1 min read

The 2019 AML List!


As I have done in previous years, will be looking ahead to 2019 and what may be in store for the AML/CTF/Financial Crime Prevention community. With new committee chairs in the US House and several retirements in the Senate, it is a safe bet that any policy debates in our area will be somewhat different than the last two years. If you add on what is likely to be a financial focus on investigations of this Administration, and in several other countries, money laundering related topics will be front and center.

The following list is both serious and has some tongue-in-cheek points too. As always, please do not use the following for any wagering, and Have a Great and Safe New Year!



GTO renewal for title insurers (Nov) GTO Expansion to variety of real estate providers
CDD implementation Agency examination of CDD compliance
Confusion on AML Innovation Joint agency statement encouraging innovation
Searching for methods to address human trafficking The STAT collaborative platform
UBS, Danske, Deutche Bank fines More fines and penalties on FI’s
Questioning SAR filings by regulators Hope for reason and fairness
Attempts to change BSA thresholds Law enforcement proving BSA data value
2018 FATF Mutual Evaluations 2019 schedule to include Russian Federation and Turkey
Wondering when FFIEC Manual is updated Still wondering
Standing by while de-risking continues Document to be produced by FI’s and NPO’s
Sanctions, sanctions, sanctions More of the same
Learning about virtual currency Regulation and additional guidance about VC
US House hearings on deregulation House hearings on AML gaps and various bank scandals
Discussion on AML reform Action but with inclusion of ALL stakeholders
Reliance on best practices to prevent art/antiquity theft Laws to prosecute criminals/require CDD
Coverage of potential ML in real estate Investigations and prosecutions worldwide
More debate on information sharing Improvement to AML regime to allow more sharing
Debate on extent of culture of compliance Continued improvement of that culture
Examiner second-guessing Improved training and communications by both sides
Private-Public Partnerships Never goes away—too essential!