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Author Archives: Jim Richards

mmAbout Jim Richards

Senior Strategic Advisor, Verafin; Founder and Principal, RegTech Consulting LLC; Former Executive Vice-President and Director of Financial Crimes Risk Management, Wells Fargo

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Defining Moments in the War on Financial Crimes

June 30, 2020 by Jim Richards

Fifty years ago, the law we now call the Bank Secrecy Act (BSA) was passed, and the war on financial crimes truly began. The BSA began with the Currency and Foreign Transactions Reporting Act of 1970. In the years that followed,... 

  Blog

Analysis & Commentary: FinCEN’s Proposed Burden Estimate for Preparing and Filing SARs

May 29, 2020 by Jim Richards

On May 26, 2020, the Financial Crimes Enforcement Network (FinCEN) published a Notice in the Federal Register titled “Proposed Updated Burden Estimate for Reporting Suspicious Transactions Using FinCEN Report 111 – Suspicious Activity Report.” This Notice is required under the... 

  Blog

Deconstructing the Currency Transaction Report

February 18, 2020 by Jim Richards

With FinCEN reporting increases in BSA report filings year over year, it is likely that over 16 million Currency Transaction Reports, or CTRs, were filed in 2019, each one reporting one or more cash transactions made by or on behalf... 

  Blog

The Bank Secrecy Act Doesn’t Really Exist

January 15, 2020 by Jim Richards

Happy New Year! Happy New Decade! But most importantly, Happy 50th Anniversary of the Bank Secrecy Act! Yes, the (so-called) Bank Secrecy Act was passed fifty years ago this October. As every BSA/AML professional knows, the Bank Secrecy Act was first made... 

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Actionable Intelligence: The Way Forward for the BSA

November 7, 2018 by Jim Richards

From its birth on October 26, 1970 as the Foreign Bank Secrecy Act of 1970, through make-overs in 1986 (criminalizing money laundering and structuring), 1990 (establishing FinCEN), 1992 (introducing Suspicious Activity Reports), and 2001 (the biggest make-over with the USA... 

  Blog

A Brief History of the BSA

November 7, 2018 by Jim Richards

From its birth on October 26, 1970 as the Foreign Bank Secrecy Act of 1970, through make-overs in 1986 (criminalizing money laundering and structuring), 1990 (establishing FinCEN), 1992 (introducing Suspicious Activity Reports), and 2001 (the biggest make-over with the USA... 

  Blog

Finding Renewed Purpose in the Bank Secrecy Act

November 7, 2018 by Jim Richards

From its birth on October 26, 1970 as the Foreign Bank Secrecy Act of 1970, through make-overs in 1986 (criminalizing money laundering and structuring), 1990 (establishing FinCEN), 1992 (introducing Suspicious Activity Reports), and 2001 (the biggest make-over with the USA...