AML Conversations

The US Department of State has issued its Implementation Plan for the US Strategy on Countering Corruption. The five-pillar Plan outlines actions for the department, its agencies, and its domestic and international partners. John and Elliot discuss the plan and its impact on global anti-corruption efforts.

The Inspector General from the US Treasury Department has issued an audit report on FinCEN’s BSA data retention processes. The Financial Conduct Authority in the UK is reviewing the treatment of domestic PEPs by financial services companies. Moody’s Analytics issued a white paper on wildlife trafficking. John and Elliot discuss these developments and what you should know about them.

Stef Cassella joins John for the record-breaking third appearance. They discuss: How Stef has been assisting other countries in drafting forfeiture legislation (criminal and civil) and in training their prosecutors and judges, a recognition in countries that are used as money laundering centers that they need a means to deter foreign criminals from using their financial institutions for that purpose What the congressional proposal called the “FAIR Act” would do to the civil forfeiture infrastructure and Stef’s view on an upcoming Supreme Court case, Culley v. Marshall, where Plaintiffs ask the Court to recognize a right to an immediate post-seizure hearing whenever law enforcement seizes property for civil forfeiture.

The International Crisis Group issued a report on the impact of sanctions on peacemaking. John and Elliot discuss critical insights in the report. They also examine whether or not sanctions against Russia have been effective and several other news items of the week.

The podcast discusses the Wolfsberg Group's comment letter on FATF's proposal on NPOs, the challenges of implementing AML compliance programs in conflict zones, and updates on the FADIF travel rule, FinSEN registration extension, and upcoming webinars.

Kevin Lee, Director, Financial Crime Technology at AML RightSource, recaps his speech on how technology can be harnessed for financial crime at the European Anti-Financial Crime Summit. Topics include changes in compliance technology, data quality and governance in AI, robotic process automation, and establishing a model risk management framework.

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.