AML Conversations

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...

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...

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,...

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...

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 authoritarian...

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 guidanc...

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 partners...

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...

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 pl...

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 Owners...

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...

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 futu...

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...

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 activi...

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, t...

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 the...

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 fina...

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 a...