AML Conversations

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 a...

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...

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 codif...

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...

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 acces...

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 intere...

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 expec...

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 recommendation...

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...

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 a...

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 financia...

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.