One Bank Asked the OCC to Have an “Agile Approach to Supervisory Oversight” On September 27, 2019 the OCC published […]
News
FinCEN’s Marijuana Banking Data … What Is Not There That Should Be There
FinCEN’s quarterly Marijuana Banking update: it is not what is being reported … it is what is NOT being reported! […]
USDA’s Interim Final Rules for Hemp Production – Summary & Highlights
“The future of the hemp industry in the United States is anything but certain.” – page 71 The Interim Final […]
Hemp’s “Key Participants” ≠ Banking’s “Beneficial Owners” … Pick One!
On October 31st the US Department of Agriculture published proposed regulations (technically, an interim final rule with request for comments) […]
The Current BSA/AML Regime is a Classic Fixer-Upper … and Here’s Seven Things to Fix
There is a lot of media attention around the need for a new way to tackle financial crimes risk management. […]
Cannabis Banking Legislation – Will the SAFE Banking Act Actually Result in More Banks Providing Financial Services to Marijuana Related Businesses?
In the last two years, the percentage of banks actively banking (federally illegal and unregulated) marijuana related businesses (MRBs) has […]
Cryptocurrencies – A New Crypto Rating Council Tries to Handicap the Likelihood a Cryptocurrency is a Security
Crypto Rating Council A group of crypto financial services firms and exchanges have formed the Crypto Rating Council, or CRC […]
SAFE Banking Act of 2019 – Some Suggestions for the Senate
The SAFE Banking Act, HR 1595, was approved by the House on September 25, 2019. As written, it is a […]
FinCEN’s BSA Value Project – An Effort to Provide Actionable Information for SAR Filers
Two Million SARs are Filed Every Year … But Which Ones Provide Tactical or Strategic Value to Law Enforcement? On […]
The WayBack Machine … and the Marihuana Problem in New York (circa 1944) – updated with the OFAC Fentanyl Drug Trafficking Organization Designation of August 21, 2019
One of the greatest investigative tools available today is the Internet Archive, a “non-profit library of millions of free books, […]