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.
Sep 09, 2022•14 min
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.
Sep 08, 2022•25 min
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.
Sep 07, 2022•14 min
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.
Sep 07, 2022•33 min
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.
Aug 29, 2022•23 min
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.
Aug 26, 2022•15 min
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...
Aug 25, 2022•25 min
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 ...
Aug 19, 2022•12 min
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.
Aug 17, 2022•29 min
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 I...
Aug 12, 2022•12 min
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 earli...
Aug 05, 2022•12 min
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.
Aug 02, 2022•26 min
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 ...
Jul 29, 2022•13 min
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.
Jul 28, 2022•20 min
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.
Jul 25, 2022•34 min
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.
Jul 22, 2022•15 min
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.
Jul 18, 2022•27 min
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.
Jul 15, 2022•15 min
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.
Jul 08, 2022•14 min
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...
Jul 01, 2022•11 min
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.
Jun 30, 2022•35 min
John interviewed Michael Lee, IRSCI Supervisory Special Agent, Western Cyber Crime Unit, on crypto, NFTs and Decentralized Finance.
Jun 27, 2022•24 min
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.
Jun 24, 2022•12 min
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.
Jun 17, 2022•13 min
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.
Jun 10, 2022•12 min
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 virtua...
Jun 03, 2022•12 min
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 financia...
May 27, 2022•11 min
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.
May 23, 2022•35 min
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.
May 20, 2022•12 min
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.
May 13, 2022•10 min
