Overview
The National Journal cited Jack Hayes in an article titled “Why the Trump Organization Can Play Dumb on Money Laundering.” The article, published October 1, explains that the law defines financial institutions as businesses and professions that could be vulnerable to money laundering or financial crime—banks, brokers, insurance companies, and even casinos. The Bank Secrecy Act statute that defines financial institutions was amended by the PATRIOT Act to include persons involved in real estate closings and settlements.
Mr. Hayes explains that FinCEN hasn’t published final regulations implementing specific anti-money-laundering-compliance obligations that apply to such persons as financial institutions.
The full article can be read at the National Journal.
