AML Conversations

Executive Order on Banking Access, Paxos Settlement, and Russian Sanctions Gaps

Aug 15, 2025
Dive into the intriguing implications of the White House's executive order aimed at ensuring fair banking for all, which may inadvertently heighten risks of white-collar crime. Discover the groundbreaking CI-FIRST initiative that enhances collaboration between the IRS and financial entities to tackle financial crime more effectively. Unpack the significant $26.5 million settlement involving Paxos for regulatory failures linked to Binance, and explore corporate accountability with Liberty Mutual's bribery case, shedding light on enforcement challenges surrounding U.S. sanctions.
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INSIGHT

Executive Order Risks Weakening Risk Decisions

  • The White House executive order on 'Guaranteeing Fair Banking' pressures banks away from independent risk-based decisions.
  • John Byrne warns this could increase exposure to white-collar crime and systemic risk.
INSIGHT

Risk Models Are Inherently Subjective

  • Risk-scoring models always include subjective components and cannot be purely objective.
  • Elliot Berman cautions that insisting on 'objective' standards is flawed and may push banks away from active risk management.
ADVICE

Join CI-FIRST For Better Information Sharing

  • Engage proactively in public-private partnerships like IRS CI's CI-FIRST to improve information sharing.
  • John Byrne highlights CI-FIRST as a model to optimize financial record requests and BSA data use.
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