- 35 years of government and private sector experience in law enforcement, regulatory and management expertise in the areas of regulatory compliance, financial crimes and customs violations
- Expertise includes independent reviews and investigations, threat/risk assessments, domestic and international training, expert testimony and anti-money laundering program development
- Former Deputy Director, Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of the Treasury
- Former Executive Director of Operations, Director of Financial Investigations, Group Supervisor, and Special Agent for the U.S. Customs Services
- All 10 Best Practices
- Pre-Meeting Discovery Process
- One-on-One Call with Expert
- Meeting Summary Report
- Post-Meeting Engagement
Anti-Money Laundering - Money Services Businesses (MSBs)
- Independent Review Report
- The Independent Review Report is the MSB's assessment of the adequacy of its AML program.
- CTR - Currency Transaction Report
A bank must file a Currency Transaction Report (CTR) for each transaction in currency (deposit, withdrawal, exchange, or other payment or transfer) of more than $10,000 by, through, or to the bank.
Multiple currency transactions totaling more than $10,000 during any one business day are treated as a single transaction if the bank has knowledge that they are by or on behalf of the same person. Transactions throughout the bank should be aggregated when determining multiple transactions.
- Prepaid Access Final Rule
Sellers of prepaid access will need to develop and implement an effective AML program, report suspicious activity, and comply with recordkeeping requirements related to customer identifying information and transactional data.
Suspicious Activity Report