AML Conversations

The American Bar Association House of Delegates has approved changes to strengthen a lawyer’s obligations as a gatekeeper. Also, FinCEN issued a Notice about the increase in worker’s compensation insurance and payroll tax fraud in the construction industry, and the US Treasury Department released information about its efforts pursuing wealthy tax evaders. John and Elliot discuss these developments and how they may shape compliance in the future.

This week, Attorney General spoke to the American Bar Association, and OFAC issued guidance on providing humanitarian assistance to Syria. John and Elliot discuss the speech and guidance and look at the recent release of SAR filing data by FinCEN.

Both the US House and Senate have been very active ahead of leaving for their August recess. John and Elliot discuss the Senate proposal to apply the AML/CFT compliance requirements to all the players in the virtual assets space and the proposals that moved to the House floor on stablecoins, limiting public company disclosures on climate change impact, and many other issues.

John Byrne and Shannon Frontanes of Thomson Reuters Special Services and a provenance expert, discuss her insight on cultural artifacts and their use for money laundering and related crimes.

The US Departments of Commerce, Treasury, and Justice recently updated their voluntary self-disclosure policies. The DOJ also announced the sentencing in a case for conspiring to violate Iranian sanctions and an indictment for a fraudulent charitable contribution tax scheme. In Europe, Interpol announced that it disrupted a transnational migrant smuggling network resulting in 62 arrests. John and Elliot discuss these announcements in a busy week in the financial crime prevention community.

The Subcommittee on National Security, Illicit Finance, and International Financial Institutions of the US House Financial Services Committee held a hearing this week on the Potential Consequences of FinCEN’s Beneficial Ownership Rulemaking. The hearing focused on the proposed beneficial ownership information registry proposed by FinCEN under the Corporate Transparency Act. John and Elliot discuss the testimony given by the witnesses and statements of the committee members.

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.