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« And The Winners Are...Trial Lawyers | Main | Doing The Chavez Shuffle »

January 29, 2008


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The BSA fetish has gone over the borderline into the realm of psychosis. Banks have to pray that the federal agencies move into the next new thing before banks start going all "Saw IV" on bank examiners.


I think you are right on target. Although I've voted Republican in every presidential election since 1976, I'm seriously considering voting Democrat for the first time.

The Bush adminstration (with the initial support of Congress) has opened the kennel doors and taken off DOJ's leash when it comes to the domestic "fight against terrorism." They have conviced most Americans that "the fight" is above liberty.

A recent article I read on stated that over 50% of Americans feel that security is more important than privacy.

Now we can add "preventing money laundering" to the list to the things that are above everything else.

Many banks think that the majority of MSBs are good folks. Many banks regularly file SARs on customers who appear to be structuring transactions to evade CTRs. If this mess created by DOJ spills over to affect banks who provide services to MSBs, then the MSBs might as well close up shop because *nobody* will take them as customers. If banks are expected to "prevent laundering" then the result will be that any customers who even smell like they are structuring transactions will find themselves kicked out the door.

This situation has the potential to be a much bigger deal than most people realize.

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