Essays by Andres Garcia on BSA/AML, sponsor-bank oversight and what examiners expect, drawn from more than a decade running compliance programs. Written for fintechs, BaaS companies and the banks that sponsor them, and published only when there is something useful to share.
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What the Bank Secrecy Act figured out about cooperation under uncertainty, and why it reads like a template
The new AI executive order asks the most powerful companies in the world to please submit their models for review. I spent a decade inside the reporting system its reaching for. Voluntary doesn't work
The biggest names in AI just asked Congress to make DNA screening and recordkeeping mandatory. I spent a decade running exactly that system. They are right, and they stopped too soon.
The Record is the thinking. The work is independent testing, control testing and readiness, performed against every record.