New GAO study released February 26. Linked to the right is a "Highlights" page as well as the full report, 117 pages.

To me, this seems to have arrived a full three years after the issue was hot. The news stories were rampant. Now there are none. The regulators issued their pronouncements for public consumption, then they ignored them.

Whether the "de-risking" stories focused on MSBs, cross border businesses, businesses with private ATMs, or international charities really makes no difference. Regulatory pressures sometimes make it difficult for banks to maintain profitable relationships and, accordingly, banks will terminate those relationships. The banks' actions are the "effect," they are not the "cause."

Click on the "Recommendations" tab. My understanding is the regulators have all agreed to study potential revision of the BSA regulations to stop this trend. They are waiting to hear from FinCEN.

We actually participated in this study. Interesting to see the results.