Aml Rightsource

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.

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.

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.

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.

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.

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 to adoption of the NDAA.

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.

John interviewed Michael Lee, IRSCI Supervisory Special Agent, Western Cyber Crime Unit, on crypto, NFTs and Decentralized Finance.

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.

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.

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.

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 virtual currencies and assets and the risks they present.

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 financial access is a serious concern, not just for charities and non-profits, but for entire nations, and some of the solutions that can be instituted to reduce the impact of the problem.

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.

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.

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.

Homeland Security Investigations’ (HSI) Outreach Initiative – Cornerstone recently shared information about the rising level of organized retail crime (ORC) being perpetrated by transnational criminal organizations. This activity involves planned theft of retail goods for later sale through gray market channels. John and Elliot discuss the value of HSI outreach to the financial crime prevention community and some of the red flags for identifying ORC.

The International Consortium of Investigation Journalists (ICIJ) recently shared documents with The Irish Times about the Kinahan organized crime cartel. The Irish Times published an extended article about the actions of the cartel in moving to the UAE and taking advantage of its secrecy laws to avoid prosecution. John and Elliot discuss the recent US sanctions issued against Daniel Kinahan, FATF’s gray listing of the UAE, and the importance of financial transparency.

The Financial Crimes Enforcement Network (FinCEN) recently issued guidance about kleptocracies and foreign corruption. The guidance includes insights into typologies and includes red flags. John and Elliot discuss the guidance, the global focus and nature of the problems identified in the guidance, and the value of the red flags as a training tool.

For this episode of our AML Conversations podcast, we sit down with Sara Crowe, the strategic initiatives director at Polaris, a non-profit working to end human trafficking. We discuss how human trafficking has evolved in recent years and concerns following refugees fleeing Ukraine, as well as actionable insights for financial institutions as to how they can help prevent human trafficking. We hope you enjoy this episode.