The QuickCEN™️ Comprehensive BSA / AML Research System is a unique tool for research on laws administered by the United States Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN). QuickCEN collects, curates, categorizes, and in many cases annotates, over 1,150 discrete items that bear on the scope and operation of the Bank Secrecy Act and its implementing regulations. The QuickCEN Research System was inspired by Sanctions Inc.'s anchor product, TURBOFAC, and leverages the same groundbreaking research interface and methodology.
The Research System’s interface contains dozens of discrete search criteria, unique to QuickCEN, which populate search results from a vast database of manually reviewed items classified in accordance with the relevant search criteria. The defined document type categories and search criteria are specifically designed to facilitate AML practitioners’ efficient location of particular items relevant to the resolution of difficult BSA/AML-related questions.
All items in the database have been reduced to plain text—even when the source file is a poor-quality scanned PDF file—such that each item is text searchable, text search locatable, and filterable by qualitative subject matter. Native PDF files are available for viewing and download as well. We treat every regulatory provision, statutory provision and every relevant item published by FinCEN as a discrete searchable item.
For a limited time, we are offering full access to QuickCEN™️ at the institutional level for a yearly subscription fee of $750. To register, contact [email protected], call (212) 786-6467, or click the registration link above.
QuickCEN™️ is an unregistered trademark of Sanctions Inc., a Delaware Corporation that is the owner and operator of TUBOFAC®️ research and interview systems for OFAC-related sanctions compliance (available at sanctions.org). Neither Sanctions Inc., www.sanctions.org nor QuickCEN™️ are affiliated with, or endorsed by, any government agency, including the United States Department of the Treasury’s Financial Crimes Enforcement Network. We are an Affiliate Member of the Association of Certified Sanctions Specialists.
QuickCEN™️ is owned and operated by Sanctions Inc., a Delaware Corporation. The website is the product of a team led by Brian M. Gatta, a seasoned sanctions attorney with over a decade of experience in private practice at leading international law firms. Brian graduated Columbia Law School in 2007.
Items are generally added to the Research System and fully categorized for searchability within 24 hours of us being made aware of their existence. The Research System commentaries corresponding to the individual documents can take longer to prepare, depending on the complexity of the document added. Consult the “Updates” page for an accounting of what additions have and have not been made to the Research System. Subscribers to the Research System can also check for updates by selecting all items issued or last amended in the current year and sorting them from newest to oldest in the search results screen.
QuickCEN™ is operated and maintained by personnel with experience as counsel at large law firms, but QuickCEN™ is not engaged in the provision of legal advice or the formation of attorney-client relationships. For site users in need of a live compliance advisor, including legal counsel, we can draw on our experience in the industry and network of practitioners to recommend counsel that we would consider appropriate for a given set of issues. BSA/AML compliance advisors can vary significantly in terms of price and skillset. Recommendation requests can be directed to [email protected].
QuickCEN™ is designed to be a vast improvement upon FinCEN's website and other available legal databases as it relates to the particular task of finding relevant publicly available, BSA-related primary source material. TURBOFAC®, by contrast, includes over 6,000 pages of original commentary and annotations, several hundred discrete search criteria, and hundreds of private guidance letters and other important sources of information that are not otherwise publicly available. For more information on the TURBOFAC® value add proposition, see the TURBOFAC FAQ page.
Many of the documents that we have reduced to plain text needed to be transferred from .pdf files. Of those, the native files are often poor-quality scans. We have taken every document available on the Research System database, run it through a top-of-the-line optical character recognition (OCR) software program, and from there reviewed it manually to make further corrections. However, this process leaves room for some errors at the margins. The reduction of documents to plain text is done primarily to facilitate text searchability. Before relying on any document, you should review the original version found in the native .pdf frame or external link to ensure that the plain text found on the Research System reflects what appears on the original file.
The Research System contains hundreds of interpretive guidance letters, specific licenses and other communications issued by OFAC to private parties.
Virtually all of these documents were i) obtained via the Freedom of Information Act, ii) included in court dockets, e.g. buried in exhibits to federal court filings available on PACER, or iii) otherwise released into the public domain by the party (or a representative thereof) corresponding with OFAC. Some were found in the National Archives.
We have put considerable effort into obtaining every document of interpretive relevance that we have been able to locate. We do not believe that anything on the Research System is subject to any form of restriction on its dissemination, but if you have cause to disagree please contact [email protected] and identify the document at issue.
Absolutely. If you are aware of something that is not on the system but should be, please send it to [email protected] and we will add it to the system as soon as practicable. By submitting a document for addition to the system, you represent that it was properly obtained and that you are at liberty to release it to the public. If you would like to submit a document with redactions, make all redactions you deem necessary, and we will add it to the system if we consider interpretive value to exist notwithstanding the redactions.
No. All classifications of items housed on the database are the product of manual review and classification. Classifications are the product of judgment calls based in large part on qualitative criteria, especially where the classifications involve the identification of the treatment of important recurring legal issues. The only aspect of the Research System that is “automated” is the hyperlinking found in the commentary portion of the individual document pages. Internal links are automatically generated on the basis of certain text strings that are associated with items in the database. It is for that reason that the first instance of a given text string associated with a system document will appear as a hyperlink, but only the first instance.
Yes
We have set up the QuickCEN internal linking system so that when a user reads a document in plain text format our software automatically inserts hyperlinks to the database entries for the relevant statutory or regulatory provisions. For documents that contain references to FinCEN’s regulations as they existed prior March 1, 2011, i.e. the regulations at 31 CFR Part 103, we have made it so those 31 CFR Part 103 links automatically direct the user to the 31 CFR Chapter X equivalent, to the extent that the provision is one that was moved from 31 CFR Part 103 to 31 CFR Chapter X on a word-for-word basis. For more information, see FinCEN’s 31 CFR Chapter X Translator.