AML Conversations

Dr. Michael Zimmer, Director, Center for Data, Ethics, and Society and Associate Professor & Vice-Chair, Department of Computer Science at Marquette University discusses: - Privacy and data ethics - The dark web - The “spatial project” - The Center’s work with policy makers on a variety of issues.

The US Department of Justice has updated its Corporate Enforcement Policy for criminal activity. John and Elliot discuss some aspects of the voluntary self-disclosure part of the CEP and how financial crime compliance professionals can make use of the policy guidance documents in reviewing elements of their compliance programs.

Liz Fraccaro, Attorney and Legal Consultant to the Antiquities Coalition, shares her insight on FATF’s recent report, Money Laundering and Terrorist Financing in the Art and Antiquities Market.

The Financial Action Task Force (FATF) held a plenary last week. FATF also issued a report on Money Laundering and Terrorist Financing in the Art and Antiquities Market. John and Elliot discuss some of the outcomes from the plenary, including the suspension of the Russian Federation’s FATF membership. They also look at key take-aways in the report on arts and antiquities.

How can we improve the cyberworld? One author tells us. We sat down with banking expert Tom Vartanian to discuss his recent book: “The Unhackable Internet: How Rebuilding Cyberspace Can Create Real Security and Prevent Financial Collapse.” Vartanian charges that our current cyber systems are unsustainable and offers several recommendations for the private and public sectors.

It has been a year since the Russian invasion of Ukraine. One of the immediate responses to Russia’s action was an ongoing coordinated effort by the US, G7 and European Union to limit Russia’s war-making ability through sanctions and export controls. John and Elliot discuss some key elements of the sanction programs and how they have performed since being imposed.

John and Elliot discuss several items this week, including a posting by the International Consortium of Investigative Journalists (ICIJ), a comment letter by a group of bank trade associations on the FinCEN Beneficial Ownership Registry proposal, and the announcement that the Organized Crime and Corruption Reporting Project (OCCRP) has been nominated for the Nobel Peace Prize.

Career agency official back over the progression of financial fraud from the Savings & Loan crisis to today. Jim Vivenzio, now with Perkins Coie LLP, provides insight on the state of the financial industry responding to the myriad of challenges they face.

The Wolfsberg Group and the Institute of International Finance have issued a joint comment letter to the European Banking Authority on de-risking. John and Elliot discuss the details of the comment letter, including its recommendation that the EBA adopt definitions and other approaches on de-risking taken by FATF, as the EBA works toward updating its AML/CFT regime for the European Union.

Chief of the Internal Revenue Service’s Criminal Division (IRSCI) Jim Lee details the 2022 results of his “BSA Challenge” to his staff. The Challenge explores and explains the value to law enforcement of Bank Secrecy Act data---CTRs, SARs, CMIRs, FBARS and Form 8300’s.