This week, Transparency International released its Corruption Perception Index for 2023. John and Elliot discuss the Index and several other items and their meaning for the financial crime compliance community.

This week, George Mason University published a report about Anti-Muslim Discrimination and Information Manipulation, the Basel Institute on Governance reported on successful efforts to improve public integrity in Peru, and the GAO issued a report on the need for more accurate collection of data on foreign investment in US farmland. John and Elliot discuss these items and others and their meaning for the financial crime compliance community.

This week Nasdaq issued its 2024 Global Financial Crime Report, the UN Office of Drugs and Crime released a report on casinos, underground banking, and money laundering, and the Anti-Defamation League published a report on the use of cryptocurrency exchanges by US extremists to foster their fundraising efforts. John and Elliot discuss these reports and their meaning for the financial crime compliance community.

Jim Lee, IRS:CI Chief, returns to AML Conversations to share his thoughts on the IRS:CI 2023 Annual Report, the work of the J5, several key IRS cases, and the first coverage of the 2023 BSA Data Challenge.

We talked with John Byrne and Elliot Berman about what they see as the trends in financial crime prevention for 2024.

This week, several interesting reports were released. Eurasia Group issued its Top Risks 2024, Human Security Collective published The Future of FATF Recommendation 8, FinCEN issued a Financial Trend Analysis and much more. John and Elliot discuss these and their meaning for the financial crime compliance community.

This week, the US Beneficial Ownership Registry went live, Senator Menendez was charged with additional allegations, export enforcement is back in the news, the US Department of Justice received new authority in foreign bribery cases and much more. John and Elliot discuss these and their meaning for the financial crime compliance community.

This episode originally aired on September 22, 2023 The Financial Crimes Enforcement Network (FinCEN) has published a Small Entity Compliance Guide for beneficial ownership information. A set of FAQs accompanies the guide. John and Elliot discuss the guide, the current compliance deadlines announced by FinCEN, and their thoughts on what may change shortly. They also chatted about a recent consent order between FinCEN and an international banking entity in Puerto Rico.

This week, an advisory on spear-phishing was issued, the US Department of Justice brought indictments for an $80 million pig butchering scheme, and several other interesting things surfaced. John and Elliot discuss these and their meaning for the financial crime compliance community.

This week, the US Treasury issued a Fact Sheet on its action to disrupt corruption, FINTRAC levied fines against another bank for AML/CFT program violations, The US House passed changes to the beneficial ownership registry rules, and several other interesting things surfaced. John and Elliot discuss these and their meaning for the financial crime compliance community.

Concluding our four-part series on Artificial Intelligence (AI), David McLaughlin, Founder of QuantaVerse and the current EVP of Technology Sales at AML RightSource, alongside our brilliant Principal Data Scientist, Leandro Loss, discuss how AI solutions are crafted and how their extraordinary capabilities are reshaping compliance; now, and in the future. Tune in to find out more about how this powerful technology can be our ally in the battle against financial crime.

We talk with Mark Freedman, an international security expert who covers how to react to terrorism by Hamas and other criminal organizations and how geopolitics and intelligence gathering assist corporations in addressing risk.

We talk to Oliver Wyman and Atlantic Council’s Dan Tannebaum about the state of sanctions, their value as a national security tool, recommendations on detecting sanctions evasions, and what to expect going forward.

It has been another busy week. The Center for International Private Enterprise issued a report on the importance of business integrity to the rebuilding efforts in Ukraine. The IRS issued an alert on charity scams. The US Treasury was urged to push the IMF to increase enforcement of its 2018 Governance Framework, and FinCEN issued a statement about the Counter Terrorism Financing Taskforce. John and Elliot discuss these communications and their meaning for the financial crime compliance community.

What can we learn? In an exclusive interview with the Project Manager of the Basel AML Index, John sits down with Kateryna Boguslavska, who has overseen the Index since 2017, and covers the key themes and takeaways for the global AML community.

Global cryptocurrency exchange giant Binance, was hit with a consent order earlier this week. John and Elliot, joined by Joe McNamara (AML RightSource) discussed the recent consent order against Binance, highlighting two main themes: the collaboration among various law enforcement agencies and the focus on cryptocurrency compliance. They noted the importance of law enforcement working together and the need for crypto exchanges to adhere to traditional anti-money laundering (AML) obligations. The discussion also covered Binance's failures in reporting transactions linked to terrorism, ransomware, child sexual abuse materials, and darknet activities, and the team's reflections on the implications of this case for the broader financial and regulatory community. Happy Thanksgiving, everyone.

It has been another busy week. The Basel Institute on Governance released its AML 2023 Index. The US and the UK issued sanctions on Hamas leaders and financiers, and the US House Financial Services Committee approved several interesting new bills. John and Elliot discuss these activities and their meaning for the financial crime compliance community.

John talks with Chuck Taylor of our Financial Crime Advisory about recent discussions in the popular press about why banks close customer accounts.

It has been a busy week. FinCEN issued an alert and final rule, OFAC issued sanctions against cartel activity on fentanyl, and Canada and the UK adopted new laws on beneficial ownership reporting. John and Elliot discuss these actions and what they mean for the future.

It has been a busy week. FATF released the outcomes from its October Plenary, the Biden Administration issued an Executive Order on Artificial Intelligence, and the US Supreme Court heard arguments about asset forfeiture. John and Elliot discuss the possible impact of these actions and what you should watch for going forward.

Step into the exciting realm of cutting-edge AI technology! Join our host, Rachel Dettmer, as she welcomes back our esteemed Principal Data Scientist, Leandro Loss, for an engaging discussion on Large Language Models. Together, they delve into thought-provoking questions: How will these models revolutionize anti-money laundering and financial crime compliance? Are human investigators at risk of being superseded by these models? Why are regulators apprehensive of their inclusion into compliance programs? Tune in as they discuss the intersection of technology and compliance in an evolving financial crime landscape!

FinCEN has issued a new regulation, renewed its real estate geographic targeting orders, and published an alert regarding terrorist financing. John and Elliot discuss this flurry of activity and why each element is important in today’s operating environment.

John and Elliot examine how different things come together in financial crime prevention efforts. They discuss a recent release from AUSTRAC about the connection between cybersecurity and AML/CFT compliance and an interesting blog post from the Council on Foreign Relations on the nexus of human trafficking, democracy, and corruption.

In this episode, Leandro Loss, our Principal Data Scientist, and Kevin Lee, our Director Financial Crime Technology, delve into the trustworthiness of AI, why it's often viewed as an enigmatic 'black box', and why conventional 'white' models are falling short in the battle against financial crime.

It's clear that terrorist financing is still a global problem that demands consistent vigilance. John and Elliot discuss the importance of being vigilant and the challenges nations and organizations face worldwide.

Jonathan Lopez joins John to discuss the state of corruption, how prosecutors see their cases, advice for BSA/AML officers to avoid personal liability, and other white collar issues.

This week Elliot and John come to you from the ACAMS Assembly in Las Vegas. They discuss some of the highlights from sessions at the conference and talk about why the work of the financial crime compliance community is so important.

Kira Zalan, Investigative Editor of the Organized Crime and Corruption Reporting Project (OCCRP) discusses the continuing need for investigative journalism, the dangers of reporting, and some examples from their various projects and stories.

Learn the fundamentals with our expert and demystify the world of Artificial Intelligence! In this episode, Leandro Loss, our esteemed Principal Data Scientist, unravels the core concepts of Data Science, Artificial Intelligence, Machine Learning, and Deep Learning. Prepare to delve into the realm of AI as he shares his vast knowledge and discusses the urgent need for data-driven solutions to combat financial crime in today's fast-paced and rapidly changing world.

In a busy week, John and Elliot discuss the corruption and bribery indictment of US Senator Robert Menendez, an adverse ruling in the civil case against the Trump Organization, a recent package of bipartisan legislation from the House Financial Services Committee, and the looming shutdown of the US government.

The Financial Crimes Enforcement Network (FinCEN) has published a Small Entity Compliance Guide for beneficial ownership information. A set of FAQs accompanies the guide. John and Elliot discuss the guide, the current compliance deadlines announced by FinCEN, and their thoughts on what may change shortly. They also chat about a recent consent order between FinCEN and an international banking entity in Puerto Rico.

The US Department of State has issued its Implementation Plan for the US Strategy on Countering Corruption. The five-pillar Plan outlines actions for the department, its agencies, and its domestic and international partners. John and Elliot discuss the plan and its impact on global anti-corruption efforts.

The Inspector General from the US Treasury Department has issued an audit report on FinCEN’s BSA data retention processes. The Financial Conduct Authority in the UK is reviewing the treatment of domestic PEPs by financial services companies. Moody’s Analytics issued a white paper on wildlife trafficking. John and Elliot discuss these developments and what you should know about them.

Stef Cassella joins John for the record-breaking third appearance. They discuss: How Stef has been assisting other countries in drafting forfeiture legislation (criminal and civil) and in training their prosecutors and judges, a recognition in countries that are used as money laundering centers that they need a means to deter foreign criminals from using their financial institutions for that purpose What the congressional proposal called the “FAIR Act” would do to the civil forfeiture infrastructure and Stef’s view on an upcoming Supreme Court case, Culley v. Marshall, where Plaintiffs ask the Court to recognize a right to an immediate post-seizure hearing whenever law enforcement seizes property for civil forfeiture.

The International Crisis Group issued a report on the impact of sanctions on peacemaking. John and Elliot discuss critical insights in the report. They also examine whether or not sanctions against Russia have been effective and several other news items of the week.

The Wolfsberg Group issued a comment letter in the public consultation of FATF’s draft amendments to Recommendation 8 and its Interpretive Note and updates to its Best Practice Paper to Combat the Abuse of NPOs. John and Elliot discuss the comments and the next steps for proposals. They also talk about several other things of interest to the financial crime community.

Kevin Lee, Director, Financial Crime Technology at AML RightSource, captivated the audience at the 2023 European Anti-Financial Crime Summit in Dublin. In this episode, we recap his speech on how technology can best be harnessed for financial crime.

The American Bar Association House of Delegates has approved changes to strengthen a lawyer’s obligations as a gatekeeper. Also, FinCEN issued a Notice about the increase in worker’s compensation insurance and payroll tax fraud in the construction industry, and the US Treasury Department released information about its efforts pursuing wealthy tax evaders. John and Elliot discuss these developments and how they may shape compliance in the future.

This week, Attorney General spoke to the American Bar Association, and OFAC issued guidance on providing humanitarian assistance to Syria. John and Elliot discuss the speech and guidance and look at the recent release of SAR filing data by FinCEN.

Both the US House and Senate have been very active ahead of leaving for their August recess. John and Elliot discuss the Senate proposal to apply the AML/CFT compliance requirements to all the players in the virtual assets space and the proposals that moved to the House floor on stablecoins, limiting public company disclosures on climate change impact, and many other issues.

John Byrne and Shannon Frontanes of Thomson Reuters Special Services and a provenance expert, discuss her insight on cultural artifacts and their use for money laundering and related crimes.

The US Departments of Commerce, Treasury, and Justice recently updated their voluntary self-disclosure policies. The DOJ also announced the sentencing in a case for conspiring to violate Iranian sanctions and an indictment for a fraudulent charitable contribution tax scheme. In Europe, Interpol announced that it disrupted a transnational migrant smuggling network resulting in 62 arrests. John and Elliot discuss these announcements in a busy week in the financial crime prevention community.

The Subcommittee on National Security, Illicit Finance, and International Financial Institutions of the US House Financial Services Committee held a hearing this week on the Potential Consequences of FinCEN’s Beneficial Ownership Rulemaking. The hearing focused on the proposed beneficial ownership information registry proposed by FinCEN under the Corporate Transparency Act. John and Elliot discuss the testimony given by the witnesses and statements of the committee members.

In this episode, Rachel Dettmer, Joshua Gubitz, and Jonathan McIsaac delve into the potential obstacles that can arise during the implementation process. They discuss the warning signs to look out for, pitfalls to avoid, risks to manage, and key areas to pay close attention to in order to ensure a successful implementation. Get ready to learn from the experts!

Europol recently issued its 2023 Terrorism Situation and Trend Report. The US Treasury issued new sanctions against a top Serbian security official. Merrill Lynch was fined and more. John and Elliot discuss the many goings-on this week in financial crime prevention.

Continuing the conversation on implementation support, Rachel Dettmer, Joshua Gubitz, and Jonathan McIsaac discuss the value of having an experienced partner on your side during implementation and how a wealth of cumulative knowledge and varied experience always proves to be advantageous.

The US Department of Justice announced an indictment charging four people with fraud and money laundering. John and Elliot discuss the connection between fraud and money laundering and how the detection of one can lead to the detection of the other.

Implementation Support is a planned approach to integrate new or upgraded software or systems into the existing workflow of an organizational structure to help ensure the success of a business's overall system. In this episode, Rachel Dettmer, Joshua Gubitz, and Jonathan McIsaac discuss why it's beneficial for banks and financial institutions to have implementation support in addition to what's just provided by the system vendor.

John Byrne and Gary Shiffman, Founder of Giant Oak, Inc., discuss his recent article It’s not the algorithm, it’s the ethics. They look at the ethics and morality of adopting machine learning and artificial intelligence tools and how these impact adoption in the financial compliance space.

The FATF June Plenary has ended, and the Homeland Security & Governmental Affairs of the US Senate issued a report on intelligence failures before January 6, 2021. John and Elliot discuss some of the outcomes of the FATF meetings and look into the key findings in the Senate committee report.

The US Department of State has issued its 2023 Trafficking in Persons report. The theme of this year’s report is partnerships. John and Elliot discuss key elements of the report and its value to the financial crime prevention community.

John Byrne and Terry Pesce discuss the recent Interagency Guidance on Third-Party Relationships: Risk Management. They look at the implications of the guidance and what banks should do to assess their current risk management process for interactions with third parties.

US bank regulators have issued interagency guidance on third-party risk management. The new pronouncement combines and updates past guidance issued by the individual agencies. John and Elliot discuss key parts of the guidance and some implications for banks and their vendors.

There have been several recent articles about the effectiveness of US sanctions. John and Elliot examine this issue and discuss where the programs have succeeded or failed to achieve their stated goals.

Seven years ago, the Panama Papers were published. Recent statistics show that registrations of anonymous corporations in Panama have dropped by more than 50% in the past ten years. John and Elliot discuss the impact of Papers on corporate activities in Panama and ownership transparency across the globe.

Jonathan Fishman, one of the authors of the 2023 Treasury Department’s De-risking Strategy, discusses the various recommendations and the rationale for some of the words used to describe the problem and identifies other key areas of the report.

US law enforcement agencies recently completed a three-month campaign to disrupt frauds perpetrated by foreign actors. John and Elliot discuss the campaign’s details, why it is essential, and what financial service providers can do to support it. They also chatted about several other events this week.

Don Fort, former Chief of IRS - Criminal Investigation Division, Director of Investigations at Kostelanetz LLP, and member of the Advisory Board at AML RightSource, discusses his recent testimony before the Senate Finance Committee about potential IRS funding cuts and their impact on federal law enforcement.

John and Elliot explore how intermediaries are helping evade sanctions and bring luxury goods to Russia. They also discuss new cooperation between the sanction teams in the US and EU and touch on other financial crime prevention news.

The New York Attorney General has proposed legislation to regulate the cryptocurrency industry. The proposal includes provisions protecting investors, increasing transparency, and eliminating conflicts of interest. John and Elliot discuss key aspects of the proposal and its implications for federal regulation of the virtual currency space. They also touch on several other news items from this week.

The US Treasury has issued its 2023 De-risking Strategy. The report reviews the reasons that banks engage in de-risking and includes recommendations to reduce the impact of the practice. John and Elliot discuss their thoughts on the strategy, where they think Treasury got things right, and where it missed opportunities.

Experts from InterAction explain the continuing efforts to enhance financial access for humanitarian organizations, including UN Resolution 2664 and the US General Licenses by OFAC. Kathryn Striffolino, Senior Manager for Humanitarian Practice, has worked in international human rights and humanitarian affairs for over a decade and a half, focusing on human rights and mass atrocity crime documentation, analysis and policy, and humanitarian response in conflict settings. Andrea Hall joined InterAction in March 2022 as Senior Manager of the Together Project. She brings over ten years of experience as a policy advocate, analyst, and organizer at the state and federal levels.

Sanctions against Russia have been a meaningful part of the support for Ukraine by the United States and the European Union. A significant challenge to the sanctions has been the efforts by bad actors and supporters of Russia to evade them. John and Elliot discuss the evasion problem, how the US is working with its allies to increase the impact of the sanctions, and ideas from some economists on increasing sanctions effectiveness.

Legal Consultant Liz Fraccaro from the Antiquities Coalition joins John Byrne again to cover The Art Market Report 2023 and how to utilize the information to enhance eventual AML due diligence.

The Wolfsberg Group has published updated Anti-Bribery and Corruption Compliance Programs guidance. John and Elliot discuss critical elements of the guidance and the importance of financial service providers maintaining effective programs.

UBS and Art Basel recently issued their report, The Art Market 2023. The report includes a discussion of the concerns about the compliance burdens of market participants. John and Elliot examine those concerns and why those markets must align with others to stem money laundering and illicit finance. They also discuss the new stolen art app from the FBI.

John Byrne interviews the publisher of the Illicit Edge, Ryan Wallerstein, who shares his career journey from business to the Treasury Department to this new content endeavor.

Another very busy week in financial crime prevention. John and Elliot discuss several items, including new sanctions, a letter from the House and Senate to Treasury and FinCEN, and a financial trend analysis issued by FinCEN.

Several important items popped up this week. The Commodities Futures Trading Commission (CFTC) issued a civil complaint against Binance, the largest crypto exchange. The CFTC alleges that the company intentionally assisted its clients in evading US laws and regulations. Also, this week the White House hosted the second Summit for Democracy, focusing on reducing corruption and illicit finance. Treasury Secretary Janet Yellen announced a Commitment entered into by the participating countries centered on transparency of beneficial ownership information. John and Elliot discuss these items and how they impact the financial crimes compliance community.

The International Consortium of Investigative Journalists (ICIJ) has published a story about artifacts in the Metropolitan Museum of Art catalog linked to possible looting and trafficking. John and Elliot discuss the global problem of antiquities trafficking and its impact on the countries from which items come.

This week the US Department of Justice announced an indictment against seven individuals for a $100 million stolen identity refund scheme. The Office of the Comptroller of the Currency announced a penalty and prohibition against a former senior official at Wells Fargo. The US Treasury Department announced it has agreed to give in camera access to certain SARs to a House oversight committee. John and Elliot unpack this busy week and share their insights on these topics.

Dr. Michael Zimmer, Director, Center for Data, Ethics, and Society and Associate Professor & Vice-Chair, Department of Computer Science at Marquette University discusses: - Privacy and data ethics - The dark web - The “spatial project” - The Center’s work with policy makers on a variety of issues.

The US Department of Justice has updated its Corporate Enforcement Policy for criminal activity. John and Elliot discuss some aspects of the voluntary self-disclosure part of the CEP and how financial crime compliance professionals can make use of the policy guidance documents in reviewing elements of their compliance programs.

Liz Fraccaro, Attorney and Legal Consultant to the Antiquities Coalition, shares her insight on FATF’s recent report, Money Laundering and Terrorist Financing in the Art and Antiquities Market.

The Financial Action Task Force (FATF) held a plenary last week. FATF also issued a report on Money Laundering and Terrorist Financing in the Art and Antiquities Market. John and Elliot discuss some of the outcomes from the plenary, including the suspension of the Russian Federation’s FATF membership. They also look at key take-aways in the report on arts and antiquities.

How can we improve the cyberworld? One author tells us. We sat down with banking expert Tom Vartanian to discuss his recent book: “The Unhackable Internet: How Rebuilding Cyberspace Can Create Real Security and Prevent Financial Collapse.” Vartanian charges that our current cyber systems are unsustainable and offers several recommendations for the private and public sectors.

It has been a year since the Russian invasion of Ukraine. One of the immediate responses to Russia’s action was an ongoing coordinated effort by the US, G7 and European Union to limit Russia’s war-making ability through sanctions and export controls. John and Elliot discuss some key elements of the sanction programs and how they have performed since being imposed.

John and Elliot discuss several items this week, including a posting by the International Consortium of Investigative Journalists (ICIJ), a comment letter by a group of bank trade associations on the FinCEN Beneficial Ownership Registry proposal, and the announcement that the Organized Crime and Corruption Reporting Project (OCCRP) has been nominated for the Nobel Peace Prize.

Career agency official back over the progression of financial fraud from the Savings & Loan crisis to today. Jim Vivenzio, now with Perkins Coie LLP, provides insight on the state of the financial industry responding to the myriad of challenges they face.

The Wolfsberg Group and the Institute of International Finance have issued a joint comment letter to the European Banking Authority on de-risking. John and Elliot discuss the details of the comment letter, including its recommendation that the EBA adopt definitions and other approaches on de-risking taken by FATF, as the EBA works toward updating its AML/CFT regime for the European Union.

Chief of the Internal Revenue Service’s Criminal Division (IRSCI) Jim Lee details the 2022 results of his “BSA Challenge” to his staff. The Challenge explores and explains the value to law enforcement of Bank Secrecy Act data---CTRs, SARs, CMIRs, FBARS and Form 8300’s.

This week Transparency International released its 2022 Corruption Perceptions Index (CPI). The CPI uses a number of criteria to evaluate the status of corruption in 180 countries. For 2022 the global average remained unchanged at 43 on a 100 point scale. The report shows that 124 countries have not made any change since 2021 and the number of countries declining has increased. John and Elliot discuss some of the findings in the CPI and the links between corruption, deterioration in human rights, the rise of authoritarianism, and the continuing assault on democracy.

his week a retired senior FBI agent Charles McGonigal was arrested on charges of money laundering and violating US sanctions. Also this week, the Financial Crimes Enforcement Network (FinCEN) issued an alert on Potential U.S. Commercial Real Estate Investments by Sanctioned Russian Elites, Oligarchs, and Their Proxies. John and Elliot discuss the arrest and its implications for national security and look at the details of the alert including the typologies and red flags included in it. They also examine McGonigal’s relationship to a sanctioned Russian oligarch and efforts by other sanctioned oligarchs to us real estate transactions to hide and preserve their wealth.

The Financial Crimes Enforcement Network (FinCEN) issued an alert focused on human smuggling along the southwest board of the US. John and Elliot review the major elements of the alert – including SAR filing guidance, red flags, and the difference between human smuggling and human trafficking. They also discuss the importance of financial services companies partnering with law enforcement to identify and prevent the terrible global crime.

The Eurasia Group, a consultancy focusing on political risk, has published its Top Risks - 2023. John and Elliot look at the purpose of the report and how it can be helpful to the financial crime compliance community in assessing and managing risk. They also discuss some of the specific risks called out in the report.

The primary US bank regulators - the Federal Reserve, FDIC, and OCC - issued a joint statement on crypto-asset risks to banking organizations. The statement lists several risks on which the regulators are focusing. John and Elliot discuss some of the risks and speculate on where regulators may be heading in this space.

This episode originally aired on July 29, 2022. The Financial Action Task Force (FATF) recently issued updated Guidance for a Risk-Based Approach to the Real Estate Sector. The updated guidance focuses on the importance of member countries to bring the real estate sector into their money laundering/terrorist financing regimes. John and Elliot discuss the guidance, including the breadth of its coverage, the need for understanding and training of real estate professionals, and how the timing of the guidance intersects with FinCEN’s request for information about the sector.

This episode originally aired on October 7, 2022. This week, the Basel Institute on Governance published its 2022 AML Index. The index assesses countries’ money laundering and terrorist financing risks and capacity to counter them. John and Elliot chat about how the index is constructed, what it says about the state of the global response to these risks, and other key take-aways from this year’s report.

The US Department of Justice and the Securities and Exchange Commission have announced resolution of charges against Danske Bank. The Bank pled guilty to fraud on US banks and agreed to forfeit $2 billion. It also agreed to settle related claims by the SEC. John and Elliot discuss the details of Danske Bank’s activities, which went on between 2008 to 2016. They also talk about how this case illustrates some of the risks that arise in correspondent banking relationships and the vigilance needed to manage those risks.

It has been a busy week for US government pronouncements on national security and terrorism. The Secretary of the Department of Homeland Security gave a speech at the Center for Strategic and International Studies and the majority staff of the Senate Committee on Homeland Security & Governmental Affairs issued a report on The Rising Threat of Domestic Terrorism. The remarks and the report each look at the challenges faced by governments in identifying and responding to terrorist threats and how to deal with the changing threat landscape. John and Elliot look at key points of the speech and the report. They discuss the increasing risks presented by domestic terrorism, the recommendations in the report, and the evolving view at DHS on the dangers we face and how partnerships among government agencies, international partners, and the private sector are critical to long-term success.

Former FBI Supervisory Special Agent on the International Corruption Unit Debra LaPrevotte discusses her career work investigating global corruption and its clear impact on communities. She is currently on a new podcast, “A Nation For Thieves” that delves into kleptocrats, notorious corrupt countries and how ill gotten gains are recovered by law enforcement and their partners.

The White House has published a Fact Sheet: Summit for Democracy: Progress in the Year of Action. It discusses activities taken since the first Summit for Democracy, held a year ago. The White House also announced a second Summit to be held in March 2023. A key goal of the first summit was curbing corruption. John and Elliot look at the progress made on this initiative, how corruption impacts the health of democratic nations, and other actions taken in the last year.

This episode originally aired on June 17, 2022.  FinCEN has issued updated guidance on Elder Financial Exploitation (EFE). The new Advisory looks at the increasing volume of thefts and scams targeted at the elderly and includes both behavioral and financial red flags. John and Elliot discuss the growing problem of EFE, some of the key messages in the Advisory, and efforts by financial service providers to detect and deter these frauds and thefts.

This week The US Treasury issued a report, Assessing the Impact of New Entrant Non-bank Firms on Competition in Consumer Finance Markets. The report examines the current state of innovation and competition between banks and non-bank financial service providers and makes several recommendations. John and Elliot discuss key aspects of the report and the recommendations. They also talk about how the recent collapse of the cryptocurrency exchange FTX may influence the approach of legislators and regulators going forward.

The US Treasury and its Office of Foreign Assets Control (OFAC) have announced new sanctions against a number of individuals and entities involved in supplying illicit fentanyl and other illegal substances. The action was coordinated with the Netherlands and the UK. John and Elliot discuss the new sanctions and the importance of the multi-lateral cooperation which led to them.

The Financial Crime Enforcement Network (FinCEN) has issued its Ransomware Trends for the second half of 2021. John and Elliot look at the process that FinCEN used in its financial trend analysis and discuss some of the conclusions in the report, including that a significant number of ransomware attacks have some connection to actors in Russia.

Kateryna Boguslavska, PhD, Project Manager Basel AML Index at the Basel Institute on Governance, discusses the 2022 AML Index and some examples of recent metrics from Eastern Europe and other regions. Dr. Boguslavska also covers the importance of “effectiveness” in understanding jurisdictional risks. View the 2022 report here - https://baselgovernance.org/basel-aml-index

The Center for Strategic and International Studies has released a report on Mitigating Financial Access Challenges. The report focuses on ways to overcome the difficulty faced by NGOs trying to transfer humanitarian funding to areas subject to sanctions or active counterterrorism measures. John and Elliot discuss the continued impact of de-risking, some of the prior work done on the problem, and examine some of the proposals to improve financial access laid out in the report.

AMLRS Advisory Board Member Nicolas Choules-Burbidge, formerly a senior executive at the Office of the Superintendent of Financial Institutions (OSFI) in Canada, where he started and oversaw the AML/CFT and Compliance Division (AMLC) for 15 years, discusses the 2021-2022 OSFI Report to Parliament and his views on AML supervision in Canada.

Jeff Pearlman, NY Times Best Selling Author of nine books and author of a new book, “The Last Folk Hero” about Bo Jackson, discusses the recent fraud in Mississippi with public funds that involves Brett Favre and his view on the challenge of local journalism today. https://jeffpearlman.com/

Jeff Pearlman, NY Times Best Selling Author of nine books and author of a new book, “The Last Folk Hero” about Bo Jackson, discusses the recent fraud in Mississippi with public funds that involves Brett Favre and his view on the challenge of local journalism today. https://jeffpearlman.com/

Homeland Security Investigations has launched Operation Boiling Point an initiative to curb organized retail crime and cargo theft. The effort brings together public and private organizations. John and Elliot discuss the importance of the focus on this challenge which impacts many levels of the economy. They also chat about the role for the financial crime compliance community in these activities.

This week the Office of Foreign Assets Control (OFAC) and the Financial Crimes Enforcement Network (FinCEN) issued enforcement actions against Bittrex, Inc., a virtual currency exchange. John and Elliot discuss the details of the two actions, including the general AML program failures and ineffective sanctions compliance efforts. They also talk about how other financial service providers can use the orders to check the status of their own sanctions and AML compliance programs.

This week, the Basel Institute on Governance published its 2022 AML Index. The index assesses countries’ money laundering and terrorist financing risks and capacity to counter them. John and Elliot chat about how the index is constructed, what it says about the state of the global response to these risks, and other key take-aways from this year’s report..

The Office of Foreign Assets Control (OFAC) has issued updated FAQs clarifying the regulations about people in the US sending electronic remittances to Cuba. This update is particularly timely given the recent devastating hurricane damage. John and Elliot review the key elements of the updates. They discuss the approved channels, the persons authorized to send and receive payments, and how banks and other service providers can meet their obligations under the rules.

John and Elliot discuss several topics from this week: a recent ProPublica article on human traffickers forcing victims into cyberscamming, recent releases from the US Treasury Department, and insights from the Missouri Bankers Association BSA/AML Conference.

The US House Financial Services Committee held a hearing this week on the availability of financial services in the Caribbean region. The hearing included testimony from Mia Amor Mottley, Prime Minister of Barbados, and from a panel of experts. John and Elliot discuss the challenges and possible solutions raised at the hearing, including the reduced availability of correspondent banking services, the potential impact of digital currencies, and several new legislative proposals.

Jenni Halleran, the Head of Financial Crimes Investigations at Silicon Valley Bank, discusses her career path, growing up in a blue collar town, and deciding to go to law school originally to be a prosecutor. She covers how she then found the AML community and shares recommendations for being successful and how to manage to help others be successful.

Mark Freedman, CEO / Founder of Rebel Global Security and former Chief of Section in the Counter-Terrorism Bureau at the US State Department discusses the need for Chief Security Officers to be more proactive on issues of national security including cyber, terrorism, and other issues related to financial crime.

A recent essay on Lawfare caught John and Elliot’s attention. The authors reviewed the costs and funding sources of the January 6th insurrection and paths to interdict financing of domestic terrorist activities. John and Elliot discuss the implications of the funding schemes used by domestic terrorists, the challenges presented to financial service providers in detecting their activities, and the importance of international cooperation on this issue.

Guy Ficco, Deputy Chief of IRS-Criminal Investigation, joins us to discuss his new role, the vast coverage of financial crime by the IRS, the importance of private-public partnership, and the facts about new IRS resources.

The US Government Accountability Office (GAO) recently issued a report to Congress. The report focused on how the US Department of Justice is complying with its obligation to report on how Suspicious Activity Reports (SARs) are being used by law enforcement. John and Elliot discuss the report, the value of better information on SAR use, and the challenges in gathering meaningful data and presenting it in an actionable format.

John Byrne chats with John M. Geiringer, of Barack Ferrazzano Financial Institutions Group, about the new book he edited and co-authored, Countering the Financing of Terrorism: Law and Policy, by the American Bar Association.

Dennis Lormel, President of the Society of Former Agents of the FBI, discusses the ramifications of the public attacks on the FBI by elected officials in response to the search warrant issued to retrieve classified documents held by former President Trump. Lormel explains the legal process and the need for the AML community to continue supporting law enforcement from clear political attacks.

The Wolfsberg Group, an association of 13 global banks, this week issued a guidance document on requests for information (RFI). The focus of the guidance is best practices in correspondent banks using RFIs in transaction monitoring. John and Elliot discuss some of the issues raised in the guidance and the value of effective use of RFIs. They also talk about the importance of banks being prompt in their responses to RFIs.

There have been outrageous comments made by “policymakers” about the IRS since the passage of the Inflation Reduction Act. AMLRS Chairman of the Advisory Board John Byrne talked to former IRSCI Chief DonFort about the facts regarding the IRA funding, the mission of IRSCI, and the impact misinformation is having on staff. Here’s a taster of some of the questions discussed: Question: There have been questions and a lot of information (misinformation) out there about the substantial funding the IRS is going to get as part of the Inflation Reduction Act, $80B over 10 years. For example, “87,000 armed agents” is being repeated in the media. Remind us of the important work IRS-CI does Explain the facts around “87,000 armed agents?” Question: What’s your take of these statements in the media? Question: What’s the real-life impact to those working for IRS-CI from these types of comments? Question: IRS-CI works more than just tax cases - are there examples of cases that IRS-CI works that have broad national and international importance? Question: How will the IRS use this funding?

The Federal Reserve has issued additional information for banking organizations about crypto-asset-related activities. It is contained in Supervisory Letter SR 22-6. The Letter reviews areas of risk for providers of these products. It also reminds organizations there are regulatory notice requirements they need to follow. John and Elliot discuss the risks identified by the Fed and how this Letter relates to a joint statement on crypto-asset policy issued by US regulators in late 2021. They also talk about the importance of having open communications with your bank regulators as you explore offering crypto-related services.

Asset Forfeiture Global Expert Stef Cassella returns to AML Conversations to discuss civil and criminal forfeiture. He explains how it's used, common misunderstandings about this law enforcement and prosecutorial tool, and also delves into his work which aims to improve its functionality worldwide.

The US Department of Justice has announced that a federal grand jury has indicted representatives of Electronic Transactions Systems Corporation, a payment processor, for fraud and money laundering. The indictment alleges that during the multi-year scheme, the company defrauded 7,000 customers out of millions of dollars. John and Elliot discuss the indictment and the scope of the alleged fraud. They also chat about a letter from US Treasury Secretary Janet Yellin, supporting the funding in the Inflation Reduction Act to modernize the IRS.

John and Elliot chat about an interesting Op/Ed piece that appeared in The Washington Post this week. The author, an expert in international law, examined the implications of designating Russia a State Sponsor of Terrorism. John and Elliot discuss the importance of understanding the impact of that designation and the potential unintended consequences. They also review the latest sanctions announced against Russian elites close to President Putin, including a new action targeting evasion of earlier sanctions.

Kit Conkin, VP at Kharon and a Senior Fellow at the Atlantic Council discusses the recent “joint alert” between the Financial Crimes Enforcement Network (FinCEN) and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) on preventing export control evasion attempts in connection with the Russian Federation’s further invasion of Ukraine.

The Financial Action Task Force (FATF) recently issued updated Guidance for a Risk-Based Approach to the Real Estate Sector. The updated guidance focuses on the importance of member countries to bring the real estate sector into their money laundering/terrorist financing regimes. John and Elliot discuss the guidance, including the breadth of its coverage, the need for understanding and training of real estate professionals, and how the timing of the guidance intersects with FinCEN’s request for information about the sector.

John discusses with Kent Belasco, the Director of Marquette University’s Commercial Banking Program, a recent project with a microfinance organization to assist an impoverished rural farming community outside Panama City.

Alan Ketley, the new Executive Secretary of the Wolfsberg Group discusses the mission of the group, their focus on a variety of AML related topics: correspondent banking, PEPs, trade finance and recent papers covering challenges such as negative news utility and broad collaboration.

FATF (the Financial Action Task Force) has issued a report: Partnering in the Fight Against Financial Crime – Data Protection, Technology and Private Sector Information Sharing. The report discusses the importance of balancing privacy with the need for financial services providers to share information to help stop the spread of financial crime. John and Elliot discuss the goals of the reported activities and the focus of several of the case studies set out in the report.

Rob Triano of CipherTrace discusses his career move from traditional banking to the Federal Reserve to CipherTrace and addressing the unique challenges of the crypto world. Advising clients with cybersecurity, money laundering and terrorist financing potentials in this market and offering insight on what to expect going forward.

The US House of Representatives is acting on proposed amendments to the National Defense Authorization Act, including the ENABLERS Act. John and Elliot discuss the status of the amendments and what is likely to make it into the version that goes to the US Senate.

The presidency of the Financial Action Task Force has recently transferred to Singapore and the new president has issued the organizational priorities for the next two years. John and Elliot discuss the work of FATF and the priorities and how they integrate with activity going on throughout the financial crime prevention community.

A bi-partisan group from the US Congress has attached the ENABLERS Act to the FY 2023 National Defense Authorization Act (NDAA). The ENABLERS Act would bring a number of groups and individuals who assist in anonymizing organizations and their transactions under the recordkeeping and recording regime of the Bank Secrecy Act. John and Elliot discuss the impact that passage of the Act would have on closing current holes in BSA coverage and the likelihood of passage of the Act, now that it is linked to adoption of the NDAA.

Tom Vartanian, the Executive Director of the Financial Technology & Cybersecurity Center discussed the ongoing problems with cybersecurity, cryptocurrency and current regulations and recommendations regarding how to address ransomware.

John interviewed Michael Lee, IRSCI Supervisory Special Agent, Western Cyber Crime Unit, on crypto, NFTs and Decentralized Finance.

FinCEN has issued a Statement on Bank Secrecy Act Due Diligence for Independent ATM Owners or Operators, focusing on the analysis that financial service providers should use to make a risk based determination about offering services. John and Elliot discuss the statement and their views of why this topic received the attention of FinCEN given all of the initiatives it is working on at this time.

FinCEN has issued updated guidance on Elder Financial Exploitation (EFE). The new Advisory looks at the increasing volume of thefts and scams targeted at the elderly and includes both behavioral and financial red flags. John and Elliot discuss the growing problem of EFE, some of the key messages in the Advisory, and efforts by financial service providers to detect and deter these frauds and thefts.

This week the Department of Homeland Security issued a bulletin, updating its assessment of the terrorism threat to the US. In the bulletin DHS reaffirms that the country remains in a heightened threat environment. John and Elliot discuss the concerns raised by DHS following the recent mass shooting events, that some of the attackers have been motivated by violent extremist ideologies that are racially or ethnically motivated, and the international implications noted by DHS.

Acting Comptroller of the Currency Michael Hsu recently spoke at the DC Blockchain Summit 2022 about the state of the virtual currency space. In his remarks he highlighted several areas of concern, in particular – the vulnerability of crypto hacks, the risk of loss contagion, and the need for clarity about the ownership of crypto assets. John and Elliot discuss each of these topics, and why members of the financial crime prevention community need to continue to grow their understanding of virtual currencies and assets and the risks they present.

This week, Congresswoman Maxine Waters, Chairwoman of the House Financial Services Committee sent a letter to President Biden about financial access for Caribbean nations and particularly the harmful phenomenon of bank de-risking. The letter recognizes that access to financial services is a key building block for creating and sustaining an effective economy. The letter references a recent report by the Atlantic Council. John and Elliot discuss the focus of the letter, how de-risking and financial access is a serious concern, not just for charities and non-profits, but for entire nations, and some of the solutions that can be instituted to reduce the impact of the problem.

John Byrne sits down with former FinCEN Deputy Director, Jamal El-Hindi and now Counsel with Clifford Chance. The two discuss AML challenges with new technology, the use of data, sanctions issues and his 20 year career at the US Treasury Department.

The Tax Justice Network has released its Financial Secrecy Index 2022. The Index “identifies the world’s biggest suppliers of financial secrecy” with the US being number 1. John and Elliot discuss the findings in this year’s Index, the overall progress noted by the TJN, and the need for continued progress in reducing the availability of tax and secrecy havens around the world.

The UK has become a haven for rich Russians. The lax approach to regulation has allowed money laundering to flourish. Recent government action in response to the Russian invasion of Ukraine is making a difference, but won’t erase the longstanding relationships that foster financial crime. John and Elliot discuss the challenges presented by the facilitating behavior of gatekeeper professionals and the global nature of the issues in the UK.

Homeland Security Investigations’ (HSI) Outreach Initiative – Cornerstone recently shared information about the rising level of organized retail crime (ORC) being perpetrated by transnational criminal organizations. This activity involves planned theft of retail goods for later sale through gray market channels. John and Elliot discuss the value of HSI outreach to the financial crime prevention community and some of the red flags for identifying ORC.

The International Consortium of Investigation Journalists (ICIJ) recently shared documents with The Irish Times about the Kinahan organized crime cartel. The Irish Times published an extended article about the actions of the cartel in moving to the UAE and taking advantage of its secrecy laws to avoid prosecution. John and Elliot discuss the recent US sanctions issued against Daniel Kinahan, FATF’s gray listing of the UAE, and the importance of financial transparency.

The Financial Crimes Enforcement Network (FinCEN) recently issued guidance about kleptocracies and foreign corruption. The guidance includes insights into typologies and includes red flags. John and Elliot discuss the guidance, the global focus and nature of the problems identified in the guidance, and the value of the red flags as a training tool.

For this episode of our AML Conversations podcast, we sit down with Sara Crowe, the strategic initiatives director at Polaris, a non-profit working to end human trafficking. We discuss how human trafficking has evolved in recent years and concerns following refugees fleeing Ukraine, as well as actionable insights for financial institutions as to how they can help prevent human trafficking. We hope you enjoy this episode.

Treasury Secretary Janet Yellen spoke recently at American University about digital assets. The speech look at the intersection of innovation, policy and regulation. John and Elliot discuss key points in the speech including how innovation in the financial sector often out strips policy and regulation and how the Yellen’s remarks create a good framework for the discussions and activities in the digital asset space.

John Byrne chats with Brian Szady, Founder of a threat mitigation firm Threatminder, on the various cybersecurity issues challenging the AML world, including ransomware, training staff and defining human as well as artificial intelligence.

This week The Washington Post and the International Consortium of Investigative Journalists (ICIJ) published another segment of the Pandora Papers. This latest release focuses on registered agents and their role in representing companies In the United States. John and Elliot discuss the total lack of transparency of corporate ownership in many of states, weakness this creates in the financial crime prevention regime In the US, and ENABLERS Act which was introduced In Congress In October 2021.

In June 2021, FinCEN issued the first National AML/CFT Policy Priorities for the US. John Byrne sat down with Dan Stipano of Davis Polk & Wardwell LLP to record this at the ACAMS Hollywood conference. John and Dan discuss the breadth and importance of the priorities, how to use them in future planning for your financial crime prevention program, and how the priorities may change the overall financial crime response regime.

FinCEN has released new Suspicious Activity Report (SAR) data. The data set covers the full years 2014 through 2021. The information looks at SARs filed by all of the required filers and breaks down the information in a number of ways. John and Elliot discuss some interesting nuggets from the release, speculate on how the data may be analyzed, and talk about finding ways to use the information to improve financial crime prevention programs.

This week the US Department of Justice indicated that it will begin directing prosecutors to “consider requiring” certification at the end of an enforcement action settlement that the “the company’s compliance program is reasonably designed and implemented to detect and prevent violations of the law and is functioning effectively.” Also this week, Chairwoman Maxine Waters of the US House Financial Services Committee issued a letter to trade associations representing numerous US businesses requesting detailed information on the actions that America’s financial institutions and businesses have taken to end their relationships and engagements in Russia and with businesses that support the Russian government. John and Elliot discuss the implications for CEOs and CCOs of the certification idea and how the trade associations may respond to Chairwoman Water’s request from information.

The Financial Action Task Force (FATF) has issued a 2nd Draft Guidance Paper for consideration and agreement to public consultation for the Real Estate Sector. This latest guidance paper will update earlier guidance issued to the sector. John and Elliot discuss some aspects of the draft, including the limited understanding of participants in the sector of money laundering and terrorist financing risks, the large role that the sector plays in many national economies, and the tie in to the Advanced Notice Proposed Rulemaking for new real estate sector reporting requirements, issued by FinCEN in December 2021.

This week FinCEN issued an alert directing US financial institutions to increase their vigilance in watching for efforts to evade Russian related sanctions. The alert identifies several possible evasion typologies that may be used. Elliot  sits down with Tim White, Special Advisor at AML RightSource and global sanctions expert to talk about the alert. Elliot and Tim discuss some of the implications for evasion through the use of virtual currency, and the importance of monitoring changes in transaction flows and volumes, and transactions from new sources. They also note that the alert has value for the financial crime prevention community beyond the US.

We sit down with our global sanctions expert Tim White to hear how the financial crime compliance community is impacted following the sanctions against Russia and how to address any concerns. We also delve into how these financial service providers can over overcome some of the challenges that they are now faced with.

John Byrne Chairman of the AML RightSource Advisory Board sits down with James Lin, the Company’s new Chief Product & Technology Officer. James discusses his vision for how technology and people working together can bring clients enhanced effectiveness in their financial crime compliance efforts. He also explores how bringing all AMLRS’s resources together to accelerate client success.

This week the US Department of Justice announced the formation of Task Force KleptoCapture. The Task Force is an “interagency law enforcement task force dedicated to enforcing the sweeping sanctions, export restrictions, and economic countermeasures” that have been and may be issued. John and Elliot talk about the focus of the new Task Force – targeting “Russian officials, government-aligned elites, and those who aid or conceal their unlawful conduct;” and how it will combat unlawful efforts to circumvent the sanctions programs.

As a result of the Russian invasion of Ukraine, nations around the world have put sanctions in place against Russia, Russian companies, and Russian nationals. John sits down with Tim White, Special Advisor at AML RightSource and global sanctions expert to discuss the severity and near term impact of the sanctions announced in the last several days, what sanctions compliance teams should be looking at to comply with these programs, and what other actions may be coming in the near future.

In January the US Department of Justice issued its National Strategy to Combat Human Trafficking. This week, a House of Representatives Committee held a hearing on Data Challenges Impacting Human Trafficking Research and Development of Anti-Trafficking Technological Tools. These two events highlight the increasing US national focus on human trafficking. John and Elliot discuss how the data issues noted at the hearing and the efforts identified in the DOJ Strategy impact the efforts of law enforcement and the financial crime compliance community to identify, disrupt, and stop human trafficking.

This week Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian Nelson spoke with leaders of NGOs active in Afghanistan. The focus of the conversation was the newly issued FAQs, which are designed to bring more clarity about food and agricultural shipments, support to public hospitals, salary support for teachers and healthcare workers, support for municipal water systems, bank transactions, and cash shipments. The FAQs add to the information issued in December 2021 Fact Sheet Provision of  Humanitarian Assistance to Afghanistan and Support for the Afghan People. John and Elliot discuss how the overall issue of de-risking is brought into clear relief in situations such as Afghanistan and how the FAQs can help financial service providers and NGOs navigate the sanctions against the Taliban and bring humanitarian support to the Afghan people.

Advisory Board Chair John Byrne sits down with Ken Harvey to discuss his joining the Board. They chat about Ken’s long career in financial service technology, the impact of technology development on customer interactions and financial crime compliance, and the continuing expansion of transaction volumes. They also talk about how regulators are fostering innovation and supporting the deployment of emerging technologies.

his week Transparency International released its 2021 Corruption Perceptions Index (CPI). The CPI uses a number of criteria to evaluate the status of corruption in 180 countries. For 2021 the global average remained unchanged at 43 on a 100 point scale. John and Elliot discuss some of the findings in the CPI and the links between corruption, deterioration in human rights, the rise of authoritarianism, and the continuing assault on democracy.

This week the US Treasury issued its Year in Review: Treasury’s Top Accomplishments During Year One of the Biden-Harris Administration. The release looks at a broad set of areas for which the Department is responsible. John and Elliot discuss items in the National Security and Protecting the Financial System sections of the release.

John Byrne sits down with Jeffrey Alberts of Pryor Cashman LLP and Ari Redbord of TRM Labs to discuss the latest guidance from the Financial Action Task Force about a risk-based approach to virtual assets and virtual asset service providers. They discuss the importance of the definitions in the guidelines, how the proliferation of virtual assets is impacting the risk landscape, and how the guidance will impact participants in the virtual asset space.

This week FinCEN’s Acting Director, Him Das, delivered remarks at the ABA/ABA Financial Crimes Enforcement Conference. In the speech, he spoke about the shifts in emphasis of Bank Secrecy Act regulations over the past 30-plus years. John and Elliot discuss those shifts and look at the three new areas of focus outlined in Acting Director Das’s remarks: new threats, new innovations, and new partnerships.

This week was the 1st anniversary of the insurrection at the US Capitol. John and Elliot focus their conversation on what the financial crime compliance community can do to identify the monetary footprint of potential domestic terrorist acts. They discuss the recent statements by the President, Vice President, and the Attorney General and urge listeners to report transaction activity that fits the patterns of possible terrorist activity.

Former FBI TFOS Director Dennis Lormel discusses the ramifications of the January 6th  2021 attacks on the US Capital on society and the AML community. Dennis covers the financial warning signs to the radicalization that leads to domestic terrorism.

This episode originally aired on October 15th, 2021. In August 2021, Global Financial Integrity published Acres of Money Laundering – Why U.S. Real Estate is a Kleptocrat’s Dream. The report compares the real estate money laundering regulations across the G7 countries. John and Elliot discuss the report’s findings on the use of the US commercial real estate market to launder funds and the roles played in the transactions by various gatekeepers. They also call out some of the key recommendations in the report. A link to the report -gfintegrity.org/report/acres-of-m…leptocrats-dream/ Here's a great article that discusses real estate and the need for real reforms in Australian AML regulations - www.amlrightsource.com/news/real-est…l-regulations

The FATF has issued it’s second 12-month review of its revised standards for virtual assets and virtual asset providers. John Byrne, Executive Vice President and Elliot Berman, Creative Director of the AML RightSource staff, sit down and discuss the key elements of the review and its implications for global compliance in this emerging area.

Kit Conklin, Director, Global Client Engagement at kharon.com discusses the importance of understanding and complying with the export control laws, the risks to national security and the need for collaboration with those charged with AML and Sanctions laws.

This week FinCEN issued an Request for Information and Comment (RFI) on a Review of Bank Secrecy Act Regulations and Guidance. The RFI asks for comments ways to streamline, modernize, and update the AML/CFT regime of the United States. John and Elliot discuss some key questions in the RFI and talk about the importance of making comments on this other regulatory proposals.

This week FinCEN issued an Advance Notice of Proposed Rulemaking (ANPRM) on Anti-Money Laundering Regulations for Real Estate Transactions and a Notice Proposed Rulemaking on Beneficial Ownership Information Reporting Requirements. The ANPRM asks for comments on how to bring US real estate transactions more fully under BSA recordkeeping and reporting requirements. The Proposal on Beneficial Ownership Information asks for comments on a rule requiring reporting by various entities of their beneficial owners. John and Elliot discuss some key points of both issuances and talk about the importance of making comments on these other regulatory proposals.

In this installment of AML Conversations, John Byrne speaks with Jim Lee, Chief of the Internal Revenue Service Criminal Investigation Division, about IRS CI. During their conversation they discuss the recent IRS CI Annual Report, the importance of public private partnerships, and the value of CTR data to successful investigations. They also review recent investigations into COVID-19 related fraud, money laundering enforcement, and tax compliance enforcement cases.

Last week the Federal Reserve, Federal Deposit Insurance Corporation and Office of the Comptroller of the Currency issued a Joint Statement on Crypto-Asset Policy Sprint Initiative and Next Steps. The joint statement highlights the current activity by the agencies to understand the impact of crypto-assets on insured depository institutions and the areas the agencies are reviewing for possible future guidance or regulation. John and Elliot discuss some of the key elements of the report, including the need for a common understanding of what crypto-assets are and how they may impact bank capital.

This episode previously aired on October, 8th 2021. The International Consortium of Investigative Journalists (ICIJ), The Washington Post and many other news organizations around the world have published a series of stories based on nearly 12 million records obtained by the ICIJ – known as the Pandora Papers - which shed light on how heads of state, the super-rich, and criminals have hidden their assets. John and Elliot look at some of the key findings by the ICIJ, The Post and other media outlets and discuss the implications for oversight and regulation going forward.

This week the IRS published the IRS-Criminal Investigation (IRS-CI) Fiscal Year 2021 Annual Report. IRS-CI is the criminal investigative arm of the IRS. The report provides detailed information about enforcement actions and partnerships from IRS-CI. John and Elliot discuss some of the highlights in the report, including the international scope of IRS-CI investigations and the breadth of its activities outside of tax enforcement, including in the cybercrime space.

Tom Vartanian is a former federal banking regulator and law professor. In this two-part podcast, we discuss his views on what caused the various the financial crises in the US, the need for improved or “smart” regulation, how accountable are the policy makers and the private sector, and the need to utilize technology to prepare us for any future financial panics.

Tom Vartanian is a former federal banking regulator and law professor. In this two-part podcast, we discuss his views on what caused the various the financial crises in the US, the need for improved or “smart” regulation, how accountable are the policy makers and the private sector, and the need to utilize technology to prepare us for any future financial panics.

The Office of Foreign Assets Control of the United States Department of the Treasury (“OFAC”), the New York State Department of Financial Services, and the Federal Reserve recently issued a series of enforcement actions against Mashreqbank PSC, Dubai, United Arab Emirates. The action all related to failures by the Bank to comply with certain sanction programs. John and Elliot discuss the orders, the specific violations, and the overall usefulness of enforcement actions.

INTERPOL has released its latest survey of member countries – Assessing Crimes Against Cultural Property 2020. The report discusses the INTERPOL Stolen Works of Art Database and the recently release ID-Art mobile application. John and Elliot discuss the increases in cultural crimes during 2020 and the challenges faced by countries around the globe as they work to reduce illicit excavations and theft of assets.

The Financial Action Task Force held its most recent Plenary last week. The delegates completed work on a number key initiatives – updated guidance for a risk-based approach to virtual assets and virtual assets service providers, and a final report on a survey on implementation of standards on cross-border payments. John and Elliot discuss the outcomes of the Plenary and what it means for the financial crime compliance community.

The Biden Administration and the Treasury Department have unveiled a proposal to improve tax fairness and compliance. The proposal seeks to enhance tax reporting by authorizing the IRS to require financial institutions to report two additional items of information on its customers: the total amount of funds deposited into the account and the total amount withdrawn over the course of a year. John and Elliot discuss the implications of the proposal and its possible impact on financial service company’s compliance activities.

In August 2021, Global Financial Integrity published Acres of Money Laundering – Why U.S. Real Estate is a Kleptocrat’s Dream. The report compares the real estate money laundering regulations across the G7 countries. John and Elliot discuss the report’s findings on the use of the US commercial real estate market to launder funds and the roles played in the transactions by various gatekeepers. They also call out some of the key recommendations in the report. A link to the report -https://gfintegrity.org/report/acres-of-money-laundering-why-u-s-real-estate-is-a-kleptocrats-dream/ Here's a great article that discusses real estate and the need for real reforms in Australian AML regulations - https://www.amlrightsource.com/news/real-estate-and-the-need-for-real-reforms-in-australian-aml-regulations

The International Consortium of Investigative Journalists (ICIJ), The Washington Post and many other news organizations around the world have published a series of stories based on nearly 12 million records obtained by the ICIJ – known as the Pandora Papers - which shed light on how heads of state, the super-rich, and criminals have hidden their assets.  John and Elliot look at some of the key findings by the ICIJ, The Post and other media outlets and discuss the implications for oversight and regulation going forward.

This week the Department of Homeland Security added an item to its website entitled “if you see something, say something.” The item discusses how individuals can report suspicious activity. John and Elliot look at some of the red flags identified by the DHS and discuss the impact of viewing suspicious activity reporting as something beyond the responsibility of entities regulated under the Bank Secrecy Act.

In this episode of AML Conversations, John Byrne and David McLaughlin discuss David’s journey in creating QuantaVerse and the problems he set out to solve. They talk about the interaction of technology and human analytics and how to develop effective processes for superior outcomes by balancing the strengths of both.

This week FinCEN published an Advance Notice of Proposed Rulemaking regarding anti-money laundering regulations for the trade in antiquities. John and Elliot look at some of the questions in the ANPRM, discuss who FinCEN would like to receive comments from, and remind listeners about the importance of providing comments to ANPRMs and the proposed regulation when they are published later this year.

In this episode of AML Conversations, John Byrne, Debra LaPrevotte, and Dr. Louise Shelley discuss environmental crime and the need for a more cohesive approach. Wildlife trafficking continues to enable the facilitation of illicit funds and is the “soft underbelly of organized crime.” Our panel discusses this global problem and what can be done to address what is a “low risk, high reward” crime.

This week the Basel Institute on Governance published its 10th AML Index. The Index looks at activities by 112 countries to effectively operate AML/CFT systems. John and Elliot share some insights into how the index is applied and the results.

This week is the 20th anniversary of 9/11. The events of that day impacted many lives and changed how people view the world and the threats in it. It also impacted how the financial crime compliance community looks at threats and performs its work. John and Elliot share some insights on how 9/11 changed things over the past 20 years.

This week FATF issued a Mutual Evaluation Report for Japan. John and Elliot discuss the findings in the report, the report process, and the focus of the process on assessing the effectiveness of a nation’s measures and their level of compliance with the FATF Recommendations.

This week saw a White House summit on cybersecurity making clear the connection between cybersecurity and national security. John and Elliot discuss the importance of connecting the domestic focus with our efforts globally to form strong partnerships and build effective cooperation to thwart cyber threats, and protect the international financial system.

This week saw the rapid fall of the Afghan government to the Taliban. John and Elliot discuss the collateral damage from this sudden change, examining the impact on financial access for individuals, NGOs and national government, the safety of historical artifacts, and how these changes can affect civil liberties.

This conversation with two of the authors of a recent article for the Federal Reserve Bank of Atlanta that examines claims of the connection between bank de-risking and AML regulation. John Byrne talks to Mark Nance, the Director of the Master of International Studies program at NC State’s School of Public and International Affairs and Eleni Tsingou, a professor in International Political Economy at the Copenhagen Business School.

This week saw virtual currencies be the focus in many venues. John and Elliot discuss statements from the head of the SEC and the fine levied against BitMEX by FinCEN for regulatory violations. They also review the negotiations in the US Senate, during the debate on the Infrastructure Bill, surrounding tax reporting by participants in the virtual currency ecosystem.

John Byrne, Executive Vice President and Vesna McCreery, Managing Director of the AML RightSource staff, sit down and chat about the progression of financial crime compliance over the past 20+ years. They discuss the journey from reputation risk, to transaction monitoring, to comprehensive client due diligence. John and Vesna examine the changes in regulatory focus and expectations and how the financial service industry’s response has evolved over time.

In this installment of AML Conversations, John Byrne sits down with Bill Maggio. In a wide-ranging conversation, Bill, a member of the AML RightSource Advisory Board, and John discuss entrepreneurship, how new and rapidly growing companies help stimulate business communities, and the current expansion activity at AML RightSource.

In this installment of AML Conversations, John Byrne speaks with Markus Schulz, Deputy Global Head FCC & Global Head Change Management at IMG, about the history of technology in the financial crime compliance space and how technology has migrated into the regulatory and examination processes as well.

This week, Tim White and John Byrne discuss the recently imposed sanctions on Cuban officials by the Biden Administration

This week the at a hearing of a subcommittee of the House Banking Committee the risks related to central bank digital currencies. John and Elliot discuss some key risks identified in the testimony, including dollar primacy, economic and trade sanctions, and cybersecurity.

This week the US Senate Caucus on International Narcotics Control held hearing on the federal response to the drug overdose epidemic. John and Elliot discuss key themes of the hearings, interesting elements of the testimony, and insights into how the traffickers are moving their ill-gotten gains.

Adverse Media Screening is a powerful tool for KYC and EDD. During this installment of AML Conversations, John Byrne discusses how AMS can be a key part of an effective financial crime compliance program with Adrian Gardner, Head of KYC at Cash App and Eve Whittaker, Senior Account Manager at Arachnys.

This session covers the recently released report by Polaris and The Avery Center on how two financial institutions, working with a human trafficking survivor, were able to develop five themes on how traffickers moved funds derived from their illicit activities.

This week US banking regulators asked for comment on proposed interagency guidance on third-party relationships. The proposed guidance will replace existing guidance, some of which dates to 2009. John and Elliot discuss the proposal, what financial service providers should consider as this proposal becomes final, and how the proposal may impact the examination process.

The FATF has issued it’s second 12-month review of its revised standards for virtual assets and virtual asset providers. John Byrne, Executive Vice President and Elliot Berman, Creative Director of the AML RightSource staff, sit down and discuss the key elements of the review and its implications for global compliance in this emerging area.

This week FinCEN issued the first Anti-Money Laundering and Countering the Financing of Terrorism National Priorities. They identify eight areas of focus for the next four years. John and Elliot discuss the Priorities, what they mean for the focus of enforcement going forward, how they may impact the examination process, and how FIs may consider responding publication of the Priorities.

This week John and Elliot discuss the recent FinCEN recognition of a number of organizations related to the use of a Bank Secrecy Act, how they are using the data to aid in law enforcement efforts. They go through a handful of the examples listed in the document, and also talk about how friends of the show made this list!

John Davidson, AML expert from the securities industry, shares his views on the difference between traditional banking and securities, recent cases and actions by the Securities and Exchange Commission (SEC), and how he sees the financial crime prevention area changing in the coming years.

The US Administration is continuing its focus on domestic terrorism. This week it published its National Strategy for Combatting Domestic Terrorism. This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss the key elements of the strategy and what it may mean for Bank Secrecy Act compliance going forward.

In this episode of AML Conversations, John Byrne sits down with Kerry Donley, a financial services executive who spent 18 years on the Alexandria, VA City Council and as Mayor for 8 of those years. Kerry had to navigate work-life balance with the added challenge of public service. He has dealt with the impact of 9/11 on his community, working closely with law enforcement and the unique nature of historical Alexandria that contains the home of George Washington. A compelling and insightful conversation that is relevant to today’s challenges.

The US Administration and the United Nations are focusing on the adverse impact of corruption on the global economy and political stability. This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss the these efforts and how both organizations are working to create change and motivate nations around the world to take up actions to reduce this nefarious activity.

This week, John Byrne is joined by AML RightSource resident Sanctions expert and Special Advisor, Tim White. John and Tim discuss the recent release of the Global Magnitzsky Designations, and a few examples of what's happened recently in Bulgaria relating to the release. From gambling institutions, to professional basketball teams, the designations will undoubtedly affect a substantial amount of assets, now frozen.

The European Commission has issued a Communication on Business Taxation for the 21st century. The focus of the communication is to “promote a robust, efficient and fair business tax system” in the EU. This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss the communication and its recognition that increasing the fairness in a tax system requires dealing with the problem of shell companies. John and Elliot explore the importance of transparency and the alignment of the EU effort with those of the current US administration.

The OCC has issued the Spring 2021 edition of its Semiannual Risk Perspectives. This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss the report and its value to the financial crimes compliance community. John and Elliot explore some of the themes in the report and the importance of understanding how FI regulators are looking at various risks going forward.

There are many forces influencing global directions and the ability of governments, NGOs and individuals to respond to crises and political events. This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff talk about the report Global Trends 2040, issued by the National Intelligence Council. John and Elliot explore the themes identifies in the report and how they may influence global events over the coming decades.

Domestic and international terrorism are growing challenges. This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff talk about an announcement by the US Department of Justice of the second guilty plea by a member of the "Boogaloo Bois" to conspiracy to provide material support to Hamas. John and Elliot explore the growing connection between these two global problems.

Corruption is a continuing global problem. This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff talk about the new UK Anti-Corruption Regime. John and Elliot explore the sanctions issued by the UK and the importance of a world-wide coordinated effort to combat corruption.

In this episode of AML Conversations, John Byrne, Executive Vice President at AML RightSource, sits down with Paul Camacho, for an in-depth discussion about the life and legacy of Elmer Irey, the first Chief of IRS Criminal Investigations. John and Paul chat about how Irey created the unit, which invented forensic accounting, and aggressively pursued tax evaders and corruption in the United States.

Domestic Terrorism is a constant issue that effects all of us. Join John and Elliot this week, as they discuss the current landscape of combating terrorism, with a specific focus on the financial elements, and how each of us in the community can be a part of the solution to this critical issue.

This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff talk about InfraGard, a 25-year-old partnership between the FBI and the private sector to help identify cyber threats. John and Elliot explore the value of public-private partnerships and how InfraGard has expanded from cybercrime to include terrorism, intelligence, and other matters.

This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff talk about the recent change in FinCEN leadership, the FinCEN ANPRM on the beneficial ownership registry, newly issued sanctions on human traffickers in Pakistan, and an evolving public-private partnership in northern Virginia. It has been a busy week in the financial crimes compliance space, tune in to hear all about it.

This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff talk about the announcement by Department of Justice that it has completed the extradition of a national of the Democratic People’s Republic of Korea (DPRK). The indictment alleges that the individual and others conspired to covertly and fraudulently access the U.S. financial system and to have defrauded U.S. banks and violated both U.S. and U.N. sanctions as part of the money laundering activities in transactions valued at over $1.5M. John and Elliot discuss the importance of FIs remaining vigilant in their understanding with whom they are transacting business.

This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff talk about the NCUA’s recent Cease and Desist Order to Live Life Federal Credit Union. John and Elliot discuss the complexities of providing services to marijuana-related businesses and dealing in virtual currency; and the lessons that all FIs can glean from the Order.

This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff talk about the recently proposed Fair Access to Banking Act. John and Elliot discuss the mandates in the Act, the challenges it presents to risk-based compliance programs, and the types of entities that are not included in the coverage of the proposed legislation.

AML RightSource Executive Vice President, John Byrne sits down with Kevin Hall, Chief Economics Correspondent and Senior Investigative Reporter for McClatchy Newspapers to explore what makes for a good investigation, characteristics of global corruption, and some of Kevin's work over the years.

This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff talk about the notice from FinCEN about its efforts around trade in antiquities and art. John and Elliot discuss the activities that FinCEN is undertaking in this area, some of the resources which are included in the notice, and FinCEN’s guidance about the elements of an effective SAR narrative about antiquities and art.

This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff talk about the policy paper on improving FinCEN’s role in national security, issued by Global Financial Integrity. John and Elliot discuss the views expressed in the paper and some of GFI’s recommendations to enhance FinCEN to meet the growing national security threat posed by money laundering.

This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff talk about hearings being held in the House of Representatives about various proposals to make domestic terrorism a federal crime. John and Elliot discuss the views expressed by several witnesses at the hearings and what the financial crimes compliance community can do now to help detect and report potential domestic terrorist activity.

This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff talk about the likely creation of a Congressional Commission to investigate the actions of January 6th. John and Elliot discuss what information useful to the financial crimes compliance community may come from such a commission’s activities and why a clear understanding of the roots and long range impacts of the events will be valuable to the community and the nation. Frankly Speaking Series Page: https://www.amlrightsource.com/frankly-speaking Frankly Speaking Podcast Page (Apple Podcasts): https://podcasts.apple.com/us/podcast/frankly-speaking/id1551894782

This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff talk about some provisions of the Anti-Money Laundering Act of 2020. John and Elliot discuss a recent posting by the International Consortium of Investigative Journalists which identifies some of the possible shortcomings in the Act and how these provisions may be come to be during the legislative process. NEW VIDEO PODCAST ALERT - Frankly Speaking You can find the video episode and audio episode player here: https://www.amlrightsource.com/frankly-speaking Go here to like, subscribe, and help us get this thing off the ground: https://podcasts.apple.com/us/podcast/frankly-speaking/id1551894782

The terrorist attacks by US citizens against Congress and the Capitol on January 6th were the most horrific attacks on US soil since 9/11. We sat down with counter terrorism expert Dennis Lormel and discussed the financial aspects that enabled these attacks and what can be done going forward. There are parallels that Dennis and AML RightSource EVP John Byrne outline and cover in this special episode.

Tom Cardamone, the CEO and President of Global Financial Integrity (GFI), discusses the worldwide challenges of preventing illicit financial flows and how beneficial ownership reporting requirements will greatly assist law enforcement as they battle this global scourge.

This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff talk about FinCEN Advisory FIN 2021-A001 which focuses on health insurance and healthcare fraud. John and Elliot discuss the red flags in the Advisory and actions FIs can take to identify this activity and messages they can share with their customers to help them recognize these schemes.

This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff talk about the release by Transparency International of its Corruption Perceptions Index for 2020. John and Elliot discuss the findings and recommendations in the CPI report, including the impact of pandemic related corruption on economic and democratic institutions.

This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff talk about the introduction of the Domestic Terrorism Prevention Act, the comments by Janet Yellen about the risks of crypto or virtual currencies, and the issuance by FinCEN of frequently asked question about SAR filing. They discuss how the DTPA is a direct response to the incursion at the Capitol and how Yellen’s comments are aligned with those by financial regulators in other countries.

This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff talk about January being National Slavery and Human Trafficking Prevention Month. They explore how the AML community is working to identify human trafficking and provide law enforcement with actionable information to support efforts, along with many other organizations, to interdict and end human trafficking.

This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss the unprecedented actions at the Capitol Building in Washington DC. They explore the challenges presented by domestic terrorism, how financial services companies can work to identify possible planning activities by domestic terrorists, and what actions Congress may take to codify domestic terrorism in the Federal criminal law.

This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss the letter from 22 Democratic members of the House Financial Services Committee to the Comptroller of Currency, urging the OCC to withdraw its notice of proposed rulemaking which would require national banks to provide services to firearms manufacturers and fossil fuel companies. During the conversation they look at the basis of the proposed rule and the concerns raise by the committee members in their letter.

This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss several cases recently filed under the Anti-Terrorism Act arising from alleged terrorist acts in the Middle East where the supportive funding was funneled through several charitable organizations. During the conversation they consider the impact the suits could have on the access legitimate charities have to financial services.

This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss the Congressional Conference Report of the National Defense Authorization Act. The Act contains the Anti-Money Laundering Act of 2020, the first major reform to the AML infrastructure since adoption of the USA PATRIOT Act. During the conversation they identify some of the interesting items contained in the final language.

This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss a recent consent order between a community bank and the FDIC. During the conversation, they look at the value for all institutions of reviewing regulatory orders to understand the current thinking of the regulators and how to review your BSA program to ensure that it meets expectations.

This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss the latest on a bi-partisan effort in Congress to adopt the first major reform to the AML infrastructure since adoption of the USA PATRIOT Act.

This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff talk about the report issued by the Organization for Co-operation and Economic Development (OECD) on the efforts by the United States to combat bribery of foreign elected officials in international business transactions. During the conversation John and Elliot discuss the recommendations in the report and the importance of US actions in this critical area.

This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss the national security risks of delays in the presidential transition process. Their conversation looks at the risks that moments of disruption present to our country from foreign and domestic bad actors.

This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff talk about the announcement from the Department of Justice of the seizure of 27 domain names being used by the Iranian Revolutionary Guard Corps – a designated terrorist organization. The websites were being used to manipulate public opinion in many countries including the United States.

This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff talk about the recent action by the Board of Directors of the FDIC to authorize publishing a proposed rule to clarify that supervisory guidance is not regulation. John and Elliot discuss the value of such a rulemaking and the need for all of the agencies which were part of the original statement in 2018 to take similar action.

This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff talk about the recent Plenary held by the Financial Action Task Force (FATF). John and Elliot discuss how FATF is moving its work forward during the pandemic and the progress being made on the organization's strategic initiatives.

This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff to talk about the new Supplemental Advisory that FinCEN issued on identifying and reporting human trafficking. John and Elliot discuss who in FIs should be aware of the new guidance and some of the key points made in the issuance.

This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss a blog post on the website of Transparency International about the rise of corruption during the pandemic and its impact on inequality. John and Elliot examine the premise of the post that flows of illicit funds increase inequality in economies and societies.

This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss a written agreement entered into between the Federal Reserve Bank of Philadelphia and a bankers’ bank, as well as the requirements set out for the bank to repair the deficiencies in its BSA compliance program.

This week, Vice Chairman John Byrne, and Creative Director Elliot Berman of the AML RightSource staff the publication of information from leaked suspicious activity reports (SARs) and the implications for BSA reform and the impact on FI compliance programs.

This week, Vice Chairman John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss FinCEN’s Advanced Notice of Proposed Rulemaking in which it asks for comment on a number of ideas for possible changes to current BSA regulations.

This week, Vice Chairman John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss the anniversary of the attacks on 9/11 and how those events have shaped financial crimes compliance for almost two decades.

This week, Vice Chairman John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss the recent press release published by FinCEN regarding the confidentiality of SARs, as well as the heavy criminal penalties around the inappropriate release of them. John discusses previous issues, and regulatory changes that helped bolster the security around the access to SARs, as well as the timing around the press release and the potential catalyst behind the release itself.

This week, Vice Chairman John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss recent guidance by financial institution regulators about politically exposed persons – PEPs - and a call by Transparency International EU for increased vigilance on money laundering enforcement by EU regulators.

This week, Vice Chairman John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss the arrest of Steve Bannon and three others on various charges including money laundering, relating to a GoFundMe campaign to support building the border wall on the Mexican border. John and Elliot also discuss elements of the Democratic Party Platform on topics of interest to the financial crimes compliance community.

This week, Vice Chairman John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss the announced seizure by the Justice Department, the IRS and other federal agencies of cryptocurrency accounts from several terrorist organizations. The seizures related to terrorist financing campaigns by the Al-Qassam Brigades, Al-Qaeda and ISIS.

This week, Vice Chairman John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss the recent report by the Senate Permanent Subcommittee on Investigations on The Art Industry and US Policies the Undermine Sanctions. The report discusses the largest unregulated – from a BSA perspective – in the US and how it is being used to launder illegal funds and evade sanctions.

This week, Creative Director Elliot Berman and Special Advisor Tim White of the AML RightSource staff discuss the recent ransomware attack against Garmin and the implications of the attack which was perpetrated by a sanctioned entity.

This week, Vice Chairman John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss the latest actions in Congress to pass sweeping reform to the AML infrastructure.

This week, Vice Chairman John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss two actions from the EU. The decision by European High Court to restrict storage of personal information of EU citizens on servers in the United States and the recommendation by the European Commission that Member States do not grant financial support to companies with links to countries on the EU's list of non-cooperative tax jurisdictions. Both of these actions will impact the financial crime compliance community in the US.

This week, Vice Chairman John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss the US Supreme Court decision in Trump v. Mazars regarding subpoenas issued by several congressional committees, including House Financial Services, to the president for certain personal financial records and the purpose for the subpoenas.

This week, Vice Chairman John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss a bi-partisan effort in the US Senate to adopt sweeping reform to the AML infrastructure.

This week, Vice Chairman John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss a recent press release from the Department of Justice about the indictment of a US Army private for conspiring to have his Army unit attacked by foreign terrorists. Link to Press Release https://www.justice.gov/opa/pr/us-army-soldier-charged-terrorism-offenses-planning-deadly-ambush-service-members-his-unit

This week, Vice Chairman John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss recent press releases from the Comptroller of the Currency and Federal Reserve about their approaches to the full resumption of bank examinations.

In this episode of This Week in AML, Vice Chairman John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss a recent press release from the IRS about the need for people to remain vigilant in protecting themselves against the many scams being triggered by the pandemic environment.

This week, Vice Chairman John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss a recent letter from the Acting Comptroller of the Currency to the president and the executive director of the National Conference of Mayors, about the impact of the COVID-19 pandemic on National Banks. The letter seeks to make the mayors “aware of a certain set of risks to the nation’s banking system created by continued state and local lockdown orders".

This week, Vice Chairman John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss a recent FinCEN release about renewing the current suspicious activity report (SAR) form. The notice focuses on proposed changes on how to assess the burden of preparing a SAR and provides participants in the financial crimes compliance community an opportunity to provide public comments on their view of the burden.

In this week's episode, Creative Director Elliot Berman and Vice Chairman John Byrne of the AML RightSource staff discuss a recent FinCEN release about law enforcement cases that were significantly impacted by BSA filings. Among the seven published cases in the release, Elliot and John discuss how the information flowing from the FIs and among law enforcement agencies supports interdiction of money laundering activity.

This week, Vice Chairman John Byrne, and Vice President, Director of Sanctions, Tim White of the AML RightSource staff discuss a recent Op Ed article in the Washington Post on the proposed use of sanctions against global white supremacist groups. They both present the quick overview of the concept, the tactical response proposed by the United States Secretary of the Treasury, Stephen Mnuchin, and how Financial Crimes Compliance professionals can monitor and combat similar examples of hate speech and terrorism.

In this edition of AML Conversations, AML RightSource Vice Chairman John Byrne sits down with terrorist financing career expert Dennis Lormel to discuss the impact of the events of 9/11 on financial crimes compliance and on everyday life around the world.

Chuck Taylor and Tim White - The Maintenance Of AML Monitoring Systems by AML RightSource

In this episode of AML Conversations, Elliot Berman sits down with Bill Murray, head of IT and Risk Management at AML RightSource to discuss the importance of the human factors in cybersecurity today, and what threats we may face tomorrow.

In this episode of AML Conversations, AML RightSource Vice Chairman John Byrne sits down with Tara Sullivan, Special Agent in Charge (SAC) for the IRS in Las Vegas. John and Tara discuss financial crime prevention and oversight in the gaming industry from the vantage point of the IRS. Tara offers insight into AML/Financial Crime gaming community and the importance of private-public partnership in 2020.

In this edition, John Byrne sits down with Gary Shiffman, Founder and CEO of Giant Oak and professor at Georgetown University, to discuss his recent publication, “The Economics of Violence.” Shiffman explains how social science can be used to improve national security strategies and gives his views on how to address true AML reform.

In the beginning of a special new series of interviews with IRSCI on financial crime challenges with COVID-19 and beyond, Mike Batdorf, Executive Director of Refund and CyberCrime, explains key issues facing law enforcement and recent fraud themes for the private sector.

With the recent upgrade to the US evaluation by FATF because of the 2018 CDD rule, there has been a debate on the appropriateness of the rating given other areas of concern. Former FATF lead from the US, Chip Poncy, discusses this criticism and offers insight into FATF, their processes, and where the US stacks up with their counterparts.

Rick Small, Executive Vice President and Director of Financial Crimes for Truist, covers the many challenges of having staff adjust to remote work, staying current with COVID-19 frauds, assisting customers with the elements of the newly passed congressional stimulus package, as well as working with the regulators on exams and audits.

Dennis Lormel COVID - 19 Stimulus Fraud Schemes by AML RightSource

In this episode of AML Conversations, John Byrne sits down with Amit Sharma, CEO of Finclusive to discuss the global problem of financial access from the standpoint of using technology as a tool to give support to the underbanked and underserved. The two review the strategies of tackling access limitations as well as a project (The Rulebook) that will be a welcomed tool for those looking for enhanced compliance advice. Sit back and enjoy AML Conversations.

The US Government has used economic sanctions for over 200 years to exert pressure on foreign countries and others to implement its foreign policies. In recent times, the US has used sanctions against numerous foreign governments, including Iran, North Korea and Venezuela. The sanctions programs relating to Iran have a particularly complex and tortured past. In this edition of AML Conversations, Elliot Berman and Tim White of AML RightSource, discuss the history of these programs from their inception in 1979 to their current state.

In this edition of AML Conversations, John Byrne sits down with Thomas Durkin, the Education Program Director of the James W. Foley Legacy Foundation. Tom takes you through an emotional discussion of the impact his friend and photojournalist, Jim Foley, has had on hostage advocacy and the security needs of journalists everywhere. In 2014, Jim was captured and later murdered by ISIS. Jim's death prompted the creation of the Foundation whose vision is that all American hostages will return home and conflict journalists who bring truth to light, like Jim, will be protected.

In this edition of AML Conversations, John Byrne, Vice Chairman at AML RightSource sits down with Andy Price of World Council of Credit Unions on AML challenges for credit unions worldwide particularly as it applies to financial inclusion. The Council, among other things, supports financial markets in growing economies, along with global partners, such as USAID, the UN, and the World Bank by promoting financial inclusion, strengthening institutions as well as providing policy and regulatory support.

In this edition of AML Conversations, Elliot Berman, Marketing Advisor at AML RightSource sits down with Steven Cohen, Executive Vice President, Chief Operating Officer and Co-Founder of Basis Technology. The company is engineering a safer & more productive world by building proven Artificial Intelligence solutions for analyzing text, connecting data silos, and discovering digital evidence. The conversation focuses on how various elements of AI are influencing the effectiveness of transaction monitoring in the financial services space and what AML compliance professionals need to know about AI as it plays and increasing role in our interdiction activities.

In this edition of AML Conversations, John sits down with Kent Belasco, Director of the Commercial Banking program at Marquette University, one of only two undergraduate programs dedicated to banking in the United States. As the AML community continues to figure out the variety of skill sets needed by financial crimes professionals, having a potential workforce with actual banking backgrounds can certainly assist with understanding the risk challenges with certain products and services.

With the horrific shootings in Gilroy, El Paso and Dayton, AML Conversations asked former FBI TFOS head Dennis Lormel how the AML community can further assist law enforcement in dealing with white supremacists.

AML RightSource is launching a quarterly webinar series, "AML RightSource Voices". The first installment will be broadcast live on July 23rd, 2019 beginning at 12:30 pm ET, with this edition focusing on AML Hot Topics. The discussion will include insights into the intersection of AML compliance and the art and antiquities markets, how to ensure your compliance program supports working effectively with charities, the recently published Framework for OFAC Compliance Commitments, updates on sanctions relating to Iran and North Korea, high risk customers, customer due diligence, and the pending AML legislation in the House and the Senate. Participating in the broadcast will be AML RightSource staff members, John Byrne, Vice Chairman, Chuck Taylor, Executive VP, Head of Financial Crimes Advisory, and Tim White, Vice President, Business Development and Sanctions; as well as Rick Small, Executive Vice President, Director Financial Crimes, at BB&T and a member of the AML RightSource Advisory Board. The webinar will be moderated by Elliot Berman, Marketing Advisor at AML RightSource. Register on the AML RightSource website today!

In this special advisory board edition, AML RightSource Vice Chairman John Byrne interviews Marilu Jimenez, who recently joined the AML RightSource Advisory Board in early April. Marilu has extensive legal and compliance experience in both the United States and internationally. She runs her own advisory practice and shares her views on the regulatory environment in Latin America, as well as her dedication to training and other interesting aspects of the AML challenges we all face. Now sit back and enjoy AML conversations.

In this edition of AML Conversations, we dig deep into how prosecutors in the Commonwealth of Virginia get trained on many areas of law, including financial crime. Vice Chairman John Byrne’s guest, Elliott Casey, a former prosecutor himself, now trains law enforcement officials (prosecutors and investigators alike) on such disparate issues like digital evidence, forfeiture and complex financial crime. Casey also shares his views on the civil safe harbor, an extremely useful protection for financial institutions.

In this edition, we join AML RightSource Vice Chairman, John Byrne as he moderates a live panel of veteran AML experts during the 2019 ACAMS moneylaundering.com 24th Annual International AML & Financial Crime Conference in Hollywood, FL. The panel, made up of Chuck Taylor – AML RightSource Executive Vice President and Head of Financial Crime Advisory, Rick Small – BB&T Executive Vice President and Director of Financial Crimes, and Dennis Lormel – President of DML Associates, review community-specific topics like career progression, current AML legislation, as well as Chuck’s unique take on the ideal valuation process for SARs. We thoroughly enjoyed the live aspect of the panel interactions, and hope you will too. Sit back and enjoy AML Conversations.

In this edition, AML RightSource Vice Chairman John Byrne sits down with Dr. Thomas Kaczmarek, Director of the Center for Cyber Security Awareness and Cyber Defense, at Marquette University in Milwaukee, Wisconsin. In their conversation, John and Thomas talk about the myriad of challenges facing the AML community, and the importance of recognizing how to combat cyber threats through communication and collaboration with all relevant parties. They also discuss the skill sets needed to enter this program and similar programs around the country, as well as a number of other hot topics in the cyber area that continue to challenge all of us. Sit back and enjoy AML Conversations. Additional Link: https://www.marquette.edu/cyber-security/

In this episode, AML RightSource Vice Chairman, John Byrne, sits down with the chief of the IRS Criminal Investigation Division, Don Fort, to talk about a number of important elements in the AML community. John and Don discuss private-public partnerships and how essential it is for law enforcement and their counterparts in the private sector, to work together. Don also talks about the value of Bank Secrecy Act data, the importance of suspicious activity reports, and how all reports are analyzed and reviewed by the Internal Revenue Service’s Criminal Investigation Division. This year marks 100 years since IRS CI has been in existence. John and Don talk about changes in financial crime over the past century, and explore some of the similarities with crimes committed at the start of the IRS CI as they relate to crimes today. Sit back and enjoy AML Conversations. Additional Links: Feds charge 2 dozen in billion dollar Medicare brace scam: https://apnews.com/a4991f62e2f84b8cb9869efeaeb57a02

We are going live! AML RightSource Vice Chairman, and host of the “AML Conversations” podcast, John Byrne, will be the moderator for a live version of this podcast during the 24th Annual ACAMS Moneylaundering.com International AML & Financial Crime Conference in Hollywood, Florida. The AML Knowledge Session, sponsored by AML RightSource, will be held on Monday April 15th at 3:05PM. The session will feature a panel of AML community leaders including AML RightSource Executive Vice President, Chuck Taylor, ACAMS advisory board chairman and BB&T Executive Vice President and Director of Financial Crimes, Rick Small, and DML Associates President/CEO, Dennis Lormel. The expected topics of conversation include legislative proposals that have a high likelihood of traction in 2019, what the potential impact of the legislative moves might look like for the AML community, how to continue working with law enforcement, and the essential nature of private-public partnerships. John and the panel will also take audience questions.

In this edition, AML RightSource Vice Chairman John Byrne sits down with Angel Swift, the Vice President of Compliance and Financial Crimes Solutions at Enigma, an Operational Data Management and Intelligence company headquartered in New York City. They discuss the S.T.A.T. (“Stand Together Against Trafficking”) program; a collaborative tool designed in part, to disrupt finances related to human trafficking. Sit back and enjoy AML Conversations. Additional links: STAT Microsite - https://stat.enigma.com/ Sanctions Tracker: https://labs.enigma.com/sanctions-tracker/

In this edition of AML Conversations, AML RightSource Vice Chairman, John Byrne, sits down with Dr. Louise Shelley, Director of George Mason University’s Terrorism, Transnational Crime and Corruption Center. In their conversation they discuss the center, her recent book “Dark Commerce”, and the connection that the center has been able to amplify in its research in understanding the links between terrorism, transnational crime and corruption.

A special edition of AML Conversations, looking at a program at Marquette University that focuses on partnerships, emphasizing how “peacemaking” can improve communities and everyday lives. Numerous peacemaking initiatives are discussed in this conversation between AML RightSource Vice Chairman, John Byrne, and Patrick Kennelly, the Director of the Center for Peacemaking program at Marquette University.

The importance of asset forfeiture both globally and domestically is analyzed by international expert Stef Cassella in this riveting edition of AML Conversations. This edition features AML RightSource Vice Chairman, John Byrne, and Stef Cassella who is currently the author and publisher of Money Laundering and Forfeiture Digest, but more importantly has been instrumental in the use, at the federal level, of the asset forfeiture laws used by prosecutors and law enforcement throughout the 80s until today. You cannot understand AML without knowledge of asset forfeiture.

In this edition of AML Conversations, AML RightSource Vice Chairman, John Byrne, sits down with Elise Bean. Elise Bean is the former staff director and chief counsel of the US Senate Permanent Subcommittee on Investigations (PSI) and the author of a new book, Financial Exposure: Carl Levin’s Senate Investigations into Finance and Tax Abuse. You’ll hear an in-depth interview on the major financial crime investigations of the past 20 years that are covered in her new book.

In this edition of AML Conversations, AML RightSource Vice Chairman, John Byrne, talks with Steven Kemmerling. Steven is the CEO and Founder of MRB Monitor, a company that doesn’t support or oppose the banking of marijuana customers, but provides information so that institutions can make more informed decisions on whether or not their account holders are directly or indirectly managing products or businesses that have something to do with the sale of or with the enabling of the sale of marijuana. This conversation delves into the major challenges of banking marijuana businesses with the federal and state conflicts that still exist.

In this edition of AML Conversations, AML RightSource Vice Chairman, John Byrne, sat down with Mark Matthews who has had a long and distinguished career in both the private and public sectors. He is currently a member of Caplin & Drysdale Tax Controversies, Tax Litigation, and Exempt Organizations practice groups and has previous experience with the Internal Revenue Service (IRS), the Justice Department, as well as experience serving in senior AML roles. This conversation covers offshore banking, beneficial ownership, tax evasion, and the role played by IRS post 9/11 and up to today.

In this edition of AML Conversations, AML RightSource Vice Chairman, John Byrne, sat down with legendary compliance expert, Chuck Lewis. Chuck is retiring after 42 years of work in the banking industry, 40 of those years specifically in compliance. Throughout his career he has worked directly for financial institutions, advisory firms, and finally for the Missouri Bankers Association advising and working with banks on various compliance matters including Bank Secrecy Act issues. Chuck Lewis is well known for his training, compliance reviews, and great sense of humor.

In this edition of AML Conversations, AML RightSource Vice Chairman, John Byrne, sat down with the founder of the Antiquities Coalition. The Antiquities Coalition is a nonprofit organization created roughly four years ago to stop the use of stolen antiquities as terrorist financing tools for extremist organizations, a very compelling part of anti-terrorist financing. The Antiquities Coalition conducts excellent advocacy and awareness work dealing with the need for countries around the world to create relevant laws and regulations to address stolen antiquities and their use as a tool to commit horrific crimes.

In this edition of AML Conversations, AML RightSource Vice Chairman, John Byrne, sat down with John Roth. John Roth has spent his career addressing the major challenges facing the AML community in the public sector and now is leading an effort for an important component in a new part of the private sector. John Roth’s distinguished career includes being the lead of the 9/11 Commission Report on terrorist financing, serving as Inspector General at the Department of Homeland Security, and serving as the Department of Justice’s liaison to the Financial Action Task Force (FATF). Today he works for a digital currency exchange, Bittrex, as the Chief Compliance and Ethics Officer. The discussion focuses on John Roth’s career and ends with where Bittrex fits in with financial technology and his views on artificial intelligence.

This edition of AML Conversations by AML RightSource features John Byrne, AML RightSource Vice Chairman, and Jonathan Lopez, Partner in the white collar corporate investigations group at Orrick, Herrington & Sutcliffe in Washington DC. The discussion revolves around Jonathan’s previous career with the Department of Justice where he covered the Foreign Corrupt Practices Act (FCPA), personal liability cases, and money laundering issues. The conversation also covers his transition to the private sector and the perspective he now has from being a prosecutor to currently defending and advising white collar clients.

In this episode of AML Conversations by AML RightSource, John Byrne, AML RightSource Vice Chairman, sat down with Dan Soto during the 2018 ACAMS AML & Financial Crime conference in Hollywood, Florida. Dan Soto serves as Chief Compliance Officer at Ally Financial and is a member of the ACAMS Advisory Board. The conversation goes through Dan’s career starting in the public sector to where he is today, including comments about compliance in 2018 and some of the things he has learned throughout his career.

This is the second episode of AML RightSource's new podcast, AML Conversations. Our second episode features John Byrne, former ACAMS Executive Vice President and current AML RightSource Vice Chairman and Board Member, discussing the intersection of fintech and community banking with John Waupsh, Chief Innovation Officer at Kasasa, and author of “Bankruption: How Community Banking can Survive Fintech.”

This is the first podcast to AML RightSource's new series, AML Conversations. Our first episode features John Byrne, former ACAMS Executive Vice President and current AML RightSource Board Member, who discusses possible changes in AML and issues currently being discussed by Congress. This discussion is a recording from the Northern Ohio ACAMS Chapter event at the Happy Dog Tavern in Cleveland, Ohio.