In early 1793, Louis XVI no longer had a need for hats.

Among his sins, he had failed to do an adequate risk assessment of the restless mob, angrier and more powerful than he expected. They rose up in numbers, storming both the fetid Bastille and th...

There is a robust international network working to prevent money laundering. It’s called the FATF (Financial Action Task Force). It has headquarters in Paris and works through nine regional satellite organizations on every continent except Antarct...

On March 2, 2025, the U.S. Treasury announced that US corporations are no longer required to file Beneficial Ownership Information (BOI) reports under the Corporate Transparency Act. 

It’s dramatic - and here’s what that means to you.

First, this c...

 I just rewatched Jaws. Richard Dreyfuss cuts the belly of that Tiger Shark open and, reaching in to his elbow, pulls out a license plate, a beer can, and bits of small tuna. I think today that TD might feel like that shark, with FinCEN, up to its el...

MBA Risk Conference: An elephant in the room

As the MBA panelists concluded, after an hour of dissecting our country’s housing issues, the distinguished speakers had left the number one issue untouched. Hadn’t laid a glove on it. They’d rope-a-doped...

Wells Fargo – when aren’t they in the news?

In a world where financial crime is becoming increasingly sophisticated, banks must remain constantly vigilant and informed to avoid severe penalties. A recent case in point is the U.S. Office of the Compt...

You can't just check the box on generic AML compliance anymore. Here I comment on FinCEN's new proposed rule on BSA compliance.

Risk assessments are becoming increasingly crucial for mortgage lenders, especially with the latest FinCEN proposal that could soon mandate such practices across all financial institutions.

The proposed rule introduces risk assessments as a "sixth p...