AML RightSource
In this episode of AML Conversations, John Byrne sits down with Sarah Beth Felix—AML expert and author of Dirty Money Weekly—for a wide-ranging discussion on the most significant AML and financial crime developments shaping the landscape in May 2026.
Drawing on her deep expertise and close reading of recent regulatory activity, Sarah shares her unfiltered take on FinCEN's newly proposed AML program rule—a sprawling 200-plus-page document that she argues raises more questions than it answers, particularly around the undefined concepts of "effectiveness," "reasonably designed," and "risk-based approach." She and John explore what it will actually take to turn those terms into actionable, operational guidance that practitioners can use.
John and Sarah also dig into the proposed FinCEN collaboration requirement on enforcement actions, examining whether the 30-day review window will create meaningful consistency across federal banking agencies—or simply add another bottleneck to an already slow process. The conversation turns to FinCEN's annual report, the persistent misalignment between the SAR form and national AML priorities, and what the removal of the OCC's model validation requirement really means for institutions managing transaction monitoring systems.
As the discussion closes, Sarah offers her top three priorities for BSA modernization ahead of the House Financial Services Committee's May 19th hearing: defining effectiveness in operational terms, codifying a genuine risk assessment process built around threats and vulnerabilities, and overhauling the SAR form to make filings more useful for law enforcement.
This episode is a must-listen for AML, compliance, and risk professionals looking for candid, practitioner-driven insights on where BSA reform stands—and what it will actually take to move the needle. The views expressed in this podcast represent those of the speakers and not AML RightSource.
