Anti-money laundering, AML, CFT, combating the financing of terrorism, AML/CFT, Bank Secrecy Act, BSA, trade based money laundering, TBML, FDIC, failing banks, insolvent banks, deposit insurance, statutory protections, Basel…more
Anti-money laundering, AML, combating the financing of terrorism, CFT, AML/CFT, Bank Secrecy Act, BSA, trade based money laundering, TBML, FDIC, failing banks, insolvent banks, bank resolutions, bank bankruptcy, deposit…more
Our thesis is that all those in the supply chain - exporters, importers, freight forwarders, carriers - should be subject to anti-money laundering/counter-terrorist financing (AML/CFT) preventive measures such as customer due…more
This article, published in Current Developments in Monetary and Financial Law, Vol. 5 (IMF 2008), considers the possible legal protections that should be extended to financial supervisors. It begins with a discussion of why such…more
A comparison of US and EU/UK requirements, processes and procedures regarding anti-money laundering (AML) audits. Also discusses international standards - the Financial Action Task Force (FATF) Recommendations - on AML audits…more
A curious thing has happened of late: lawyers have been
appointed by the international community as the new
guardians of governance for their clients. More specifically,
lawyers are increasingly regarded as part of the…more
Every Bank Failure Is a Regulatory Failure
Certainly banks do not fail only because regulators fail in their oversight responsibilities. Many other failures are typically involved in any bank failure, including failures of…more
It is an open secret that the Financial Action Task Force (FATF), is considering a new recommendation on trade-based money
laundering. Its intentions were telegraphed by the publication in June 2006 of its monograph entitled…more
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