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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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  Blog

AML Act of 2020 Formalizes Risk-Based Approach for Compliance

July 28, 2021 by Jim Richards

The fifth instalment in Jim Richards’ Renewing the BSA Series. Under the current law, 31 USC Section 5318(h) and it’s subsequent regulations, financial institutions are required to have an Anti-Money Laundering (AML) program, but there has never been a requirement... 

  Blog

A Mandate for Innovation in the AML Act of 2020

May 28, 2021 by Jim Richards

The fourth instalment in Jim Richards’ Renewing the BSA Series. Innovation is a key theme throughout the Anti-Money Laundering Act of 2020 (AMLA or the Act). As financial crimes evolve and regulatory compliance commitments advance, financial institutions need innovative solutions... 

  Blog

Information Sharing Prioritized in AML Act of 2020

March 4, 2021 by Jim Richards

The third instalment in Jim Richards’ Renewing the BSA Series. Many professionals are touting the Anti-Money Laundering Act of 2020 (AMLA) as the biggest change to American efforts to fight crime and corruption since the USA PATRIOT Act of 2001... 

  Blog

AML Act of 2020 Progresses SAR Regime

February 19, 2021 by Jim Richards

The second instalment in Jim Richards’ Renewing the BSA Series. On January 1, 2021 the United States Senate approved the National Defense Authorization Act (NDAA), and with it, the most significant legislation addressing the U.S. Anti-Money Laundering and Countering the... 

  Blog

A Brief Introduction to the AML Act of 2020

February 12, 2021 by Jim Richards

The first instalment in Jim Richards’ Renewing the BSA Series. The landscape of the Bank Secrecy Act (BSA) is changing. The latter half of 2020 saw repeated calls to examine and modernize Anti-Money Laundering (AML) and Countering the Financing of... 

  Blog

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... 

  Blog

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...