Ray

🧱Building in half public (idk if any of this is going to work)
👁️‍🗨️AML
⛳️Road to low digit cap
ai•crypto•golf•compliance•shitpost

[Ray @rwenner_]

UBS got fined $125M for AML failures this week. The kicker: FinCEN already fined them in 2018 for the same thing. They paid, promised to fix it, and didn't. New article on this, the Saitama crypto extradition, and why hospice fraud is the typology you should be watching right now.

[Ray @rwenner_]

EagleBank's compliance team flagged a check-kiting scheme. Senior management overrode them. For a decade. The $9.7M DOJ settlement this week is not an AML failure. It's a governance failure. There's a difference and the new Fed AML reform proposal doesn't fully address it.

[Ray @rwenner_]

Merrill Lynch's own compliance team documented the monitoring gap. The threshold never changed. The SEC just made that a $7.5M public record. Meanwhile the Fed proposed the most significant AML overhaul in years. Notes on what both mean for people actually running these programs.

[Ray @rwenner_]

Treasury sanctioned a Florida cell that moved $30M in PCC drug money through crypto. FBI arrested six in January. Brazil froze $2B in assets days later. The enforcement coordination worked. The $30M that moved before the disruption is the part worth sitting with.

[Ray @rwenner_]

Evaluating AI outputs in a high-stakes context requires different criteria than consumer apps. The stakes change what 'good enough' means.

[Ray @rwenner_]

I built Caddie Trip because planning golf trips with friends is genuinely terrible. 12 texts, 3 apps, someone always books the wrong dates. 🧵

[Ray @rwenner_]

Made the turn at even par. Shot 47 on the back. Roller coaster smh.

[Ray @rwenner_]

I also suck at marketing my solutions lol...

[Ray @rwenner_]

You can build without a marketing budget if the problem is real enough. That's the whole thesis.

[Ray @rwenner_]

Shell company structures are not inherently suspicious. The question is whether the structure makes sense for the stated business. Most KYC doesn't ask that question.

[Ray @rwenner_]

The hospital sent me to collections for a bill I disputed six months ago. Still have the certified mail receipt. This is exactly what https://t.co/cOBRjTw7fH is for.

[Ray @rwenner_]

Prompt injection attacks on AI tools handling sensitive data are not theoretical. If your compliance tool runs on an LLM, you have an attack surface.

[Ray @rwenner_]

Account takeover fraud looks different than it did three years ago. The attack patterns changed. Most detection programs didn't. 🧵

[Ray @rwenner_]

Greens were bad today. That's my story and I'm sticking to it.

[Ray @rwenner_]

Beneficial ownership rules exist on paper. Enforcement is a separate conversation. Fraud rings know the difference.

[Ray @rwenner_]

Built RegPilot because people kept getting wrecked on obvious rug pulls. The on-chain signals were there. Nobody was surfacing them clearly.

[Ray @rwenner_]

Just realized I've been paying for three streaming services I haven't opened in two months

[Ray @rwenner_]

Crypto mixer usage is not automatically a red flag. Context matters, theres plenty of reasons someone might use a mixer outside of criminals . Most compliance programs don't have a framework for the context part, or even to understand mixers

[Ray @rwenner_]

AI-native compliance is not what the vendors are selling. Here's what it actually looks like when it works. 🧵

[Ray @rwenner_]

Drove it 280 into the fairway on 1. Hit OB on 2. Golf.