AML Conversations

The Financial Action Task Force (FATF) recently issued updated Guidance for a Risk-Based Approach to the Real Estate Sector. The updated guidance focuses on the importance of member countries to bring the real estate sector into their money laundering/terrorist financing regimes. John and Elliot discuss the guidance, including the breadth of its coverage, the need for understanding and training of real estate professionals, and how the timing of the guidance intersects with FinCEN’s request for information about the sector.

John discusses with Kent Belasco, the Director of Marquette University’s Commercial Banking Program, a recent project with a microfinance organization to assist an impoverished rural farming community outside Panama City.

Alan Ketley, the new Executive Secretary of the Wolfsberg Group discusses the mission of the group, their focus on a variety of AML related topics: correspondent banking, PEPs, trade finance and recent papers covering challenges such as negative news utility and broad collaboration.

FATF (the Financial Action Task Force) has issued a report: Partnering in the Fight Against Financial Crime – Data Protection, Technology and Private Sector Information Sharing. The report discusses the importance of balancing privacy with the need for financial services providers to share information to help stop the spread of financial crime. John and Elliot discuss the goals of the reported activities and the focus of several of the case studies set out in the report.

Rob Triano of CipherTrace discusses his career move from traditional banking to the Federal Reserve to CipherTrace and addressing the unique challenges of the crypto world. Advising clients with cybersecurity, money laundering and terrorist financing potentials in this market and offering insight on what to expect going forward.

The US House of Representatives is acting on proposed amendments to the National Defense Authorization Act, including the ENABLERS Act. John and Elliot discuss the status of the amendments and what is likely to make it into the version that goes to the US Senate.

The presidency of the Financial Action Task Force has recently transferred to Singapore and the new president has issued the organizational priorities for the next two years. John and Elliot discuss the work of FATF and the priorities and how they integrate with activity going on throughout the financial crime prevention community.

A bi-partisan group from the US Congress has attached the ENABLERS Act to the FY 2023 National Defense Authorization Act (NDAA). The ENABLERS Act would bring a number of groups and individuals who assist in anonymizing organizations and their transactions under the recordkeeping and recording regime of the Bank Secrecy Act. John and Elliot discuss the impact that passage of the Act would have on closing current holes in BSA coverage and the likelihood of passage of the Act, now that it is linked to adoption of the NDAA.

Tom Vartanian, the Executive Director of the Financial Technology & Cybersecurity Center discussed the ongoing problems with cybersecurity, cryptocurrency and current regulations and recommendations regarding how to address ransomware.

John interviewed Michael Lee, IRSCI Supervisory Special Agent, Western Cyber Crime Unit, on crypto, NFTs and Decentralized Finance.