talk show host Stephen Platt. For an hour – live! […]
FinCEN’s Estimate of the Costs and Burden of Filing SARs Is Evolving, But Needs Private Sector Input
For years, FinCEN has used a one-size-fits-all-SARs method of determining the costs and burden of filing Suspicious Activity Reports (SARs): […]
FinCEN Director Ken Blanco is Crystal Clear on Virtual Currency Risks & Requirements
FinCEN Director Kenneth A. Blanco, delivered Prepared Remarks at the Consensus Blockchain Conference on May 13, 2020. They are available at Prepared […]