AML Conversations

Jenni Halleran, the Head of Financial Crimes Investigations at Silicon Valley Bank, discusses her career path, growing up in a blue collar town, and deciding to go to law school originally to be a prosecutor. She covers how she then found the AML community and shares recommendations for being successful and how to manage to help others be successful.

Mark Freedman, CEO / Founder of Rebel Global Security and former Chief of Section in the Counter-Terrorism Bureau at the US State Department discusses the need for Chief Security Officers to be more proactive on issues of national security including cyber, terrorism, and other issues related to financial crime.

A recent essay on Lawfare caught John and Elliot’s attention. The authors reviewed the costs and funding sources of the January 6th insurrection and paths to interdict financing of domestic terrorist activities. John and Elliot discuss the implications of the funding schemes used by domestic terrorists, the challenges presented to financial service providers in detecting their activities, and the importance of international cooperation on this issue.

Guy Ficco, Deputy Chief of IRS-Criminal Investigation, joins us to discuss his new role, the vast coverage of financial crime by the IRS, the importance of private-public partnership, and the facts about new IRS resources.

The US Government Accountability Office (GAO) recently issued a report to Congress. The report focused on how the US Department of Justice is complying with its obligation to report on how Suspicious Activity Reports (SARs) are being used by law enforcement. John and Elliot discuss the report, the value of better information on SAR use, and the challenges in gathering meaningful data and presenting it in an actionable format.

John Byrne chats with John M. Geiringer, of Barack Ferrazzano Financial Institutions Group, about the new book he edited and co-authored, Countering the Financing of Terrorism: Law and Policy, by the American Bar Association.

Dennis Lormel, President of the Society of Former Agents of the FBI, discusses the ramifications of the public attacks on the FBI by elected officials in response to the search warrant issued to retrieve classified documents held by former President Trump. Lormel explains the legal process and the need for the AML community to continue supporting law enforcement from clear political attacks.

The Wolfsberg Group, an association of 13 global banks, this week issued a guidance document on requests for information (RFI). The focus of the guidance is best practices in correspondent banks using RFIs in transaction monitoring. John and Elliot discuss some of the issues raised in the guidance and the value of effective use of RFIs. They also talk about the importance of banks being prompt in their responses to RFIs.

There have been outrageous comments made by “policymakers” about the IRS since the passage of the Inflation Reduction Act. AMLRS Chairman of the Advisory Board John Byrne talked to former IRSCI Chief DonFort about the facts regarding the IRA funding, the mission of IRSCI, and the impact misinformation is having on staff. Here’s a taster of some of the questions discussed: Question: There have been questions and a lot of information (misinformation) out there about the substantial funding the IRS is going to get as part of the Inflation Reduction Act, $80B over 10 years. For example, “87,000 armed agents” is being repeated in the media. Remind us of the important work IRS-CI does Explain the facts around “87,000 armed agents?” Question: What’s your take of these statements in the media? Question: What’s the real-life impact to those working for IRS-CI from these types of comments? Question: IRS-CI works more than just tax cases - are there examples of cases that IRS-CI works that have broad national and international importance? Question: How will the IRS use this funding?

The Federal Reserve has issued additional information for banking organizations about crypto-asset-related activities. It is contained in Supervisory Letter SR 22-6. The Letter reviews areas of risk for providers of these products. It also reminds organizations there are regulatory notice requirements they need to follow. John and Elliot discuss the risks identified by the Fed and how this Letter relates to a joint statement on crypto-asset policy issued by US regulators in late 2021. They also talk about the importance of having open communications with your bank regulators as you explore offering crypto-related services.