Abstract

The current presidential administration has proven eager to cut regulations across all industries, including in the financial services, where one of the more cumbersome regulatory regimes is the Bank Secrecy Act (“BSA”) governing anti-money-laundering (“AML”) regulations. The financial industry has justified regulatory easing by arguing that a high level of regulatory scrutiny and financial penalties has caused too many irrelevant suspicious activity reports (“SAR”) to be filed “defensively” which impedes law enforcement authorities’ capacity to detect legitimate crime. This report investigates such claims through a comprehensive literature review and an extensive document analysis to gauge industry sentiment over time. While the statistical findings are not highly conclusive, they suggest that high levels of regulatory fines did lead to an increase in SAR filings. However, that rise does not appear to contribute to a reduction in SAR utility as a whole, in part because developments in technology have allowed authorities to extract valuable strategic insights from the large dataset of BSA filings. However, this report identifies other ways in which the current form of regulatory enforcement may be adversely affecting law enforcement efforts by encouraging de-risking and other informal banking alternatives such as hawala networks and cryptocurrency use. Finally, several ways in which the current AML regulatory regime contributes positively to financial crime detection and prevention are identified, which suggests that any regulatory reform should be judicious.

Manhattan District Attorney’s Office, New York – Financial Intelligence Analyst September 2017 – Current

Major Economic Crimes Bureau – International Money Movement Center

BDO Consulting, New York – Litigation Manager, Investigative Due Diligence November 2015 – June 2017

Credit Suisse, New York – Assistant Vice President May 2013 – October 2015

Veracity Worldwide, New York – Analyst; Associate January 2010 – May 2013

Credit Suisse, New York – Analyst (Client Service Representative) June 2008 – December 2009

Education

• New York University, New York GPA:3.98 May 2020

M.S. in Global Affairs (Transnational Security)

• Stony Brook University, New York GPA:3.80 May 2008

B.S. in Business Management (Finance); Economics

• Certification: Certified Anti-Money Laundering Specialist (CAMS)

Knowledge and Skills

• LexisNexis; Clear; TLO; Factiva; Westlaw; Pacer; WorldCheck

• i2 relationship mapping

• Fluent in Russian

• Experience with BSA/AML Compliance; FCPA; and OFAC

• Open-source, US public records, and legal research

• FinCEN BSA filing database

• Subpoena processing and compliance