AML Conversations

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 entit...

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 purpo...

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...

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...

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...

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.

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.

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 ju...

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.