Aml Rightsource

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 just provided by the system vendor.

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.