AML Conversations: Monthly Chat with Sarah Beth Felix

John Byrne is joined by Sarah Beth Felix, author of Dirty Money Weekly, for their monthly conversation on financial crime developments. They start with FinCEN's final rule ending Corporate Transparency Act reporting and what it means in practice: the detection burden for shell companies shifts back to financial institutions, the CDD rule remains in force, and beneficial ownership data belongs in SAR backup documentation to support law enforcement. Sarah Beth shares practical red flags for spotting shell companies, from formation mill documents to companies with no online presence and unexplained revenue.

The conversation then turns to the Wise enforcement action and why a clean exam history is the wrong benchmark for a compliance program, including the OCC's pointed finding that leadership lacked financial crime expertise at the board level. They also discuss the Capital One litigation and the safety risks of demands to identify individual investigators, and close on the operational obstacles AML teams face in responding to the executive order on credit risk and illegal immigration, where citizenship indicators are buried across lending and deposit systems that financial crime teams rarely see.