In this week’s episode of This Week in AML, Elliot and John unpack a wide-ranging set of global developments impacting financial crime compliance. They preview key agenda items from the FATF Plenary in Mexico City, including new mutual evaluations and technology-focused initiatives. The conversation also examines Transparency International’s 2025 Corruption Perceptions Index, highlighting troubling downward trends among high-scoring democracies, including the U.S.
Elliot and John also explore the EU’s proposed sanctions package targeting Russian crypto activity, the FTC’s latest ransomware oversight report, new OFAC actions related to Hezbollah, recent enforcement in the crypto fraud space, and ongoing gaps in U.S. regulation of the antiquities market. Additional topics include global efforts to combat illicit gold trafficking, Jersey’s move toward comprehensive modern slavery legislation, and seasonal warnings about romance‑investment scams.
FATF Plenary, CPI Findings, and AMLA’s Next Steps - Transcript
Elliot Berman: Hi John. How are you today?
John Byrne: Good, Elliot. It was nice connecting with you and Karen past couple days when we were in Milwaukee. Got back here to Northern Virginia and the snow is still here and ice is still covering it even though it's in the forties. So same weather that you guys have had?
Elliot Berman: Yeah. I think we had less snow to dissipate and it's not gone, but the piles are coming down.
John Byrne: This week is the FATF plenary. It's the fifth plenary under the, Mexican presidency of Elisa de Anda Madraz and it is actually taking place in Mexico City. So by Friday of this week when we post this, there'll be a virtual press conference from the president about the outcomes of the meeting. And I know they have a couple things on the agenda. What did you see there?
Elliot Berman: They're going to, review the mutual evaluation reports from Austria, Italy, and Singapore.
And they're also working on how to harness technological innovation to combat crime. And they're going to, take another look, as they do at every plenary, at the countries or jurisdictions that are under increased monitoring. The ones on the grey list.
And there's usually, as you've pointed out when we've talked about FATF in the past, usually other initiatives that are announced, that then cascade out over the months between the plenaries.
John Byrne: A reminder that the evaluation group that's looking at the US will actually be in the US in person, roughly about March 6th, I think is when those in-person meetings are going on.
And I would just mention as an aside, I'm working with acoalition that's dealing with some of the challenges that NPOs are having regarding de-risking and other similar issues. They filed a paper with the evaluators late December, and they are working on additional advocacy regarding some of the struggles that, again, humanitarian and charity groups are having under the umbrella of, uh, financial institutions and governments looking at terrorist financing and other issues.
So we'll have more on that as, as the months go by.
Elliot Berman: We saw a release this morning that the EU is in the process of working on a new sanctions package against Russia, related to the war in Ukraine. It would prevent EU firms and individuals from dealing with any crypto asset service provider based in Russia, which would be , a meaningful step forward in terms of clamping down on sanctions evasion.
John Byrne: The, organization, Transparency International, who we have mentioned quite a bit throughout our time of doing this, they've issued the Corruption Perceptions Index for 2025. And in the intro they've mentioned that they've analyzed 182 countries. And as we know, it's to assess their fight against corruption.
TI says the following though, the results are alarming. Andover a decade, most countries have made little to no progress in tackling public sector corruption. And they go on to say that the global order faces strain from major power rivalry, armed conflicts, and the climate crisis.
The index is available on their website. Just looking here atthe top five countries that have high rankings meaning that they are positive in terms of anti-corruption. It's Denmark, Finland, Singapore, New Zealand, and Norway. Obviously there's a lot in this. What were some of the things in the index that jumped out at you?
Elliot Berman: The US ticked down one point. Our rating now is 64, and we're 29th on the list. We've continued to drift down over the last number of years. They noted that there'sonly five countries now that score above 80, which happened to be the five that you mentioned.
And a decade ago there were 12. They're seriously concerned about the slippage in high scoring democracies as an indicator that corruption risk can rise even where institutions once looked secure. You and I have talked about things in the US, about Foreign Corrupt Practices Act backpedaling, and we've certainly reported on corruption activity around the globe.
But it's a serious issue, and I think this report is valuable every year because it encapsulates a broad, view of what's going on that otherwise you have to look at a lot of different sources. I suggest that folks take a look at it and think about how their programs are tuned to identify potential corrupt activity.
John Byrne: One more thing I'll mention, and again, there's quite a bit in the index, but they have,uh, indicated that there's increased restrictions on civic space. Quoting here,by making it hard or dangerous for citizens, NGOs, and journalists to challenge abuses of power, they're reducing transparency and accountability this allows corruption to flourish. Something that I think we have seen here as well as in other jurisdictions.
Elliot Berman: Agreed. Coming to the US for a moment. The Federal Trade Commission has an obligation under the RANSONWARE Act, which like so many is an acronym. It's the Reporting Attacks from Nations Selected for Oversight and Monitoring Web Attacks and Ransomware from Enemies Act. They worked really hard to get it to mean RANSONWARE Act. Those identified countries are China, Russia, North Korea,and Iran. The FTC has brought more than 90 enforcement actions with favorable outcomes.
This is the FTC looking at companies in the US who are not meeting the obligations under the Act. These reports are required every two years. This new report issued now covers 2025. Worth a look. The Act looks at US companies. But it's interesting because, we've also seen a degradation in the staffing and mission of CISA, which is the Federal Government's Bureau that is responsible for not only keeping the government, but keeping the country safe. It's a little hard sometimes to get these things to match up.
John Byrne: OFAC this week took action dealing with Hezbollah. According to the press statement, they took action to disrupt two key mechanisms that Hezbollah uses to sustain its economic stability, revenue generation, and coordination with the Iranian regime. And the exploitation of Lebanon's informal financial sector.
So there's information on that OFAC announcement on both the Treasury website and the OFAC website as well.
Elliot Berman: The Antiquities Coalition announced that the United States and Bahrain had renewed commitments to strengthen cultural heritage cooperation. So in 2021, the two countries entered into letters of commitment and this this renewal builds onthe work from the 2021 commitments. The new statement, according to the press release, reflects a strengthened bilateral focus on enhancing the exchange of information to prevent illicit trafficking of cultural property, sharing best practices, supporting networks dedicated to combating the illegal trade in art and antiquities, and promoting responsible art market standards and advancing cultural exchange.
I think that's a good sign. You and I have talked about the various efforts in this space for a long time, and I know you've done some work with the Antiquities Coalition. Again, calling out a little bit of the inconsistency, it is interesting that we have not been able to get the creation of a regulatory obligation for art dealers in the US to be covered by the Bank Secrecy Act. Which would be another way to help that.
John Byrne: Yeah. And let's hope that eventually does occur in some fashion. Back in the US the IRS, has announced that the CEO of the digital asset company, Safe Moon, has been sentenced to a hundred months in prison for his role in a multi million dollar crypto fraud scheme.
The individual Braden Carny, was sentenced following a trial conviction for conspiracy to commit securities fraud, wire fraud, and money laundering in connection with a scheme to defraud. Investors. And so that sentencing followed investigation by IRS-CI, the FBI, and HSI out of New York.
Elliot Berman: AMLA, has issued three consultations. One is on AML penalties, one is on AML due diligence, and one is on business relationships.
If you go to the AMLA website, you'll be able to standards drafts. The one on penalties, the comments are due the 9th of March. And thenthe one on due diligence and the one on business relationships, those comments are both due the 8th of May. So essentially a 30 day and a 60 day comment period. For those of our listeners who are governed in any way or will begoverned in any way by the Amela regulations, this is an opportunity for you to comment as the regulations evolve.
Some of this work has was already in flight from prior organizations whose responsibilities are now being moved over to AMLA. But as we have done always when there are regulatory opportunities to comment on proposals, the comments are taken seriously by the regulators and this is a great opportunity for those of you who will be impacted by these to review the mand make any comments that you feel are valuable.
John Byrne: The FACT Coalition has posted a report that looks at new data from an organization called the World Customs Organization. And this focuses on illicit gold. According to the posting that in the most recent year period, I think the report actually looks at 2024. Custom agencies worldwide seized over 19 metrictons of dirty gold, primarily at airports and in large part hidden within traveler's hand luggage. This represents, according to Fact Coalition, about $3billion in illicit wealth. And the FACT Coalition has stressed that they're pushing governments to address what they call loopholes in the AML/CTF regimes around dirty gold.
So an interesting report coming out from the World Customs Organization. It's called the illicit Trade Report, 2024.
Elliot Berman: The government of Jersey, not New Jersey, but Jersey has announced that it intends to bring forward dedicated modern slavery legislation to strengthen protections for workers.
In its release the government said the proposed reforms would focus on preventing exploitations, improving support and protection for victims, and ensuring the authorities had clear power, safeguards and accountability to tackle modern slavery effectively. I think this is worth mentioning because when we've talked about the challenges of human slavery, it's borderless and therefore having a strong regime in every country is really important. And even if it's a small country like Jersey it's good to see that the trend is in the right direction.
John Byrne: As we record this, obviously over the weekend is Valentine's Day. The Commodities Future Trading Commission announced that they're leading an international awareness effort, to continue to warn the public about relationship investment scams.
A whole host of organizations are with the CFTC at the federal level. IRS-CI, the FDIC Office of Inspector General, all sorts of agencies. And there's many state agencies, and there's certainly some non-governmental organizations like FINRA and others. They remind people that warning signs of relation investment scams include an online friend or love interest who quoteis unable to meet in person, moves the conversation off social or dating platforms to encrypted messaging, claims to be or know an expert crypto trader, I think that's pretty important. And offers to help the victim trade or invest money.
So there's information on the CFTC website and a number of other federal government and state government websites about the continuing challenge of relationship fraud.
Elliot Berman: John, I wanted to mention some things that AML RightSource is doing over the next four or five weeks. We're gonna have a presence at a number of conferences, both in the US and in Europe. And so if you're at any of these please stop in and, meet our colleagues and strike up a conversation to see if there's something we do that can be helpful to you.
If you're gonna be at IIB March 8th in Washington, DC, we will have a booth in the exhibit hall, and that'd be a good spot to stop. If you'regonna be at 1IoD on March 11th in New York City we'll have two of our senior folks leading a VIP roundtable discussion with practitioners on innovation in financial crime compliance.
And if you're at FRC. Leaders Convention which is in Frankfurt, next week on the 19th. Mark Sully will be moderating a panel on Budgeting for Impact how to impress regulators without breaking the bank. And several of other folks will be dealing with other factors. So important to see us inperson since all you get to do with John and me is hear us.
Also, you can still register for our webinar this month, which is on SARs. And it will live stream at 1:00 PM Eastern Time on February 26th. John, anything else?
John Byrne: Yeah, I want to remind people that March 19th and 20th here in Washington DC we will have the fourth annual AML Partnership Forum that we've talked about.
This is an excellent opportunity to network, with partners in the private and public sector. We have an amazing agenda that we've put together that's gonna cover a whole host of topics. And we're gonna be recognizing some very dedicated public servants during the that two day conference at the Mayflower.
You can go check out the information. It's out on LinkedIn. March eight, 19th and 20th at the Mayflower Hotel in Washington DC. Registration is open. And as I've said many times, you cannot prevent financial crime without active partnership. And that's what this is designed to accomplish.
Elliot Berman: Another thing to watch for is over the next several weeks, we'll be doing a podcast with Alan Ketley about the big picture around AMLA to get people to think about it who haven't maybe focused on it. So watch for that to post to our website over the next couple weeks. John, anything else?
John Byrne: Once again, we'll be sitting down with Sarah Beth Felix, in the next couple of weeks for our February conversation. And I am attempting to effort additional folks for our AML Conversations. So if you have somebody that you'd like us to talk to or a topic or theme, please reach out to Elliot or myself.
Elliot Berman: John, you have a great rest of the week and hopefully you'll get to watch the snowrecede in Northern Virginia.
John Byrne: Takecare. Stay safe.
Elliot Berman: Youtoo. Bye-bye.