In this episode of This Week In AML, Joe McNamara fills in for Elliot Berman and joins John Byrne for a packed week of AML news on both sides of the Atlantic. The conversation opens with the fallout from Treasury and FinCEN's final rule eliminating domestic beneficial ownership reporting under the Corporate Transparency Act, then moves to Transparency International's guidance for EU member states that have not yet published a national anti-corruption strategy. Ireland, one of the six late adopters named in that report, has now released its first national AML/CFT/CPF strategy, and John walks through its five strategic goals and three pillars ahead of AMLA supervision and FATF evaluation.
The hosts also cover the UN Security Council's 38th Monitoring Team report on ISIL, AMLA's warning that money laundering in the EU property sector could deepen the housing crisis, and the OCC's conditional approval of a national trust bank charter for World Liberty Trust Company, along with the sharp objections raised by Senator Elizabeth Warren and others over conflicts of interest. Stateside, they close on Treasury: an unreleased internal report on the risks of an AI bubble, and the department's public request for comment on GENIUS Act implementation. John rounds out the episode with a $165 million crypto Ponzi indictment reported by OCCRP.
Links Referenced
Transparency International, Good Practices for National Anti-Corruption Strategies in EU Member States: https://knowledgehub.transparency.org/helpdesk/good-practices-for-national-anti-corruption-strategie...
Ireland Department of Finance, Ireland's First National Anti-Money Laundering Strategy: https://www.gov.ie/en/department-of-finance/press-releases/t%C3%A1naiste-and-minister-for-finance-si...
UN Security Council, 38th Report of the Analytical Support and Sanctions Monitoring Team (S/2026/651): https://docs.un.org/en/S/2026/651
AML Intelligence, AMLA Urges Crackdown on Money Laundering in EU Property Sector: https://www.amlintelligence.com/2026/08/news-amla-urges-crackdown-on-money-laundering-in-eu-property...
OCC, Conditional Approval for World Liberty Trust Company (CD 1385): https://www.occ.gov/topics/charters-and-licensing/interpretations-and-decisions/2026/cd1385.pdf
NOTUS, Treasury Internal Report Warns of the Dangers of an AI Bubble: https://www.notus.org/economy/treasury-internal-report-warning-dangers-ai-bubble?utm_source=content_...
U.S. Treasury, Request for Public Comment on GENIUS Act Implementation: https://home.treasury.gov/news/press-releases/sb0605
Corporate Transparency Rollback, Ireland's First AML Strategy, and Trump's Bank Charter - Transcript
Joe McNamara: Hey, John, how are you this week?
John Byrne: I'm good. Joe, thanks for filling in, as you do several times a year for Elliot and me. Elliot is on a well-deserved vacation. He's out this week, but thanks for sitting in for him. I appreciate it.
Joe McNamara: I'm so excited to be here. I feel like I tell you guys this every time, but I'm a big fan. I hope you both take more vacations so I get more chances to be involved in these conversations. Happy to be here, John.
John Byrne: That sounds good. There is a bunch of stuff happening, both domestically and internationally, but there are a few more international things I think we want to highlight this week. One is an organization we talk about quite a bit, Transparency International. Great organization.
As a quick aside, last week when Elliot and I were in the middle of recording, that was exactly when Treasury and FinCEN issued their final rule on the Corporate Transparency Act, eliminating the requirement for domestic entities to file beneficial ownership information with FinCEN. They did that, and they also said they are emptying the database. So all the filings that had previously been captured, and that were eventually going to be utilized by law enforcement and potentially financial institutions, no longer exist.
I raise that because Transparency International has been pretty vocal about the downside, especially when law enforcement talks so frequently about the need to determine whether shell companies are fronts for illicit activity. I've also seen a number of blog pieces and podcasts that mention this. In fact, several national news programs that don't always cover these types of issues have had at least segments on the fact that this database has been emptied and there is no longer any requirement, except if you're a foreign entity.
And I'll end on this point. We did our look back with Sarah Beth Felix, which will have been posted by the time you hear this conversation. Sarah Beth talks at length about the elimination of that requirement, plus the fact that foreign entities can easily circumvent the requirements and become a domestic entity. She also covers that in her Dirty Money Weekly. So there is a lot on that topic. We only briefly touched on it last week because it had just come out, so I wanted to mention it.
That is a long-winded way of starting my comment about Transparency International. They posted a report. The report is from April, but they posted it just the other day. It falls under the category of what they call a Helpdesk Answer document, and it is their direction to members of the European Union as they put together their anti-corruption strategies. The analysis in the report gives direction on what TI thinks is a good starting point and how to create those strategies. It's available on the TI website, and also if you follow them on LinkedIn.
Joe McNamara: That's right. The one thing I would call out specifically is that, with the EU's anti-corruption directive, it's the first time member states are legally obliged to both adopt and publish a national anti-corruption strategy.
The interesting thing, and it makes for a really great segue, is that up until they published this, there were still six states that had not done that. Those are listed in the report: Belgium, Denmark, Germany, Luxembourg, the Netherlands, and Ireland. So this comes from a legal obligation, and the directive further requires the national anti-corruption strategies to specify the objectives, priorities, and measurements associated with whatever their position is going to be.
I say segue because Ireland was on that list of states that had not acted, and interestingly enough, we've seen some things come through in the last few months regarding Ireland. I think what we most recently reported on was the risk assessment, but we saw something else this week around their AML strategy. John, what did you think about that?
John Byrne: Right. So Ireland issued its national AML/CFT and counter-proliferation financing strategy. In addition to risk assessment as a strategic goal, Ireland has four other goals: national coordination, which certainly makes sense across the country and all the different agencies; the strategy on their regulatory framework; capacity building and outreach, meaning how do you message all this; and then international cooperation.
Ireland posted their strategy because, as you say, they're among the countries getting ready for AMLA to oversee this, and also for mutual evaluations by the Financial Action Task Force. All of that plays into this. In terms of the strategy, and we've said this about the U.S. strategy as well, the evaluations from FATF are not just about whether there is a strategy. Is it enforceable? What are some of the metrics on activity by financial institutions and law enforcement? All those sorts of things.
The document is 30-plus pages. They talk about the framework having three pillars, if you will: policy and oversight; safeguarding and monitoring; and investigation and enforcement. So Ireland launched their strategy in response to the things Joe highlighted, and you should get a chance to take a look at it. It's available on the Irish government website, and others have posted the document on LinkedIn as well.
Joe McNamara: Yeah, like you said, John, a 30-page report. And going from a 30-page report to the 38th report, today is just full of updates on reports. In terms of the UN and the Security Council, they just published their 38th report from the Analytical Support and Sanctions Monitoring Team, focused mostly on ISIL, the Islamic State in Iraq and the Levant.
John Byrne: Yeah, it covers the first half of 2026, and they talk about some of the key takeaways. This was posted by a UN expert who kindly read through the document and summarized it. Some of the key takeaways: kidnapping for ransom remains a top revenue stream, especially in the Sahel, with proceeds moving across affiliates alongside the growing use of virtual assets. Beneficial ownership comes back again. Some affiliates increasingly lean on tribal sympathizers and unwitting third parties to front real estate, vehicle sales, and local businesses. And then sanctions, where there are a few movements on that list.
For anybody who's involved in security and CFT, as you said, this is another 30-page document from the UN Security Council, and it's available on their website as well.
Joe McNamara: Bingo. Now, from 30 pages to what I would argue is probably a minute-and-a-half read, if you read slowly as I do. There was some news out of AMLA regarding a crackdown on money laundering in the EU property sector. This is not the first time we've heard this organization call for order, if you will, or call for heightened enforcement. But in terms of what we're seeing, what jumped out to you in this area?
John Byrne: I want to give credit to the folks at AML Intelligence, who do a great job with their programming and also their newsletters and information. Their chair, Stephen Rae, posted this, and this is his analysis of the report you mentioned, Joe. AMLA believes that money laundering in the property sector could even worsen the housing crisis in Europe's major cities. That's a byproduct we don't talk about that much: when you have real estate fraud, it does impact the ability of regular folks to get access to housing.
One of the items in the report, and this is a quote: "Distortions in the real estate sector in the form of increased prices are particularly harmful for our economies and societies." End quote. A full analysis is now available from AML Intelligence on their home page, but you can also read the report directly. Again, I wanted to give credit to them for highlighting this. They also say that criminal organizations rarely pay for property entirely in cash because that could raise suspicions. Instead, they use standard financing methods, which I didn't realize, such as mortgages, or reserving cash for down payments, that sort of thing. So again, a report worthy of a look.
This is a side issue, but I'll connect it. It has been 25 years since 9/11 and 24-plus since the Patriot Act. One of the things we pushed for very strongly in the Patriot Act was coverage of the real estate industry. Twenty-four years later, that still hasn't happened in the U.S. to any degree that would make sense, and the things highlighted here are still a problem decades later.
Joe McNamara: No doubt. And I know you've got some cool plans ahead on that front, especially with Dennis Lormel, so I'm looking forward to seeing that conversation, hopefully later this month and certainly before the 25th anniversary.
Coming back stateside, we've seen a couple of things of note. I think the biggest was that last week the OCC reviewed the application from World Liberty Trust Company, which was essentially filing for a charter. There are a lot of opinions floating around on this particular topic. What jumped out to me, from a kudos perspective, if there is one to give, is the process itself. In terms of how they filed, they followed the rules. They went through the process. They were very transparent about what they were applying for, and therefore were granted conditional approval. But I know there have been some reservations voiced pretty strongly by members of the House and others. John, in terms of what you're seeing, is there anything in particular we should keep our eyes on here?
John Byrne: What was interesting is that it was posted on a Friday night, and usually that's a news dump day, let's face it, although I don't think that's relevant anymore because news cycles are 24/7. That's probably an old-fashioned way of looking at news at the end of the week. But when it was posted, as you just mentioned, at least according to some former OCC officials, the process was both transparent and seemingly consistent with other approvals.
Several policymakers, though, have suggested there is a very large potential for conflicts of interest, meaning that World Liberty is obviously run by the Trump Organization, and Trump is the president, and he decides who's going to be in these various agencies. This is not something we've ever had to consider before: that the regulators of an entity owned in part by the President of the United States are going to be managed in that particular fashion. I'm sure many will watch this very carefully. A number of supporters of digital asset growth have talked positively about this, both on LinkedIn and in other places. So it's worth watching, but I will tell you that Senator Elizabeth Warren and several others have expressed major concerns about the potential here.
We'll see. It's out there now, so everybody is well aware of what's happened. And this is our world, because part of what they agreed to is AML processes. So it's going to be continued watching by our community, no doubt.
Joe McNamara: No doubt. And to further balance the conversation, if I'm looking for a silver lining in all of this: when we look back at the last four or five years, the volume of charter applications had significantly dropped off, and we're starting to see that come back. Every example is very nuanced and has its own particularities that are going to make or break the decision. But as a whole, I think it's exciting to see that maybe we're starting to get back to a bit of a growth stage here.
John Byrne: Just real quick, the letter from Warren and others is available on the Banking Committee website. This is the pull-out quote from Warren: "President Trump is now the first president in history to approve, operate, and supervise his own bank. This is the most brazen act of self-dealing our financial system has ever seen, and Congress cannot allow it to stand." Now again, these are letters from the opposite political party, so you take that with a grain of salt. But it's going to be an interesting thing to follow. That information and the signers of the letter are available on the Banking Committee website.
Joe McNamara: No doubt, and the two words that come to mind almost immediately are due diligence. At the very least, I hope there is ongoing conversation.
Switching gears a little bit. Treasury has also been busy as it relates to AI. I saw a report that surfaced about a Treasury internal report warning about the dangers of an AI bubble. Depending on how many days you go without connecting to the internet or checking your phone, it's pretty likely you're getting something from AI or interacting with AI almost daily. It was interesting because, in terms of the formal positioning and messaging we've seen, whether out of the administration or more generally, we don't see much dissent about the potential for harm, similar in nature to the dot-com bubble at the beginning of the 2000s.
I would make a point to call out that the aspects of the dot-com bubble don't necessarily apply in the same ways to AI. However, I think it's prudent for anybody looking at the growth cycle of this new technology to take into consideration that things ebb and flow a bit. For the most part, AI seems to have just flowed. There has not been much ebbing. What I take from this is twofold. First, continue to use good judgment when it comes to those who are heavily leveraged in this space. More importantly, take it for what it is, which in my opinion is a tool. We're finding new and better ways to apply more of the tool's capabilities to a lot of what we do in our day-to-day professional and personal lives, and I think it is providing a lot of good. However, it's worth noting that simply relying on it for the sake of reliance is shortsighted and, quite frankly, a very dangerous position to be in as it relates to AI.
John Byrne: So this report, which has not been publicly released, we discovered through a platform called NOTUS, News of the United States. It's a fairly recent newsletter operation. They reviewed this draft report, which was not released and was designed to give direction to Secretary Bessent. According to the story, they went back to Treasury, and the spokesperson for Treasury said something Joe just mentioned too: that AI has the potential to deliver unprecedented productivity, expand economic opportunity, and empower American workers.
The report said, though, that an AI bubble popping, if it happens, would lead to less of an immediate crash than the dot-com bust Joe referenced. But the analysts predicted companies would cut back, investors would lose confidence, and the economy would grow more slowly should the industry falter. They went on to say that stock markets, private credit markets, companies financing data center buildout, cloud providers, chip manufacturers, and utilities would all feel the effect, according to the report. Now, this report has not been reported anywhere other than the publication I mentioned, so my educated guess is it will not be released. But obviously it was shared with a particular reporter at that organization.
Long-winded way of saying we're all trying to grapple with what AI means for the AML community. I teach a class, and I always wonder if my students are using AI to produce final papers. I make them at least tell me that they've used it for grammar and punctuation and that sort of thing. But it's so far ahead now that it would be really hard to figure out whether they're actually using it for content. So we're all trying to figure that out.
A lot of politicians on both sides of the aisle are pushing back on data centers. I live in Northern Virginia, and Loudoun County, the next county over, has the largest concentration of data centers in the country. It's going to be fascinating, and they say it's in part because of all the artificial intelligence we use. Joe knows this space better than I do. This is going to be something we have to continue to watch, and I'm not sure how far ahead we're going to get. It's going to be a reactive issue, in my opinion. So I don't know, Joe, your thoughts on that?
Joe McNamara: Yeah, I wholeheartedly agree with you, John. My only offhand comment would be: send it to space. That's the pipe dream, but really the only solution, in my opinion, worth pursuing in any real measure right now.
I know the running theme here has been that we're deep into what Treasury has been up to in the past week or so, but there was one more thing that came out, I believe on Friday, and that was its call for public comment around the GENIUS Act. I'm pulling from the press release from the 17th, where the Treasury Secretary said, quote, "Treasury welcomes input from stakeholders as we work to provide the regulatory certainty businesses need to innovate and grow in America, cement the role of the U.S. dollar as the world's reserve currency, and keep America the crypto capital of the world."
To me it sounds like, and I feel like we're feeling this, not only do we want to be the AI masters of the world, but we're also trying to stay the crypto capital of the world. I'm assuming you saw this. Any thoughts on what we should expect to see? And certainly for folks who feel strongly enough to provide comment, which I would recommend, I think it's worth the effort. From your perspective, John, what would you say?
John Byrne: I'm not sure. They say the expected effective date of the act is January 2027, which is not that far away now, so it's going to be fascinating. There are still a lot of political issues to grapple with in the whole stablecoin area. I read one review that said there are at least 50 questions Treasury is asking for comment on. I don't write comment letters anymore. I spent a lot of my career doing that sort of thing, and it was always a struggle to make sure you could get as many questions responded to as possible. At that point, I was running the Bankers Association comment process. You would hope that people on all sides would comment on operational and legal questions and that sort of thing. So it's another thing we should be watching, and obviously once it's final, AML RightSource will do content on it, whether that's a webinar or a couple of conversations with experts, so that our clients get the best information possible.
Joe McNamara: Great point, and I agree. The tongue-in-cheek comment would be that maybe we should use AI to help answer all those questions, but don't actually do that. To your point about programming, this month's webinar is on the risks of virtual assets. While it's not specific to crypto, Elliot has put together a great panel on the 27th at 1 p.m. Eastern, where they're going to dive into the specifics around some of the risks associated with virtual assets, both from an exposure standpoint and for practitioners and organizations that are effectively offering these types of things as a mechanism for transfer of value. I highly encourage folks to attend.
Shameless plug aside, I've reached the end of my list. Is there anything else you had today, John?
John Byrne: Well, as we always do with these conversations, things pop up, and something just popped up on my feed from OCCRP. It's relevant to what we just talked about. Federal prosecutors in Georgia have unsealed a 25-count indictment against an American man accused of orchestrating a $165 million cryptocurrency Ponzi scheme that defrauded thousands of investors, just days after authorities in Fiji apprehended him and handed him over to federal agents. This particular individual, Edward Zimbardo, was the subject of an international manhunt. He promised up to 25% monthly returns from high-yield investment platforms before he fled to the South Pacific as federal regulators closed in. That's available on the OCCRP website, and it's free. They look for donations because they are investigative journalists, but it's free.
So no, I don't have anything else. Related to that, an investigative journalist and I are going to speak on Friday for a sit-down podcast where he's going to talk about some defense contracting fraud. We'll have that conversation and post it a week or so after. So that's coming up, and my conversation with Sarah Beth Felix will be available by the time you hear Joe's and my conversation.
Joe McNamara: Absolutely, John. Well, another great week of Around the Horn. Obviously the news never sleeps. I really appreciate you having me back on. Just as a plug, all the material we covered today will be available in this episode's summary, so anybody looking for that information can find it in the summary description of this episode. And I highly encourage you to check out the additional value in the information you can find on the AML RightSource website. Again, John, I really appreciate you having me on today. Stay safe.
John Byrne: Take care of yourself. Talk to you soon.
Joe McNamara: Bye-bye