From Sanctions to Seabeds: Global AML Shifts and Emerging Risks

In this week’s episode of This Week in AML, Elliot Berman and John Byrne cover a fast-moving landscape of regulatory, financial crime, and geopolitical developments across the U.S., EU, and beyond.

They discuss the latest releases of Epstein-related files and the surprising absence of financial‑transaction disclosures, a Wall Street Journal investigation into a major foreign investment tied to AI chip access, and new insights into U.S. corporate tax transparency. The conversation moves through significant DOJ actions, a controversial ICE memo, and key UK updates on crypto-related sanctions, data‑quality failures, and public consultations.

Elliot and John also explore new EU priorities for AMLA, research on illicit antiquities trafficking, a deep-sea mining corruption investigation, and the DOJ’s 2025 Fraud Section Year‑in‑Review. If your work touches financial crime, sanctions, compliance, or emerging‑risk intelligence, this episode is packed with timely developments that matter.

From Sanctions to Seabeds: Global AML Shifts and Emerging Risks - Transcript

Elliot Berman: Hi, John, how are you today?

John Byrne: I'm good, Elliot. Quite a bit of international things to cover, but there's always somethings to talk about in the states and, we'll,, start with that. One thing that we didn't talk about before we started recording, everybody's aware of , last Friday's data dump of more Epstein files.

I'll just say this from our perspective, in terms of our community, the AML community, there have been no releases, as far as I know, of any financial transaction material, which is interesting. The Justice Department has said there'll be no more disclosures. I don't think they're gonna be able to hold to that.

It will be very interesting if they are able to post anything that's financially, related in terms of transactional activity. Just something to think about. I haven't really seen anybody talk about this yet. That to me was interesting regardless of all the other stuff that people have talked about for the past four or five days anyway. Just wanted to mention that something that as AML professionals, we'll certainly look at if that ever does get posted.

Elliot Berman: Seems to violate the standing viewpoint that when you've got a complex crime, you follow the money.

John Byrne: Right. And obviously the movement of illicit funds is something that does occur from trafficking as we know.

The Wall Street Journal, which has actually done some really excellent investigative reporting. They've always had a strong, I think reporting function regardless of what you think about opinion pages and allthat. But the Wall Street Journal's always had some really good reporters, even far back as when I was at the Bankers Association, always respected the goodwork they did.

Over the weekend they reported. That there, prior to the inauguration of Trump, there was a $500 million investment for 49% of WorldLiberty, which, as is run by his sons. That came months before the UAE won access to what the Journal is calling tightly guarded American AI chips.

This is a big deal. So they say four days before the inauguration, lieutenants to an Abu Dhabi Royal, secretly signed a deal withthe Trump family to purchase that 49% stake, in what then was a fledgling cryptocurrency venture for half a billion dollars. The deal, which had not been previously reported was signed by Eric Trump.

At least $31 million was also slated to flow to entities affiliated with the family of Steve Witkoff, a World Liberty co-founder. Who has done some work regarding the Middle East. He's the US Envoy. In any event this is a big deal for a number of reasons.

There was concern during the Biden administration that this AI hardware was fearful that it might get in the hands of China, because of the connection of UAE to China. That's something that people are still watching. So anyway big story. The headline in the Journal is, and I'm quoting Spy Sheikhbought Secret Stake in Trump Company. From January 31st.

So, just tell our folks that pay attention to corruption and bribery and related issues, to take a look at that article. I'm sure there'llbe follow up.

Elliot Berman: Yes. Staying in the US, the FACT Coalition came out with a review of the amount of tax that US companies are paying in the US versus other jurisdictions around the globe. And it turns out that many US based companies longstanding, US based companies have been, uh, paying a lot less tax here than tax in other countries.

In part because over the years, the tax code in the US has been used for all different kinds of purposes beyond just straight revenue raising. But the reason that we now have better numbers is the Financial Accounting Standards Board changed some of their accounting rules that now requires US companies to report, this information more clearly. In the old rules there was no requirement to break it down either in the report or a footnote.

Again, interesting. I guess for me, the big takeaway, 'causeI'm not shocked by numbers, The big takeaway is more transparency is better.

John Byrne: Sticking in the US, the Justice Department announced a Brooklyn banker pleaded guilty to laundering proceeds of Medicare fraud for transnational criminal organizations.

And as we always talk about what are the continued priorities that were established a couple years ago, certainly transnational criminal organizational crime is certainly a priority. So a New York man pleaded guilty to participating in a scheme to launder more than $8 million in healthcare fraud proceeds through a US bank on behalf of a TCO and that according toJustice Department, marks the first time the Healthcare Fraud Unit has chargedand convicted a former bank employee for conspiring to launder healthcare fraud proceeds.

Elliot Berman: This is the first one I think that we've seen with a transnational criminal organization tied to the output of money laundering. So we'll, it wouldn't shock me that there'll be more of them.

John Byrne: Over the weekend there was a guest essay by six former Homeland Security Lawyers. Under the guest essay title, We Were Top Homeland Security Lawyers, You Can't Wish Away the Fourth Amendment. ICE has reportedly issued a memorandum that authorizes its agents to enter private residences forcibly without a judicial warrant.

And then according to the the current general counsel, they defended the policy saying that quote, deep state actors in the federal government had for decades told ICE officers that they may not enter afugitive's, alien's home even with the final order of removal and administrative warrant.

And the article says we disagree. And these lawyers, by the way, served in roles in both Republican and Democratic administrations. In any event, this opinion piece is in the February 2nd edition of the New York Times, and I think it's worth a read.

Elliot Berman: It was well written and quite clear what the authors felt was the errors in the DOJ memo that you referred to.

Couple things from the EU and the UK. So OFSI, which is the Office of Financial Sanctions Implementation in the UK, they have been working with other law enforcement and financial crime prevention groups in a pilotprogram with the Crypto Cash Fusion Cell - CCFC. And the goal here is to share information among various organizations in an effort to cut down on potential breaches of financial sanctions using crypto assets by UK based. And they're making progress.

We've talked about the value of information sharing. Here we've got groups working together in a joint way, sharing intelligence, sharing other information so that they can focus their efforts.

Also in the UK there's been a study which has looked at dataproblems and indicated that that data deficiencies contributed to more than twothirds of UK enforcement cases for AML failures between 2020 and 2025. The datagaps were linked to over £430 million in fines. More importantly, a lot ofoutdated or missing information, which included reliance on outdated PEP listsand investment lists. Failures to identify the ultimate beneficial owners, which is still required in the UK, unlike in the UK. Weak verification ofwealth, source of funds, and discrepancies between customer declarations and public records were four of the big buckets of problems that they identified.

So, data is king, everybody keeps saying. But quality data is the king you wanna be working with.

And then the last thing I have related directly to the UK, FCA is in a public consultation timeframe. Final comments are due by the 12th of March, and this relates to the FCA Handbook for Regulated Crypto Asset activities.

And, uh, if you go out onto their website and type that inyou'll get it. There's a whole series of areas that they're looking for public comment on. This is part of their ongoing effort to upgrade their overall enforcement regime as it relates to crypto assets.

John Byrne: Our friends at the Antiquities Coalition posted the beginning of a number of research outputs from several programs over the past couple years regarding the economic and social context of illicit trafficking archeological goods. The group name is ANCHISE, but it is something that's funded by the EU.

This is an interesting report. The symposium that started theseconversations is designed to do a few things and I'm just reading from the from the particular website that they referenced. But there's more here if this is aspace that you pay attention to or follow.

Artifacts, roots networks, endangered archeological and trafficking of these objects. It documents how to shed light on the traffickingof these cultural goods and summaries of the main actors and recommendations,that sort of thing. So again, if you're in this space, which is obviously avery complicated but important space in AML related topics but the use ofillicit trafficking in the space is something that we've talked about beforeand the Antiquities Coalition has highlighted.

I'm still hoping Elliot, by the way to effort to get folks fromthe AC to sit down and talk about where we stand with everything, both the USand globally. So just a another very interesting adjacency to what we've spentour careers working on, and that is cultural artifacts and their use for illegal activities.

Elliot Berman: Yes. And I know that you mentioned that we just saw this morning that AMLA in the EU has set its, priorities for 26 through 28. You just want to give us the highlights on that.

John Byrne: Right.,So they as you mentioned they put out their priorities. Pretty lengthy seriesof these, but obviously pretty important.

At least for the next two years, what they are recommending isto complete their single rule book, and that puts all the what they hope to harmonize AML rules across the entire EU. Advancing what they're calling supervisory convergence. That's also something that's gonna be interesting towatch.

And then strengthening cooperation among the various financial intelligence units. Some of the subcategories of what I just mentioned are coreregulatory mandates, operationalizing the framework for FIUs, and what they'recalling, building the AML risk frameworks as well.

I know we're gonna follow up in the, in this space with aprogram. Do you wanna talk a bit about that?

Elliot Berman: Our March webinar which is scheduled for March 26th, is gonna be focused on what's happening with the implementation of AMLA. AMLA, the regulatory scheme, as well as the building out of AMLA, the FIU.

And we have several bankers who've agreed to talk about how they and their institutions are beginning to look at, the changes they may need to make to come into compliance with the updated regime as well as the things that they're concerned about. Not because they're bad things, but as with any significant regulatory change there's a long list of things that keep the senior professionals up at night, so we'll be talking about that.

And you can watch for further information and you will be ableto register for that webinar by the end of this month. Continue to watch ourwebsite and any other email that you get from us.

John Byrne: You know, as we mentioned adjacencies, like antiquities also want to mention another areathat doesn't get a lot of direct focus unless you're an expert in this space. The Anti-corruption Data Collective in an investigation just announcedsomething on deep sea mining. The subtitle is A New Frontier for Corporate Opacity and Undue Influence, and it's an interesting piece. They did it inconjunction with Greenpeace it looks like from the description here. And just acouple things related to the report. They say for decades, companies and governments have explored the deep seabed to study various nodules and attempted to develop technologies to extract them.

Critics, however, say that potential environmental damage of mining the deep seabed far outweigh the potential benefits it could cause.Long-term damage to ecosystems and there's a fear of, uh, or at least some identified corruption that goes on in this space. They do mention that we, the US is not a signatory to one of these major projects, and it's not bound by the regulatory process.

And they say in April. President Trump issued an executive order that ordered the US government to accelerate the licensing process in US territories as well as international waters, which they believe is problematic.But anyway, another space in which neither of us will pretend to be experts inbut something to take a look at, if that's a space that you're focused on, which touches on corruption and touches on, illicit funds.

Elliot Berman: Back to the US the Department of Justice Fraud Section issued its year in review, 2025. It's a review of their activities and accomplishments. You can find that in the DOJ website if you're interested. .

So John anything else before we sign off?

John Byrne: No, just as a side issue the Washington Post announced today massive layoffs. Is a paper I've been subscribing to for decades. Their. Virtually getting rid of their sports department, which for me as a sports fan, is really awful. But also other areas. So just from a journalistic standpoint, that's unfortunate.

In terms of content. We were able to do our first interview with Sarah Beth Felix, and that's now available on LinkedIn and on our website.We hope to talk to Sarah every month and get her take. Remember, she is the author of Dirty Money Weekly. And I am efforting some others for the next couple of podcasts. As always, if you have topics or folks you'd like us to talk to please reach out to Elliot or myself.

Elliot Berman: John you have a good rest of the week. I know you're traveling to Milwaukee for along weekend here, so hopefully you and I will get a chance to see each other and in the meantime travel safely.

John Byrne: Sounds good. I'm, I'm going from, 20 degrees to 20 degrees, so I'm not, I'm certainly not trying to go anywhere warm.

Elliot Berman: No. And even if you went a place warm, you'd be going to 35 degrees.

John Byrne: That's right. Take care. Stay safe.

Elliot Berman: Youtoo. Bye-bye.