
Daniel P. Stipano
Head of AML/CFT, Davis Polk & WardwellDaniel P. Stipano is the head of the AML/CFT practice at Davis Polk & Wardwell LLP and the former deputy chief counsel at the Office of the Comptroller of the Currency.

Daniel P. Stipano is the head of the AML/CFT practice at Davis Polk & Wardwell LLP and the former deputy chief counsel at the Office of the Comptroller of the Currency.
It is long past time to revisit the regulatory regime implementing the Bank Secrecy Act. In a good sign, key elements of the Trump administration seem to be in alignment on reform.
The rule requiring businesses to report their beneficial ownership is deeply flawed. Enforcement should be suspended until it can be revised to place fewer burdens on law-abiding people and companies.
Without rollbacks of existing anti-money-laundering reporting requirements, a measure designed to make Bank Secrecy Act enforcement more risk-focused would do little to ease banks' regulatory burden.
Without rollbacks of existing anti-money-laundering reporting requirements, a measure designed to make Bank Secrecy Act enforcement more risk-focused would do little to ease banks' regulatory burden.
Legislation that would force transparency around company ownership would be better than another burdensome anti-money-laundering rule.
The objectives of a Financial Crimes Enforcement Network rule requiring financial institutions to collect “beneficial ownership” details are laudable, but the regulation can be subverted by unscrupulous customers.
As the Bank Secrecy Act approaches its 50th anniversary, legitimate questions have arisen about the efficacy of anti-money-laundering requirements and the burden of compliance.