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11 04, 2022

CBDC11

2023-03-02T11:28:47-05:00April 11th, 2022|1- Financial Services Management|

Treasury Digital Dollar

Progressive Democrats in the House have introduced an alternative digital-dollar proposal (“e-cash”) to the “FedAccount” construct urged by Senate progressives that mandates an electronic currency created by the Treasury Department to devise an electronic substitute for physical fiat currency. The measure acknowledges at least some of the challenges in doing so (e.g., obstacles for those with disabilities or limited broadband access), but nonetheless mandates a very fast-paced implementation schedule that is governed by a new Treasury office with senior status and considerable independence. While a new inter-agency council would be established to address issues such as conflicts between e-cash issuance and monetary policy, the bill itself otherwise fails to address this fundamental question, as well as many others such as how it achieves privacy and anonymity goals….

CBDC11.pdf

6 01, 2022

AML135

2023-04-25T15:44:59-04:00January 6th, 2022|1- Financial Services Management|

AML/CFT Regulatory Reform

As the banking industry has long hoped and Congress last year directed, FinCEN is beginning to develop a new policy framework prioritizing ways to make anti-money laundering (AML) and countering the financing of terrorism (CFT) regulation more risk-based.  FinCEN is taking the opportunity of its request for information (RFI) also to seek views on ways to modernize AML/CFT standards, make them more efficient, ensure adherence to global protocols, and toughen rules where necessary to protect national security.  Last year’s law required Treasury to enhance law enforcement and submit a report on AML/CFT reform by January of 2022.

AML135.pdf

6 01, 2022

Analysis of AML/CFT Regulatory Reform

2023-04-25T15:45:12-04:00January 6th, 2022|The Vault|

As the banking industry has long hoped and Congress last year directed,1 FinCEN is beginning to develop a new policy framework prioritizing ways to make anti-money laundering (AML) and countering the financing of terrorism (CFT) regulation more risk-based. FinCEN is taking the opportunity of its request for information (RFI) also to seek views on ways to modernize AML/CFT standards, make them more efficient, ensure adherence to global protocols, and toughen rules where necessary to protect national security. Last year’s law required Treasury to enhance law enforcement and submit a report on AML/CFT….

The full report is available to retainer clients. To find out how you can sign up for the service, click here.…

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