AML Conversations

Homeland Security Investigations has launched Operation Boiling Point an initiative to curb organized retail crime and cargo theft. The effort brings together public and private organizations. John and Elliot discuss the importance of the focus on this challenge which impacts many levels of the economy. They also chat about the role for the financial crime compliance community in these activities.

This week the Office of Foreign Assets Control (OFAC) and the Financial Crimes Enforcement Network (FinCEN) issued enforcement actions against Bittrex, Inc., a virtual currency exchange. John and Elliot discuss the details of the two actions, including the general AML program failures and ineffective sanctions compliance efforts. They also talk about how other financial service providers can use the orders to check the status of their own sanctions and AML compliance programs.

This week, the Basel Institute on Governance published its 2022 AML Index. The index assesses countries’ money laundering and terrorist financing risks and capacity to counter them. John and Elliot chat about how the index is constructed, what it says about the state of the global response to these risks, and other key take-aways from this year’s report..

The Office of Foreign Assets Control (OFAC) has issued updated FAQs clarifying the regulations about people in the US sending electronic remittances to Cuba. This update is particularly timely given the recent devastating hurricane damage. John and Elliot review the key elements of the updates. They discuss the approved channels, the persons authorized to send and receive payments, and how banks and other service providers can meet their obligations under the rules.

John and Elliot discuss several topics from this week: a recent ProPublica article on human traffickers forcing victims into cyberscamming, recent releases from the US Treasury Department, and insights from the Missouri Bankers Association BSA/AML Conference.

The US House Financial Services Committee held a hearing this week on the availability of financial services in the Caribbean region. The hearing included testimony from Mia Amor Mottley, Prime Minister of Barbados, and from a panel of experts. John and Elliot discuss the challenges and possible solutions raised at the hearing, including the reduced availability of correspondent banking services, the potential impact of digital currencies, and several new legislative proposals.

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.