Knowledge = Burden
Three stories this week, two threads running through all of them: 1) if you have knowledge, you have burden; and 2) the government keeps shrinking the net while expecting financial institutions to catch more fish.
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Global AML/Sanctions happenings, why it matters, and what you should do next
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Wise gets the Heisman… from the OCC
You may be surprised to hear this – but I’m conflicted a bit on this one.
FinCEN's MX Fuel Smuggling Alert
Took me a minute to digest FinCEN’s Alert-003 concerning fuel smuggling and tax evasion schemes published two weeks ago.
If Cart-Before-Horse Was a (FinCEN) Advisory
Cart = monitoring and reporting of red flags associated with funds transfers involving illegal aliens (FIN-2025-Alert003) or monitoring and reporting of red flags associated with non-work authorized populations and their employers (FIN-2026-A002).
Bucketizing: When Things Get Busy
Last week was slightly busier with 2 Executive Orders, 1 OCC consent order against a fintech-focused community bank, and 1 FDIC consent order (from several weeks ago).
IRGC & The World Cup (Human Trafficking)
FinCEN published an alert and a notice within the last week – covering two very different trends.
Football and the FRB
Anyone watch the National Football League (NFL) draft this week?
Statistical Gymnastics
I should’ve labeled this Dirty Money Weekly-ish.
9 Days, 3 Proposed Rules
FinCEN was busy from March 30th to April 8th, proposing the whistleblower rule, “fight illicit finance” AML/CFT reform rule, and the GENIUS Act’s countering illicit finance rule.
Dear Diary...
This last week was long...