This Week in AML

Some Thoughts on 9/11

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.  




Some Thoughts on 9/11 TRANSCRIPT


Elliot Berman: Hi, John, how are you this week?

John Byrne: Hi, Elliot, how are you doing?

Elliot Berman: I'm doing well. Thank you.

So, as everybody knows, Saturday is the 20th anniversary of the 9/11 attacks, [and] you and a distinguished panel live-streamed the webinar for AML RightSource on that topic earlier today. I thought it would make sense for you and I just to spend a few minutes talking about some of our thoughts about what happened and, more importantly, what it triggered on a go-forward basis.

John Byrne: Yeah. Obviously, as we both know, we were on the phone together that morning [and] talking about money laundering-related topics and bank secrecy when all this happened. So, like everybody else, we dealt with our reaction to that, and of course, you know, hugging our families and seeing if anybody that we knew was impacted.

What I thought about today that continues to be interesting is the partnership that started before 9/11 but really ratcheted up after that day in terms of law enforcement and the bankers saying we can do more to work together, and that's still a pretty big theme in 2021. So, I thought that was an interesting outcome that still resonates today.

Elliot Berman: Yeah.

Another one that I was thinking about is how the 9/11 events became such a dramatic call to service for so many people. There was a significant uptick in military enlistments. There were a number of people who joined law enforcement at the federal [level] and at other levels, and then lots of people who just generally went into government service, and when interviewed about it, their reason for doing it was 9/11.

So, I think that's a positive, in a sense that people saw an opportunity for civic service coming out of a terrible set of events.

John Byrne: Yeah. What I think it did for our world is, we felt through the late eighties and nineties, the importance of compliance in the anti-money laundering space.

But I think after 9/11, we recognized again [and] to today as well that what our community does matters. Today it's anti-human trafficking, elder abuse, you know, all sorts of types of financial crime, but I think there was a feeling, hey, you know, whether it's an OFAC compliance dealing with blacklists at the time or filing SARS that you know, what we do matters.

Not that it didn't matter before, but to your point about public service, I think some went into our field, thinking, you know, I can make a difference. So, I think that also was a nice by-product. Nice is the wrong word but a by-product of the 9/11 response.

Elliot Berman: Yeah, I agree. Because oftentimes back in the eighties and early nineties, there was a certain feeling in some compliance corners that people were toiling, unnoticed and unappreciated.

I think that that certainly has changed.

John Byrne: That's exactly right.

The other thing that I took away from today's conversation was, you know, the importance also to agencies working together. [Because] That was a big negative. Both the intelligence agencies and law enforcement [agencies] there were these, what they call the failure of imagination in terms of figuring out what they could do and why there were some sharing that went on before and partnering within agencies. It wasn't common.

So, I think there's still some of that today, but it has changed to some degree.

Elliot Berman: Yeah, coming out of 9/11, The Office of the Director of National Intelligence was created, and the various intelligence agencies scattered across the federal government, including The Department of Defense, got pulled at least for nominal reporting purposes under one head, and the purpose of that was to increase the intelligence sharing so that we would get the leverage of more eyes on the problem as opposed to fewer. So, I think that was a positive. By no means a perfect solution, no time to plant a flag, but definitely a big improvement over pre 9/11.

John Byrne: Yeah.

The other one, we'd be remiss if we didn't mention this. Cause we did mention it during the program, and that is the 9/11 commission at the time appointed by the Congress had five Republicans, five Democrats, [and] [a] large commission staff. We had one of the main staff members, John Roth, on our panel today, and it produced very sharp and compelling recommendations, criticisms, and some support for what went on. Unfortunately, given what went on on January 6th, we don't have that same function. There are a couple of Republicans on the January 6th commission, but it's not bipartisan in terms of support. It will be seen as political, regardless of [the] outcome, which is sad.

We need to really know what transpired prior [to], and during January 6th, we got that for 9/11. I hate to say, and I don't think we'll get that for January 6th.

Elliot Berman: Agreed, and not to end on two sorts of downers in a row, but I think the other thing 9/11 did, is it really brought to much higher prominence the whole concept of the threat landscape and paying attention to its evolution.

For those, you know, in the financial crime community [and] crime compliance community, that's all about typologies and trying to fair it out. What you're seeing and what's going on.

After 9/11, I think terrorism was viewed by most Americans as an external threat. Still, you and I have talked a number of times this year, and we've seen reports and other things that indicate that domestic terrorism is becoming, in many ways, a bigger threat.

I think that the threat landscape concept is really something that was around certainly in the intelligence agencies beforehand, but I don't think bankers, for example, or other financial services experts talked about the threat landscape and the way we all sort of have to think about it and talk about it today.

John Byrne: No, I agree with that.

It was a live stream today, but we'll be sending out a recording. So, if you get a chance, myself and Dennis Lormel wrote some blogs about our view about 9/11 and what transpired after that's also on our website. So, if you get a chance to read those, I would urge you to take a look at our site on that and a lot of the other content we've been producing.

Elliot Berman: Yeah.

John and I are here every week, and you can catch our podcast and our other podcasts on Spotify, Apple Podcast, or wherever you get your podcasts.

John, I will talk to you next week.

John Byrne: Take care, stay safe.

Elliot Berman: Bye-bye.