AML Conversations

John Byrne and Terry Pesce discuss the recent Interagency Guidance on Third-Party Relationships: Risk Management. They look at the implications of the guidance and what banks should do to assess their current risk management process for interactions with third parties.

US bank regulators have issued interagency guidance on third-party risk management. The new pronouncement combines and updates past guidance issued by the individual agencies. John and Elliot discuss key parts of the guidance and some implications for banks and their vendors.

There have been several recent articles about the effectiveness of US sanctions. John and Elliot examine this issue and discuss where the programs have succeeded or failed to achieve their stated goals.

Seven years ago, the Panama Papers were published. Recent statistics show that registrations of anonymous corporations in Panama have dropped by more than 50% in the past ten years. John and Elliot discuss the impact of Papers on corporate activities in Panama and ownership transparency across the globe.

Jonathan Fishman, one of the authors of the 2023 Treasury Department’s De-risking Strategy, discusses the various recommendations and the rationale for some of the words used to describe the problem and identifies other key areas of the report.

US law enforcement agencies recently completed a three-month campaign to disrupt frauds perpetrated by foreign actors. John and Elliot discuss the campaign’s details, why it is essential, and what financial service providers can do to support it. They also chatted about several other events this week.

Don Fort, former Chief of IRS - Criminal Investigation Division, Director of Investigations at Kostelanetz LLP, and member of the Advisory Board at AML RightSource, discusses his recent testimony before the Senate Finance Committee about potential IRS funding cuts and their impact on federal law enforcement.

John and Elliot explore how intermediaries are helping evade sanctions and bring luxury goods to Russia. They also discuss new cooperation between the sanction teams in the US and EU and touch on other financial crime prevention news.

The New York Attorney General has proposed legislation to regulate the cryptocurrency industry. The proposal includes provisions protecting investors, increasing transparency, and eliminating conflicts of interest. John and Elliot discuss key aspects of the proposal and its implications for federal regulation of the virtual currency space. They also touch on several other news items from this week.

The US Treasury has issued its 2023 De-risking Strategy. The report reviews the reasons that banks engage in de-risking and includes recommendations to reduce the impact of the practice. John and Elliot discuss their thoughts on the strategy, where they think Treasury got things right, and where it missed opportunities.