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FinCEN Files Show Banks’ ‘Whack-a-Mole’ Battle Against KYC/AML

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21), Commerzbank recounted in a statement that the transactions detailed in the FinCEN files are “based entirely on reports made by Commerzbank to the responsible authorities, mainly in the period 2010 to 2016,” and that the bank had reached a settlement in 2015 to pay regulators about $1.5 In one example, reported on Monday (Sept.

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