System check - some proposals for reforming US AML inspired by the FinCEN Files

Matthew Stephenson (+1 (617) 495-9863, mstephen@law.harvard.edu) is Professor of Law at Harvard Law School, where he teaches administrative law, legislation and regulation, anti-corruption law, and political economy of public law.

In the wake of the leak of SARs from FinCEN, revealing major banks’ ongoing dealings with some highly suspicious customers, there is renewed appetite to change the calculus that makes such conduct profitable. Matthew Stephenson, Professor of Law at Harvard Law School, advances potential legal and financial correctives.