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From the President
By Cynthia Hujar Orr
President's Column columns.
Calling them professional money launderers,1 the Bush administration announced in 2001 its goal to investigate lawyers, bankers, and accountants. The strategy lacked any objective measure of its effectiveness to stem money laundering.2 But it moved ahead, fueled by frustrations that law enforcement lacked sufficient training and expertise to investigate complex business entity and financial structures.3
The Bank Secrecy Act (BSA) and its regulations were originally intended to help prevent financial institutions and money services providers from wittingly or unwittingly being used to disguise, move, or hold proceeds of unlawful activities. The Office of the Comptroller of the Currency monitors compliance with the BSA through Suspicious Activity Reports (SARs), Currency Transaction Reports (CTRs), Currency or Monetary Instruments Reports (CMIRs), and bank examinations. Congress centralized the filing of SARs and extended requirements to nonbanking institutions such as check cashing stor
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