The Risk of Money Laundering Through Crowdfunding: A Funding Portal's Guide to Compliance and Crime Fighting

  title={The Risk of Money Laundering Through Crowdfunding: A Funding Portal's Guide to Compliance and Crime Fighting},
  author={Zachary Robock},
  journal={Michigan Business \& Entrepreneurial Law Review},
  • Zachary Robock
  • Published 2014
  • Business
  • Michigan Business & Entrepreneurial Law Review
With the recent passage of the Jumpstart Our Business Startups Act (“JOBS Act”) and proposed regulations, equity crowdfunding is poised to play an important role in fundraising for many types of emerging growth companies. A fundamental purpose of crowdfunding is to reduce economic barriers to capital markets for emerging growth companies, in part by relaxing rigorous information disclosure requirements currently mandated by the Securities and Exchange Commission (“SEC”). Relaxed regulation… 

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) (lacking any mention of general account termination requirements). 93. FIN. CRIMES ENFORCEMENT NETWORK, supra note 92 (quoting Fin. Crimes Enforcement Network
  • The SAR Activity Rev. Trends Tips & Issues
at Appendix F: Money Laundering and Terrorist Financing
  • Red Flags
Regulation Crowdfunding, supra note 2, § § 227
    )(ii) (2011) (discussing "documentary" methods for verifying customer identification, such as government-issued documents, and "non-documentary" methods
      lacking any mention of general account termination requirements)