AML Conversations

Experts from InterAction explain the continuing efforts to enhance financial access for humanitarian organizations, including UN Resolution 2664 and the US General Licenses by OFAC. Kathryn Striffolino, Senior Manager for Humanitarian Practice, has worked in international human rights and humanitarian affairs for over a decade and a half, focusing on human rights and mass atrocity crime documentation, analysis and policy, and humanitarian response in conflict settings. Andrea Hall joined InterAction in March 2022 as Senior Manager of the Together Project. She brings over ten years of experience as a policy advocate, analyst, and organizer at the state and federal levels.

Sanctions against Russia have been a meaningful part of the support for Ukraine by the United States and the European Union. A significant challenge to the sanctions has been the efforts by bad actors and supporters of Russia to evade them. John and Elliot discuss the evasion problem, how the US is working with its allies to increase the impact of the sanctions, and ideas from some economists on increasing sanctions effectiveness.

Legal Consultant Liz Fraccaro from the Antiquities Coalition joins John Byrne again to cover The Art Market Report 2023 and how to utilize the information to enhance eventual AML due diligence.

The Wolfsberg Group has published updated Anti-Bribery and Corruption Compliance Programs guidance. John and Elliot discuss critical elements of the guidance and the importance of financial service providers maintaining effective programs.

UBS and Art Basel recently issued their report, The Art Market 2023. The report includes a discussion of the concerns about the compliance burdens of market participants. John and Elliot examine those concerns and why those markets must align with others to stem money laundering and illicit finance. They also discuss the new stolen art app from the FBI.

John Byrne interviews the publisher of the Illicit Edge, Ryan Wallerstein, who shares his career journey from business to the Treasury Department to this new content endeavor.

Another very busy week in financial crime prevention. John and Elliot discuss several items, including new sanctions, a letter from the House and Senate to Treasury and FinCEN, and a financial trend analysis issued by FinCEN.

This week the White House hosted the second Summit for Democracy, focusing on reducing corruption and illicit finance. Treasury Secretary Janet Yellen announced a Commitment entered into by the participating countries centered on transparency of beneficial ownership information. John and Elliot discuss these items and how they impact the financial crimes compliance community.

The International Consortium of Investigative Journalists (ICIJ) has published a story about artifacts in the Metropolitan Museum of Art catalog linked to possible looting and trafficking. John and Elliot discuss the global problem of antiquities trafficking and its impact on the countries from which items come.

This week the US Department of Justice announced an indictment against seven individuals for a $100 million stolen identity refund scheme. The Office of the Comptroller of the Currency announced a penalty and prohibition against a former senior official at Wells Fargo. The US Treasury Department announced it has agreed to give in camera access to certain SARs to a House oversight committee. John and Elliot unpack this busy week and share their insights on these topics.