We are taking recommendations from the FDIC and trying to implement. As we work through implementation, we realize that what the FDIC said isn't practical.
Imagine that! No, really. We need to be able to bring these rouge examiners and field offices to the table with FinCEN and hold all of these "recommendations" to a harsh light. To me it is RIDICULOUS that banks are WASTING time, energy and resources chasing after errant butterflies just to satisfy an examiner rather than focusing on finding truly suspicious or criminal transactions.
It's like having as a back seat driver someone who has never actually, you know, driven a car!