A reporter recently interviewed me for a story he was putting together regarding yet another FinCEN official departing for HSBC. This touches on an issue that has concerned me for many years; the revolving door between DOJ, Treasury, and the private sector. Going back over the last twenty years, almost all high ranking Treasury enforcement officials that oversee AML/CFT issues (those heading TFI, FinCEN,OFAC) have come from the DOJ. The creation of DHS made the situation even worse. The problem, of course, is that there used to be healthy competition between the two departments in the area of financial crimes enforcement. Now there is collective DOJ inspired "group think." They approach the issues the same way and offer the same solutions. There has been a defacto DOJ takeover or coup of Treasury enforcement (or what's left of it after the creation of DHS). The lawyers have taken over. Our over-emphasis on sanctions and designations is but one example. What is even more troubling, after doing time in Treasury, most of these high level officials rotate out to the financial industry sector. They are given high salaries and positions in the very financial institutions that they were overseeing. While legal, I'm not sure about the ethics of it all. To me it stinks. Insiders don't want to discuss it because they risk upsetting the "old-boy" network, but I think light needs to be shed on this issue. What do you think?
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