Aml Rightsource

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.

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.

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.

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.

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 is going to get as part of the Inflation Reduction Act, $80B over 10 years. For example, “87,000 armed agents” is being repeated in the media. Remind us of the important work IRS-CI does Explain the facts around “87,000 armed agents?” Question: What’s your take of these statements in the media? Question: What’s the real-life impact to those working for IRS-CI from these types of comments? Question: IRS-CI works more than just tax cases - are there examples of cases that IRS-CI works that have broad national and

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 talk about the importance of having open communications with your bank regulators as you explore offering crypto-related services.

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.

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 Inflation Reduction Act to modernize the IRS.

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 earlier sanctions.

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.

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 information about the sector.

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.

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.