FinCEN’s “De-risking” Message Not New
FinCEN's recent message instructing financial institutions not to "de-risk" whole industries, such as money service businesses, in favor of making decisions on a case-by-case basis is not exactly new. FinCEN issued a similar statement a decade ago. But it is clear that federal authorities are on the defensive that their approach has been heavy handed as of late. [11/11/14]