the judicial discretion or disposition in the final case outcome , rather than for any actual charges of perjury being sought . Left open is the question of just how egregious these lies , perjuries or misrepresentations must be to warrant the consideration of a separate and specified investigation .
Now that AML / BSA monitoring efforts can literally identify financial anomalies at pocket-change levels , the emerging question becomes which anomalies should be further investigated . This has always been a question when addressing crime in general . Society seems to continually fluctuate between zero tolerance to overly tolerant in various enforcement or abatement efforts . The only thing new is that tech-enhanced monitoring is now enabling the concept of “ following the money ” in even the pettiest of crimes and financial indiscretions . This may be the equivalent to that 10 mph leeway for speeding as it relates to AML / BSA monitoring and enforcement . The peer-to-peer sports betting pattern of a klatch may now be picked up by AML / BSA monitoring , but like Keith ’ s low-level tax cheating , few would find the activity egregious enough to warrant using enforcement resources to abate it .
When should BSA scofflaws be treated like serious criminals ?
General law enforcement ( LE ) investigative practices have had to adjust to many technological and scientific advances . Videos , voice recordings and incriminating texts of crimes are now commonplace . Conversations and suspect identities once left to unreliable memories are often now documented and digitally preserved . In the AML / BSA world of following the money , we now have documented swipes and taps for even the smallest of transactions . The question this raises for AML / BSA enforcement efforts is whether the offender being dealt with is a routine speeder or a more serious type of scoundrel .
tech-enhanced monitoring is now enabling the concept of “ following the money ” in even the pettiest of crimes
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