This Week in AML
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.
National Strategy for Combatting Domestic Terrorism TRANSCRIPT
Elliot Berman: Hi, John, how are you this week?
John Byrne: Hi, Elliot. How's it going?
Elliot Berman: Oh, it's going okay. This week I saw that the White House announced the national strategy for countering domestic terrorism. Did you get a chance to take a look at that?
John Byrne: Yeah, they make the point in their fact sheet that the President did this in his first full day of office. So it was a hundred day plus review. And this is the result of that. So it's definitely consistent with what we've talked about in some of the previous This Week AML sessions that we have. But yeah, I did see that there's a number of things in there that I think just point to our community that how much more priority and focus should be placed on domestic terrorism to the extent that we can see activity and transactional movements that could be indicative of that.
Elliot Berman: Yeah. I agree with that - the strategy basically as four pillars as they talk about one is information sharing, another, focused on interdicting recruiting, the third one is working to deter activity before it turns violent, and the last is more of a long range - and that's addressing the contributing causes so that for the longterm we actually change the playing field to reduce the likelihood.
John Byrne: Yeah. Yeah. And I think the key that we understand very well in our world is to enhance information sharing among government agencies, that becomes so important to both understand and share that information. So that's something we've been asking for and we do get for the most part from our counterparts in law enforcement, but it's good to see that's a key component of the strategy as well.
Elliot Berman: Yeah. Agreed. As part of the information sharing pillar there is a fair amount of discussion in one of the sub-parts of that strategy, that part of the strategy that does talk about information sharing related to, within the context of the bank secrecy act and other ways, because there is recognition as we know that one of the ways to interdict and actually stop the activity is to identify the financial flows and and stop those because they cause a disruption in the effort to disrupt.
John Byrne: Yeah. Yeah. And I think they have chosen words carefully, right? They say that there needs to be utilization of the bank secrecy act through existing provisions, so to engage, enhance engagement with institutions through the existing provision. So they're not asking for new legislation, but I think this would tell me as an AML Officer, that this is a space like human trafficking and elder abuse and other areas that I should, up my game a bit and try to figure out topologies and indicators.
Elliot Berman: Yes. I agree. I think there was definitely an important element of broad efforts that included many. And so something that you've been a big champion of and you and I have talked about many times - public private partnership, it is a law enforcement and a governmental activity, but there's more to it than that. And whether it's trying to change the playing field for the longterm, or whether it's sharing information, as you just referred to where folks in the private sector would be aware of what to look for, this is not something that the plan talks about solving just by having the government focus on.
John Byrne: Right. And, we talk about this maybe in a future program, but this week also focuses on how financial services are looked at as a series of provisions and witnesses dealing with sanctions. And they talk about private public partnership in that context. We've seen it in the anti money laundering act of 2020 that was signed earlier this year. That's a theme, so that's all good. And that's telling me and telling us that all the policy makers, all the stakeholders agree that this is a continued goal, and this is just another indication of the importance.
Elliot Berman: Agreed. I would urge people to take a look at least at the fact sheet. You also can access the the full report - it's about 32 pages both on a number of websites, including the one on housewhitehouse.gov
John Byrne: Yeah, I agree with that. One more point before we go this week the president was obviously in Europe, NATO and also met with Putin. One of the things I just want to highlight, because again, this just points to the issue of domestic terrorism and how much we have to do in response to a question about the violence that certainly many would argue Putin has allowed/ enabled to occur. He basically did a, "what about-ism" and said ,"Well, January 6th, those were simply political protestors and you've arrested over 400 of them."
Those are I hate to say this, talking points of a political party, sadly. So the fact that Vladimir Putin is suggesting, suggesting that the riot and insurrection that occurred on January 6th was political protest should annoy every American and anybody who cares about democracy.
Just I can't get over the fact that this is not the headline this week and some of the storylines, because that's really sad.
Elliot Berman: Yeah, I agree. But we've seen the narrative change radically over the last number of years and it it will take a long time for it to reach something that's more balanced and thoughtful and accurate.
John Byrne: A favorite quote of all time is Daniel Patrick Moynihan, who once said "You're entitled to your own opinions, you're not entitled to your own facts." And it applies in so many ways to this and other issues.
Elliot Berman: Yes, I'm not sure he knew how pressioned he really was being..
John Byrne: Exactly. All right. Well, have yourself a good rest of the week and we will talk next week.
Elliot Berman: All right.
John Byrne: Take care.
Elliot Berman: Bye-bye John.