Tag Archives: FinCEN

A sprinkling of SAR-dust

There is regularly – and quite rightly – a fair amount of soul-searching about the SARs regime.  Does it shift the burden of investigation from law enforcement to the financial sector?  Does it cost much more than it saves?  Are … Continue reading

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SARs in tiaras

I love FIUs, you know I do.  But they do vary enormously in how they interpret (or, perhaps more realistically, can persuade the holders of their government purse strings to interpret) FATF Recommendation 29 that (my emphasis) “Countries should establish … Continue reading

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