White Paper

50 Years of the Bank Secrecy Act

It’s Time to Renew the Purpose of Providing Actionable Intelligence to Law Enforcement

October 2018

To recognize almost 50 years of the Bank Secrecy Act (BSA), thought leader and industry expert, Jim Richards, has produced this thoughtful and insightful whitepaper.

In it, Richards reflects on the circumstances surrounding the birth of the BSA as the Foreign Bank Secrecy Act of 1970, charting its history through various updates and iterations, and exploring how world events, changing technologies, and the fluctuating social and economic climates have informed its evolution through the years. Richards speaks to the purpose of the Act, the difficult times surrounding the 2008 financial crisis and the years that followed, and how the last couple of years have seen a change of intention and approach in the financial crimes risk management industry.

Finally, Richards suggests a subtle but important change to the language of the BSA/AML Manual, centred around “providing timely and actionable intelligence to law enforcement” in order to lead the industry forward into what he calls “an exciting and dynamic time”.


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

Jim Richards is a Senior Advisor to Verafin Inc., the leading provider of fraud detection and BSA/AML collaboration software for financial institutions in North America. Jim is also the principal and founder of RegTech Consulting LLC, focused on developing the next generation of financial crimes technologies and professionals, and providing strategic advice on all aspects of financial crimes risk management.

Prior to founding RegTech Consulting, Jim worked for almost 13 years at Wells Fargo & Co. as the BSA Officer and Global Head of Financial Crimes Risk Management. He was a founding member of the Association of Certified Anti-Money Laundering Specialists (ACAMS) Advisory Board, a three-time member of the Treasury Department’s BSA Advisory Group (BSAAG), and the author of Transnational Criminal Organizations, Cybercrime, and Money Laundering.

  •   BSA/AML Compliance
  •   Money Laundering

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