Aml Rightsource

The Financial Crime Enforcement Network (FinCEN) has issued its Ransomware Trends for the second half of 2021. John and Elliot look at the process that FinCEN used in its financial trend analysis and discuss some of the conclusions in the report, including that a significant number of ransomware attacks have some connection to actors in Russia.

Kateryna Boguslavska, PhD, Project Manager Basel AML Index at the Basel Institute on Governance, discusses the 2022 AML Index and some examples of recent metrics from Eastern Europe and other regions. Dr. Boguslavska also covers the importance of “effectiveness” in understanding jurisdictional risks. View the 2022 report here - https://baselgovernance.org/basel-aml-index

The Center for Strategic and International Studies has released a report on Mitigating Financial Access Challenges. The report focuses on ways to overcome the difficulty faced by NGOs trying to transfer humanitarian funding to areas subject to sanctions or active counterterrorism measures. John and Elliot discuss the continued impact of de-risking, some of the prior work done on the problem, and examine some of the proposals to improve financial access laid out in the report.

AMLRS Advisory Board Member Nicolas Choules-Burbidge, formerly a senior executive at the Office of the Superintendent of Financial Institutions (OSFI) in Canada, where he started and oversaw the AML/CFT and Compliance Division (AMLC) for 15 years, discusses the 2021-2022 OSFI Report to Parliament and his views on AML supervision in Canada.

Jeff Pearlman, NY Times Best Selling Author of nine books and author of a new book, “The Last Folk Hero” about Bo Jackson, discusses the recent fraud in Mississippi with public funds that involves Brett Favre and his view on the challenge of local journalism today. https://jeffpearlman.com/

Jeff Pearlman, NY Times Best Selling Author of nine books and author of a new book, “The Last Folk Hero” about Bo Jackson, discusses the recent fraud in Mississippi with public funds that involves Brett Favre and his view on the challenge of local journalism today. https://jeffpearlman.com/

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.

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.