Episode Playlist

Treasury Dept Issues Review of 2021 Activities

By AML RightSource | January 21, 2022
This week the US Treasury issued its Year in Review: Treasury’s Top Accomplishments During Year One of the Biden-Harris Administration. The release looks at a broad set of areas for which the Department is responsible. John and Elliot discuss items in the National Security and Protecting the Financial System sections of the release.  

FinCEN Director Outlines Transformations in AML Compliance

By AML RightSource | January 14, 2022
This week FinCEN’s Acting Director, Him Das, delivered remarks at the ABA/ABA Financial Crimes Enforcement Conference. In the speech, he spoke about the shifts in emphasis of Bank Secrecy Act regulations over the past 30-plus years. John and Elliot discuss those shifts and look at the three new areas of focus outlined in Acting Director Das’s remarks: new threats, new innovations, and new partnerships.  

1/6/22 – Where Do We Go From Here?

By AML RightSource | January 7, 2022
This week was the 1st anniversary of the insurrection at the US Capitol. John and Elliot focus their conversation on what the financial crime compliance community can do to identify the monetary footprint of potential domestic terrorist acts. They discuss the recent statements by the President, Vice President, and the Attorney General and urge listeners to report transaction activity that fits the patterns of possible terrorist activity.  

Billions are Hidden in US Real Estate (Archive Edition)

By AML RightSource | December 31, 2021
This episode originally aired on October 15th, 2021.  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    

FATF: Review of Standards on Virtual Assets and Providers (Archive Edition)

By AML RightSource | December 24, 2021
The FATF has issued it’s second 12-month review of its revised standards for virtual assets and virtual asset providers. John Byrne, Executive Vice President and Elliot Berman, Creative Director of the AML RightSource staff, sit down and discuss the key elements of the review and its implications for global compliance in this emerging area.

FinCEN Seeks Comments on the Entire BSA

By AML RightSource | December 17, 2021
This week FinCEN issued an Request for Information and Comment (RFI) on a Review of Bank Secrecy Act Regulations and Guidance. The RFI asks for comments ways to streamline, modernize, and update the AML/CFT regime of the United States. John and Elliot discuss some key questions in the RFI and talk about the importance of making comments on this other regulatory proposals.

FinCEN Issues Several Proposals on Which You should Comment

By AML RightSource | December 10, 2021
This week FinCEN issued an Advance Notice of Proposed Rulemaking (ANPRM) on Anti-Money Laundering Regulations for Real Estate Transactions and a Notice Proposed Rulemaking on Beneficial Ownership Information Reporting Requirements. The ANPRM asks for comments on how to bring US real estate transactions more fully under BSA recordkeeping and reporting requirements. The Proposal on Beneficial Ownership Information asks for comments on a rule requiring reporting by various entities of their beneficial owners. John and Elliot discuss some key points of both issuances and talk about the importance of making comments on these other regulatory proposals.  

Banking Agencies Looking at Impact of Crypto-Assets

By AML RightSource | December 3, 2021
Last week the Federal Reserve, Federal Deposit Insurance Corporation and Office of the Comptroller of the Currency issued a Joint Statement on Crypto-Asset Policy Sprint Initiative and Next Steps. The joint statement highlights the current activity by the agencies to understand the impact of crypto-assets on insured depository institutions and the areas the agencies are reviewing for possible future guidance or regulation. John and Elliot discuss some of the key elements of the report, including the need for a common understanding of what crypto-assets are and how they may impact bank capital.      

Pandora Papers: Global and Local Financial Secrets (Archive Edition)

By AML RightSource | November 26, 2021
This episode previously aired October, 8th 2021. 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.    

IRS-Criminal Investigation 2021 Annual Report

By AML RightSource | November 19, 2021
This week the IRS published the IRS-Criminal Investigation (IRS-CI) Fiscal Year 2021 Annual Report. IRS-CI is the criminal investigative arm of the IRS. The report provides detailed information about enforcement actions and partnerships from IRS-CI. John and Elliot discuss some of the highlights in the report, including the international scope of IRS-CI investigations and the breadth of its activities outside of tax enforcement, including in the cybercrime space.                 

Your Sanctions Program is a Key Compliance Issue

By AML RightSource | November 12, 2021
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 Looks At Cultural Property Crime

By AML RightSource | November 5, 2021
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.                    

Latest FATF Plenary; October 2021

By AML RightSource | October 29, 2021
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.                      

Aiming for Improving Tax Fairness

By AML RightSource | October 22, 2021
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.       

Billions are Hidden in US Real Estate

By AML RightSource | October 15, 2021
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    

Pandora Papers: Global and Local Financial Secrets

By AML RightSource | October 8, 2021
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.    

Suspicious Activity Beyond the SAR

By AML RightSource | October 1, 2021
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.    

Regulation of Antiquities – The ANPRM

By AML RightSource | September 24, 2021
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.      

Basel: Money Laundering and Terrorist Financing Risk

By AML RightSource | September 17, 2021
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.         

Some Thoughts on 9/11

By AML RightSource | September 10, 2021
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.      

FATF: Mutual Evaluation Report – Japan

By AML RightSource | September 3, 2021
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.    

Cybersecurity: A Global Challenge

By AML RightSource | August 27, 2021
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.      

Afghanistan - From Bad to Worse

By AML RightSource | August 20, 2021
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.      

A Busy Week in Virtual Currency

By AML RightSource | August 13, 2021
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.      

New Cuban Sanctions

By AML RightSource | August 6, 2021
This week, Tim White and John Byrne discuss the recently imposed sanctions on Cuban officials by the Biden Administration     

The Risks of Central Bank Digital Currencies

By AML RightSource | July 30, 2021
This week at a hearing of a subcommittee of the House Banking Committee the risks related to central bank digital currencies. John and Elliot discuss some key risks identified in the testimony, including dollar primacy, economic and trade sanctions, and cybersecurity.  

The Nexus of Narcotics Trafficking and Dirty Money

By AML RightSource | July 23, 2021
This week the US Senate Caucus on International Narcotics Control held hearing on the federal response to the drug overdose epidemic. John and Elliot discuss key themes of the hearings, interesting elements of the testimony, and insights into how the traffickers are moving their ill-gotten gains.      

Proposed Interagency Guidance on Third-Party Relationships

By AML RightSource | July 16, 2021
This week US banking regulators asked for comment on proposed interagency guidance on third-party relationships. The proposed guidance will replace existing guidance, some of which dates to 2009. John and Elliot discuss the proposal, what financial service providers should consider as this proposal becomes final, and how the proposal may impact the examination process.

FATF: Review of Standards on Virtual Assets and Providers

By AML RightSource | July 9, 2021
The FATF has issued it’s second 12-month review of its revised standards for virtual assets and virtual asset providers. John Byrne, Executive Vice President and Elliot Berman, Creative Director of the AML RightSource staff, sit down and discuss the key elements of the review and its implications for global compliance in this emerging area.  

The New National Priorities for AML and Terrorist Financing

By AML RightSource | July 2, 2021
This week FinCEN issued the first Anti-Money Laundering and Countering the Financing of Terrorism National Priorities. They identify eight areas of focus for the next four years. John and Elliot discuss the Priorities, what they mean for the focus of enforcement going forward, how they may impact the examination process, and how FIs may consider responding publication of the Priorities.  

Information Sharing - It Really Works!

By AML RightSource | June 25, 2021
This week John and Elliot discuss the recent FinCEN recognition of a number of organizations related to the use of a Bank Secrecy Act, how they are using the data to aid in law enforcement efforts. They go through a handful of the examples listed in the document, and also talk about how friends of the show made FinCEN's list!  

National Strategy for Combatting Domestic Terrorism

By AML RightSource | June 18, 2021
The US Administration is continuing its focus on domestic terrorism. This week it published its National Strategy for Combatting Domestic Terrorism. This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss the key elements of the strategy and what it may mean for Bank Secrecy Act compliance going forward.  

Corruption: A Topic of Global Focus

By AML RightSource | June 11, 2021
The US Administration and the United Nations are focusing on the adverse impact of corruption on the global economy and political stability. This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss these efforts and how both organizations are working to create change and motivate nations around the world to take up actions to reduce this nefarious activity.

Treasury Sanctions on Bulgarian Corruption

By AML RightSource | June 4, 2021
This week, John Byrne is joined by AML RightSource resident Sanctions expert and Special Advisor, Tim White. John and Tim discuss the recent release of the Global Magnitzsky Designations, and a few examples of what's happened recently in Bulgaria relating to the release. From gambling institutions, to professional basketball teams, the designations will undoubtedly affect a substantial amount of assets, now frozen. Link to Global Magnitsky Designations  

Tax Fairness and Shell Companies - the EU Weighs In

By AML RightSource | May 28, 2021
The European Commission has issued a Communication on Business Taxation for the 21st century. The focus of the communication is to “promote a robust, efficient and fair business tax system” in the EU. This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss the communication and its recognition that increasing the fairness in a tax system requires dealing with the problem of shell companies. John and Elliot explore the importance of transparency and the alignment of the EU effort with those of the current US administration.

OCC's Semiannual Risk Perspectives

By AML RightSource | May 21, 2021
The OCC has issued the Spring 2021 edition of its Semiannual Risk Perspectives. This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss the report and its value to the financial crimes compliance community. John and Elliot explore some of the themes in the report and the importance of understanding how FI regulators are looking at various risks going forward.  

National Intelligence Council - Global Trends 2040

By AML RightSource | May 14, 2021
There are many forces influencing global directions and the ability of governments, NGOs, and individuals to respond to crises and political events. This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff talk about the report Global Trends 2040, issued by the National Intelligence Council. John and Elliot explore the themes identified in the report and how they may influence global events over the coming decades.  

The Growing Connection Between Domestic and International Terrorism

By AML RightSource | May 7, 2021
Domestic and international terrorism are growing challenges. This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff talk about an announcement by the US Department of Justice of the second guilty plea by a member of the "Boogaloo Bois" to conspiracy to provide material support to Hamas. John and Elliot explore the growing connection between these two global problems.  

UK Issues Sanctions Under Anti-Corruption Regime

By AML RightSource | April 30, 2021
Corruption is a continuing global problem. This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff talk about the new UK Anti-Corruption Regime. John and Elliot explore the sanctions issued by the UK and the importance of a world-wide coordinated effort to combat corruption.

Continued Vigilance on Domestic Terrorism

By AML RightSource | April 23, 2021
Domestic Terrorism is a constant issue that effects all of us. Join John and Elliot this week, as they discuss the current landscape of combating terrorism, with a specific focus on the financial elements, and how each of us in the community can be a part of the solution to this critical issue.    

InfraGard – 25 Years of Partnership

By AML RightSource | April 16, 2021
This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff talk about InfraGard, a 25-year-old partnership between the FBI and the private sector to help identify cyber threats. John and Elliot explore the value of public-private partnerships and how InfraGard has expanded from cybercrime to include terrorism, intelligence, and other matters.    

Busy, Busy, Busy…

By AML RightSource | April 9, 2021
This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff talk about the recent change in FinCEN leadership, the FinCEN ANPRM on the beneficial ownership registry, newly issued sanctions on human traffickers in Pakistan, and an evolving public-private partnership in northern Virginia. It has been a busy week in the financial crimes compliance space, tune in to hear all about it.  

North Korean "Businessperson" Extradited for Money Laundering

By AML RightSource | April 2, 2021
This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff talk about the announcement by Department of Justice that it has completed the extradition of a national of the Democratic People’s Republic of Korea (DPRK). The indictment alleges that the individual and others conspired to covertly and fraudulently access the U.S. financial system and to have defrauded U.S. banks and violated both U.S. and U.N. sanctions as part of the money laundering activities in transactions valued at over $1.5M. John and Elliot discuss the importance of FIs remaining vigilant in their understanding with whom they are transacting business.  

Do You Know How to Serve Complex Clients?

By AML RightSource | March 26, 2021
This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff talk about the NCUA’s recent Cease and Desist Order to Live Life Federal Credit Union. John and Elliot discuss the complexities of providing services to marijuana-related businesses and dealing in virtual currency; and the lessons that all FIs can glean from the Order.    

What is Fair Access to Banking?

By AML RightSource | March 19, 2021
This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff talk about the recently proposed Fair Access to Banking Act. John and Elliot discuss the mandates in the Act, the challenges it presents to risk-based compliance programs, and the types of entities that are not included in the coverage of the proposed legislation.     

FinCEN Reminds FIs About Trade in Antiquities and Art

By AML RightSource | March 12, 2021
This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff talk about the notice from FinCEN about its efforts around trade in antiquities and art. John and Elliot discuss the activities that FinCEN is undertaking in this area, some of the resources which are included in the notice, and FinCEN’s guidance about the elements of an effective SAR narrative about antiquities and art.    

Should FinCEN's Standing in the National Security Apparatus be Enhanced?

By AML RightSource | March 5, 2021
This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff talk about the policy paper on improving FinCEN’s role in national security, issued by Global Financial Integrity. John and Elliot discuss the views expressed in the paper and some of GFI’s recommendations to enhance FinCEN to meet the growing national security threat posed by money laundering.    

Will There Be a Domestic Terrorism Statute?

By AML RightSource | February 26, 2021
This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff talk about hearings being held in the House of Representatives about various proposals to make domestic terrorism a federal crime. John and Elliot discuss the views expressed by several witnesses at the hearings and what the financial crimes compliance community can do now to help detect and report potential domestic terrorist activity.    

Why There Should Be a 1/6 Commission

By AML RightSource | February 19, 2021
This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff talk about the likely creation of a Congressional Commission to investigate the actions of January 6th. John and Elliot discuss what information useful to the financial crimes compliance community may come from such a commission’s activities and why a clear understanding of the roots and long range impacts of the events will be valuable to the community and the nation.  

Some Things to Watch in the Anti-Money Laundering Act

By AML RightSource | February 12, 2021
This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff talk about some provisions of the Anti-Money Laundering Act of 2020. John and Elliot discuss a recent posting by the International Consortium of Investigative Journalists which identifies some of the possible shortcomings in the Act and how these provisions may be come to be during the legislative process.