In 1829, an engineer named Francis Xaver Riepl and the Austrian banker Salomon von Rothschild decided that the Austro-Hungarian Empire was ready to enter the Railroad Era.
The two men went to the court of the Habsburg Emperor Francis I and requested permission and funds to build Austria’s first steam-powered railroad line.
But Francis was not blind.
His family dynasty had ruled large swaths of Europe and all of Austria for more than 550 years, and it hadn’t maintained its dominion for centuries by ignoring threats to its power.
The emperor knew exactly what was happening to the British monarchy and nobility as the industrial revolution overhauled Britain, and wanted no part of it.
Next step in AML overhaul: Simplify SARs
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On December 10, 2020, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a Fact Sheet clarifying the circumstances under which financial institutions can share information under Section 314(b) of the USA Patriot Act (“Section 314(b)”), 31 C.F.R. § 1010.540. In a speech on the same day, FinCEN’s director, Kenneth Blanco, urged financial institutions to take advantage of the program.
Section 314(b) is a safe harbor provision that protects financial institutions from liability when disclosing customer information to other financial institutions in order to flag possible money laundering or terrorist activities. Financial institutions can use the program to gather information about customers with flagged activity, including accounts held away from the institution, activities, and associated entities or individuals. While widely utilized, the program has often been c
Tuesday, December 22, 2020
On December 10, 2020, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a Fact Sheet clarifying the circumstances under which financial institutions can share information under Section 314(b) of the USA Patriot Act (“Section 314(b)”), 31 C.F.R. § 1010.540. In a speech on the same day, FinCEN’s director, Kenneth Blanco, urged financial institutions to take advantage of the program.
Section 314(b) is a safe harbor provision that protects financial institutions from liability when disclosing customer information to other financial institutions in order to flag possible money laundering or terrorist activities. Financial institutions can use the program to gather information about customers with flagged activity, including accounts held away from the institution, activities, and associated entities or individuals. While widely utilized, the program has often been criticized for faili
On December 10, 2020, Kenneth Blanco, Director of FinCEN, issued public
comments at the American Bankers Association/American Bar Association Financial Crimes Enforcement Conference announcing new
FinCEN guidance for covered financial institutions to utilize the voluntary information sharing provisions of section 314(b) of the USA Patriot Act (“Guidance”). The Guidance encourages information sharing under section 314(b) and emphasizes the potential breadth of the provision, which protects compliant financial institutions from civil liability.
Section 314(b) Summarized
Section 314(b) provides that a financial institution required by the Bank Secrecy Act (“BSA”) to have an anti-money laundering program, or an association of such financial institutions, may “share information with any other financial institution or association of financial institutions regarding individuals, entities, organizations, and countries for purposes of identifying and, where appropriate, report
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