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Legal Consultant Liz Fraccaro from the Antiquities Coalition joins John Byrne again to cover The Art Market Report 2023 and how to utilize the information to enhance eventual AML due diligence.

The Wolfsberg Group has published updated Anti-Bribery and Corruption Compliance Programs guidance. John and Elliot discuss critical elements of the guidance and the importance of financial service providers maintaining effective programs.

UBS and Art Basel recently issued their report, The Art Market 2023. The report includes a discussion of the concerns about the compliance burdens of market participants. John and Elliot examine those concerns and why those markets must align with others to stem money laundering and illicit finance. They also discuss the new stolen art app from the FBI.

John Byrne interviews the publisher of the Illicit Edge, Ryan Wallerstein, who shares his career journey from business to the Treasury Department to this new content endeavor.

Another very busy week in financial crime prevention. John and Elliot discuss several items, including new sanctions, a letter from the House and Senate to Treasury and FinCEN, and a financial trend analysis issued by FinCEN.

Several important items popped up this week. The Commodities Futures Trading Commission (CFTC) issued a civil complaint against Binance, the largest crypto exchange. The CFTC alleges that the company intentionally assisted its clients in evading US laws and regulations. Also, this week the White House hosted the second Summit for Democracy, focusing on reducing corruption and illicit finance. Treasury Secretary Janet Yellen announced a Commitment entered into by the participating countries centered on transparency of beneficial ownership information. John and Elliot discuss these items and how they impact the financial crimes compliance community.

The International Consortium of Investigative Journalists (ICIJ) has published a story about artifacts in the Metropolitan Museum of Art catalog linked to possible looting and trafficking. John and Elliot discuss the global problem of antiquities trafficking and its impact on the countries from which items come.

This week the US Department of Justice announced an indictment against seven individuals for a $100 million stolen identity refund scheme. The Office of the Comptroller of the Currency announced a penalty and prohibition against a former senior official at Wells Fargo. The US Treasury Department announced it has agreed to give in camera access to certain SARs to a House oversight committee. John and Elliot unpack this busy week and share their insights on these topics.

Dr. Michael Zimmer, Director, Center for Data, Ethics, and Society and Associate Professor & Vice-Chair, Department of Computer Science at Marquette University discusses: - Privacy and data ethics - The dark web - The “spatial project” - The Center’s work with policy makers on a variety of issues.

The US Department of Justice has updated its Corporate Enforcement Policy for criminal activity. John and Elliot discuss some aspects of the voluntary self-disclosure part of the CEP and how financial crime compliance professionals can make use of the policy guidance documents in reviewing elements of their compliance programs.

Liz Fraccaro, Attorney and Legal Consultant to the Antiquities Coalition, shares her insight on FATF’s recent report, Money Laundering and Terrorist Financing in the Art and Antiquities Market.

The Financial Action Task Force (FATF) held a plenary last week. FATF also issued a report on Money Laundering and Terrorist Financing in the Art and Antiquities Market. John and Elliot discuss some of the outcomes from the plenary, including the suspension of the Russian Federation’s FATF membership. They also look at key take-aways in the report on arts and antiquities.

How can we improve the cyberworld? One author tells us. We sat down with banking expert Tom Vartanian to discuss his recent book: “The Unhackable Internet: How Rebuilding Cyberspace Can Create Real Security and Prevent Financial Collapse.” Vartanian charges that our current cyber systems are unsustainable and offers several recommendations for the private and public sectors.

It has been a year since the Russian invasion of Ukraine. One of the immediate responses to Russia’s action was an ongoing coordinated effort by the US, G7 and European Union to limit Russia’s war-making ability through sanctions and export controls. John and Elliot discuss some key elements of the sanction programs and how they have performed since being imposed.

John and Elliot discuss several items this week, including a posting by the International Consortium of Investigative Journalists (ICIJ), a comment letter by a group of bank trade associations on the FinCEN Beneficial Ownership Registry proposal, and the announcement that the Organized Crime and Corruption Reporting Project (OCCRP) has been nominated for the Nobel Peace Prize.

Career agency official back over the progression of financial fraud from the Savings & Loan crisis to today. Jim Vivenzio, now with Perkins Coie LLP, provides insight on the state of the financial industry responding to the myriad of challenges they face.

The Wolfsberg Group and the Institute of International Finance have issued a joint comment letter to the European Banking Authority on de-risking. John and Elliot discuss the details of the comment letter, including its recommendation that the EBA adopt definitions and other approaches on de-risking taken by FATF, as the EBA works toward updating its AML/CFT regime for the European Union.

Chief of the Internal Revenue Service’s Criminal Division (IRSCI) Jim Lee details the 2022 results of his “BSA Challenge” to his staff. The Challenge explores and explains the value to law enforcement of Bank Secrecy Act data---CTRs, SARs, CMIRs, FBARS and Form 8300’s.

This week Transparency International released its 2022 Corruption Perceptions Index (CPI). The CPI uses a number of criteria to evaluate the status of corruption in 180 countries. For 2022 the global average remained unchanged at 43 on a 100 point scale. The report shows that 124 countries have not made any change since 2021 and the number of countries declining has increased. John and Elliot discuss some of the findings in the CPI and the links between corruption, deterioration in human rights, the rise of authoritarianism, and the continuing assault on democracy.

his week a retired senior FBI agent Charles McGonigal was arrested on charges of money laundering and violating US sanctions. Also this week, the Financial Crimes Enforcement Network (FinCEN) issued an alert on Potential U.S. Commercial Real Estate Investments by Sanctioned Russian Elites, Oligarchs, and Their Proxies. John and Elliot discuss the arrest and its implications for national security and look at the details of the alert including the typologies and red flags included in it. They also examine McGonigal’s relationship to a sanctioned Russian oligarch and efforts by other sanctioned oligarchs to us real estate transactions to hide and preserve their wealth.