Aml Rightsource

Tom Vartanian is a former federal banking regulator and law professor. In this two-part podcast, we discuss his views on what caused the various the financial crises in the US, the need for improved or “smart” regulation, how accountable are the policy makers and the private sector, and the need to utilize technology to prepare us for any future financial panics.

Tom Vartanian is a former federal banking regulator and law professor. In this two-part podcast, we discuss his views on what caused the various the financial crises in the US, the need for improved or “smart” regulation, how accountable are the policy makers and the private sector, and the need to utilize technology to prepare us for any future financial panics.

The Office of Foreign Assets Control of the United States Department of the Treasury (“OFAC”), the New York State Department of Financial Services, and the Federal Reserve recently issued a series of enforcement actions against Mashreqbank PSC, Dubai, United Arab Emirates. The action all related to failures by the Bank to comply with certain sanction programs. John and Elliot discuss the orders, the specific violations, and the overall usefulness of enforcement actions.

INTERPOL has released its latest survey of member countries – Assessing Crimes Against Cultural Property 2020. The report discusses the INTERPOL Stolen Works of Art Database and the recently release ID-Art mobile application. John and Elliot discuss the increases in cultural crimes during 2020 and the challenges faced by countries around the globe as they work to reduce illicit excavations and theft of assets.

The Financial Action Task Force held its most recent Plenary last week. The delegates completed work on a number key initiatives – updated guidance for a risk-based approach to virtual assets and virtual assets service providers, and a final report on a survey on implementation of standards on cross-border payments. John and Elliot discuss the outcomes of the Plenary and what it means for the financial crime compliance community.

The Biden Administration and the Treasury Department have unveiled a proposal to improve tax fairness and compliance. The proposal seeks to enhance tax reporting by authorizing the IRS to require financial institutions to report two additional items of information on its customers: the total amount of funds deposited into the account and the total amount withdrawn over the course of a year. John and Elliot discuss the implications of the proposal and its possible impact on financial service company’s compliance activities.

In August 2021, Global Financial Integrity published Acres of Money Laundering – Why U.S. Real Estate is a Kleptocrat’s Dream. The report compares the real estate money laundering regulations across the G7 countries. John and Elliot discuss the report’s findings on the use of the US commercial real estate market to launder funds and the roles played in the transactions by various gatekeepers. They also call out some of the key recommendations in the report. A link to the report -https://gfintegrity.org/report/acres-of-money-laundering-why-u-s-real-estate-is-a-kleptocrats-dream/ Here's a great article that discusses real estate and the need for real reforms in Australian AML regulations - https://www.amlrightsource.com/news/real-estate-and-the-need-for-real-reforms-in-australian-aml-regulations

The International Consortium of Investigative Journalists (ICIJ), The Washington Post and many other news organizations around the world have published a series of stories based on nearly 12 million records obtained by the ICIJ – known as the Pandora Papers - which shed light on how heads of state, the super-rich, and criminals have hidden their assets.  John and Elliot look at some of the key findings by the ICIJ, The Post and other media outlets and discuss the implications for oversight and regulation going forward.

This week the Department of Homeland Security added an item to its website entitled “if you see something, say something.” The item discusses how individuals can report suspicious activity. John and Elliot look at some of the red flags identified by the DHS and discuss the impact of viewing suspicious activity reporting as something beyond the responsibility of entities regulated under the Bank Secrecy Act.

In this episode of AML Conversations, John Byrne and David McLaughlin discuss David’s journey in creating QuantaVerse and the problems he set out to solve. They talk about the interaction of technology and human analytics and how to develop effective processes for superior outcomes by balancing the strengths of both.

This week FinCEN published an Advance Notice of Proposed Rulemaking regarding anti-money laundering regulations for the trade in antiquities. John and Elliot look at some of the questions in the ANPRM, discuss who FinCEN would like to receive comments from, and remind listeners about the importance of providing comments to ANPRMs and the proposed regulation when they are published later this year.

In this episode of AML Conversations, John Byrne, Debra LaPrevotte, and Dr. Louise Shelley discuss environmental crime and the need for a more cohesive approach. Wildlife trafficking continues to enable the facilitation of illicit funds and is the “soft underbelly of organized crime.” Our panel discusses this global problem and what can be done to address what is a “low risk, high reward” crime.

This week the Basel Institute on Governance published its 10th AML Index. The Index looks at activities by 112 countries to effectively operate AML/CFT systems. John and Elliot share some insights into how the index is applied and the results.

This week is the 20th anniversary of 9/11. The events of that day impacted many lives and changed how people view the world and the threats in it. It also impacted how the financial crime compliance community looks at threats and performs its work. John and Elliot share some insights on how 9/11 changed things over the past 20 years.

This week FATF issued a Mutual Evaluation Report for Japan. John and Elliot discuss the findings in the report, the report process, and the focus of the process on assessing the effectiveness of a nation’s measures and their level of compliance with the FATF Recommendations.

This week saw a White House summit on cybersecurity making clear the connection between cybersecurity and national security. John and Elliot discuss the importance of connecting the domestic focus with our efforts globally to form strong partnerships and build effective cooperation to thwart cyber threats, and protect the international financial system.

This week saw the rapid fall of the Afghan government to the Taliban. John and Elliot discuss the collateral damage from this sudden change, examining the impact on financial access for individuals, NGOs and national government, the safety of historical artifacts, and how these changes can affect civil liberties.

This conversation with two of the authors of a recent article for the Federal Reserve Bank of Atlanta that examines claims of the connection between bank de-risking and AML regulation. John Byrne talks to Mark Nance, the Director of the Master of International Studies program at NC State’s School of Public and International Affairs and Eleni Tsingou, a professor in International Political Economy at the Copenhagen Business School.

This week saw virtual currencies be the focus in many venues. John and Elliot discuss statements from the head of the SEC and the fine levied against BitMEX by FinCEN for regulatory violations. They also review the negotiations in the US Senate, during the debate on the Infrastructure Bill, surrounding tax reporting by participants in the virtual currency ecosystem.

John Byrne, Executive Vice President and Vesna McCreery, Managing Director of the AML RightSource staff, sit down and chat about the progression of financial crime compliance over the past 20+ years. They discuss the journey from reputation risk, to transaction monitoring, to comprehensive client due diligence. John and Vesna examine the changes in regulatory focus and expectations and how the financial service industry’s response has evolved over time.