Proposed Interagency Guidance on Third-Party Relationships

By AML RightSource | July 16, 2021
This week US banking regulators asked for comment on proposed interagency guidance on third-party relationships. The proposed guidance will replace existing guidance, some of which dates to 2009. John and Elliot discuss the proposal, what financial service providers should consider as this proposal becomes final, and how the proposal may impact the examination process.

FATF: Review of Standards on Virtual Assets and Providers

By AML RightSource | July 9, 2021
The FATF has issued it’s second 12-month review of its revised standards for virtual assets and virtual asset providers. John Byrne, Executive Vice President and Elliot Berman, Creative Director of the AML RightSource staff, sit down and discuss the key elements of the review and its implications for global compliance in this emerging area.  

The New National Priorities for AML and Terrorist Financing

By AML RightSource | July 2, 2021
This week FinCEN issued the first Anti-Money Laundering and Countering the Financing of Terrorism National Priorities. They identify eight areas of focus for the next four years. John and Elliot discuss the Priorities, what they mean for the focus of enforcement going forward, how they may impact the examination process, and how FIs may consider responding publication of the Priorities.  

National Strategy for Combatting Domestic Terrorism

By AML RightSource | June 18, 2021
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.  

Corruption: A Topic of Global Focus

By AML RightSource | June 11, 2021
The US Administration and the United Nations are focusing on the adverse impact of corruption on the global economy and political stability. This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss these efforts and how both organizations are working to create change and motivate nations around the world to take up actions to reduce this nefarious activity.

Treasury Sanctions on Bulgarian Corruption

By AML RightSource | June 4, 2021
This week, John Byrne is joined by AML RightSource resident Sanctions expert and Special Advisor, Tim White. John and Tim discuss the recent release of the Global Magnitzsky Designations, and a few examples of what's happened recently in Bulgaria relating to the release. From gambling institutions, to professional basketball teams, the designations will undoubtedly affect a substantial amount of assets, now frozen. Link to Global Magnitsky Designations  

Tax Fairness and Shell Companies - the EU Weighs In

By AML RightSource | May 28, 2021
The European Commission has issued a Communication on Business Taxation for the 21st century. The focus of the communication is to “promote a robust, efficient and fair business tax system” in the EU. This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss the communication and its recognition that increasing the fairness in a tax system requires dealing with the problem of shell companies. John and Elliot explore the importance of transparency and the alignment of the EU effort with those of the current US administration.

OCC's Semiannual Risk Perspectives

By AML RightSource | May 21, 2021
The OCC has issued the Spring 2021 edition of its Semiannual Risk Perspectives. This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss the report and its value to the financial crimes compliance community. John and Elliot explore some of the themes in the report and the importance of understanding how FI regulators are looking at various risks going forward.  

National Intelligence Council - Global Trends 2040

By AML RightSource | May 14, 2021
There are many forces influencing global directions and the ability of governments, NGOs, and individuals to respond to crises and political events. This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff talk about the report Global Trends 2040, issued by the National Intelligence Council. John and Elliot explore the themes identified in the report and how they may influence global events over the coming decades.  

The Growing Connection Between Domestic and International Terrorism

By AML RightSource | May 7, 2021
Domestic and international terrorism are growing challenges. This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff talk about an announcement by the US Department of Justice of the second guilty plea by a member of the "Boogaloo Bois" to conspiracy to provide material support to Hamas. John and Elliot explore the growing connection between these two global problems.  

UK Issues Sanctions Under Anti-Corruption Regime

By AML RightSource | April 30, 2021
Corruption is a continuing global problem. This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff talk about the new UK Anti-Corruption Regime. John and Elliot explore the sanctions issued by the UK and the importance of a world-wide coordinated effort to combat corruption.

Continued Vigilance on Domestic Terrorism

By AML RightSource | April 23, 2021
Domestic Terrorism is a constant issue that effects all of us. Join John and Elliot this week, as they discuss the current landscape of combating terrorism, with a specific focus on the financial elements, and how each of us in the community can be a part of the solution to this critical issue.    

InfraGard – 25 Years of Partnership

By AML RightSource | April 16, 2021
This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff talk about InfraGard, a 25-year-old partnership between the FBI and the private sector to help identify cyber threats. John and Elliot explore the value of public-private partnerships and how InfraGard has expanded from cybercrime to include terrorism, intelligence, and other matters.    

Busy, Busy, Busy…

By AML RightSource | April 9, 2021
This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff talk about the recent change in FinCEN leadership, the FinCEN ANPRM on the beneficial ownership registry, newly issued sanctions on human traffickers in Pakistan, and an evolving public-private partnership in northern Virginia. It has been a busy week in the financial crimes compliance space, tune in to hear all about it.  

North Korean "Businessperson" Extradited for Money Laundering

By AML RightSource | April 2, 2021
This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff talk about the announcement by Department of Justice that it has completed the extradition of a national of the Democratic People’s Republic of Korea (DPRK). The indictment alleges that the individual and others conspired to covertly and fraudulently access the U.S. financial system and to have defrauded U.S. banks and violated both U.S. and U.N. sanctions as part of the money laundering activities in transactions valued at over $1.5M. John and Elliot discuss the importance of FIs remaining vigilant in their understanding with whom they are transacting business.  

Do You Know How to Serve Complex Clients?

By AML RightSource | March 26, 2021
This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff talk about the NCUA’s recent Cease and Desist Order to Live Life Federal Credit Union. John and Elliot discuss the complexities of providing services to marijuana-related businesses and dealing in virtual currency; and the lessons that all FIs can glean from the Order.    

What is Fair Access to Banking?

By AML RightSource | March 19, 2021
This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff talk about the recently proposed Fair Access to Banking Act. John and Elliot discuss the mandates in the Act, the challenges it presents to risk-based compliance programs, and the types of entities that are not included in the coverage of the proposed legislation.     

FinCEN Reminds FIs About Trade in Antiquities and Art

By AML RightSource | March 12, 2021
This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff talk about the notice from FinCEN about its efforts around trade in antiquities and art. John and Elliot discuss the activities that FinCEN is undertaking in this area, some of the resources which are included in the notice, and FinCEN’s guidance about the elements of an effective SAR narrative about antiquities and art.    

Should FinCEN's Standing in the National Security Apparatus be Enhanced?

By AML RightSource | March 5, 2021
This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff talk about the policy paper on improving FinCEN’s role in national security, issued by Global Financial Integrity. John and Elliot discuss the views expressed in the paper and some of GFI’s recommendations to enhance FinCEN to meet the growing national security threat posed by money laundering.    

Some Things to Watch in the Anti-Money Laundering Act

By AML RightSource | February 12, 2021
This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff talk about some provisions of the Anti-Money Laundering Act of 2020. John and Elliot discuss a recent posting by the International Consortium of Investigative Journalists which identifies some of the possible shortcomings in the Act and how these provisions may be come to be during the legislative process.  

Fraud - This Time It's Healthcare

By AML RightSource | February 5, 2021
This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff talk about FinCEN Advisory FIN 2021-A001 which focuses on health insurance and healthcare fraud. John and Elliot discuss the red flags in the Advisory and actions FIs can take to identify this activity and messages they can share with their customers to help them recognize these schemes.  

Public Corruption's Impact on Democracy

By AML RightSource | January 29, 2021
This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff talk about the release by Transparency International of its Corruption Perceptions Index for 2020. John and Elliot discuss the findings and recommendations in the CPI report, including the impact of pandemic related corruption on economic and democratic institutions.

A Lot Happened This Week in AML

By AML RightSource | January 22, 2021
This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff talk about the introduction of the Domestic Terrorism Prevention Act, the comments by Janet Yellen about the risks of crypto or virtual currencies, and the issuance by FinCEN of frequently asked question about SAR filing. They discuss how the DTPA is a direct response to the incursion at the Capitol and how Yellen’s comments are aligned with those by financial regulators in other countries.

Let's Keep Working to Stop Human Trafficking

By AML RightSource | January 15, 2021
This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff talk about January being National Slavery and Human Trafficking Prevention Month. They explore how the AML community is working to identify human trafficking and provide law enforcement with actionable information to support efforts, along with many other organizations, to interdict and end human trafficking.

Domestic Terrorism in Our Nation's Capitol

By AML RightSource | January 8, 2021
This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss the unprecedented actions at the Capitol Building in Washington DC. They explore the challenges presented by domestic terrorism, how financial services companies can work to identify possible planning activities by domestic terrorists, and what actions Congress may take to codify domestic terrorism in the Federal criminal law.  

OCC Proposal Mandating Banking Services

By AML RightSource | January 1, 2021
This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss the letter from 22 Democratic members of the House Financial Services Committee to the Comptroller of Currency, urging the OCC to withdraw its notice of proposed rulemaking which would require national banks to provide services to firearms manufacturers and fossil fuel companies. During the conversation they look at the basis of the proposed rule and the concerns raise by the committee members in their letter.  

The Anti-Terrorism Act

By AML RightSource | December 18, 2020
This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss several cases recently filed under the Anti-Terrorism Act arising from alleged terrorist acts in the Middle East where the supportive funding was funneled through several charitable organizations. During the conversation they consider the impact the suits could have on the access legitimate charities have to financial services.

AML Reform - What Has Congress Agreed To?

By AML RightSource | December 11, 2020
This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss the Congressional Conference Report of the National Defense Authorization Act. The Act contains the Anti-Money Laundering Act of 2020, the first major reform to the AML infrastructure since adoption of the USA PATRIOT Act. During the conversation they identify some of the interesting items contained in the final language.    

What We Can Learn From Regulatory Orders

By AML RightSource | December 4, 2020
This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss a recent consent order between a community bank and the FDIC. During the conversation, they look at the value for all institutions of reviewing regulatory orders to understand the current thinking of the regulators and how to review your BSA program to ensure that it meets expectations.    

Continued Forward Progress on BSA Reform

By AML RightSource | November 27, 2020
This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss the latest on a bi-partisan effort in Congress to adopt the first major reform to the AML infrastructure since adoption of the USA PATRIOT Act.  

OECD Phase 4 Report on US Anti-corruption Efforts

By AML RightSource | November 20, 2020
This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff talk about the report issued by the Organization for Co-operation and Economic Development (OECD) on the efforts by the United States to combat bribery of foreign elected officials in international business transactions. During the conversation John and Elliot discuss the recommendations in the report and the importance of US actions in this critical area.

National Security Implications of a Delayed Transition

By AML RightSource | November 13, 2020
This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss the national security risks of delays in the presidential transition process. Their conversation looks at the risks that moments of disruption present to our country from foreign and domestic bad actors.    

When Sanctions and Election Influencing Meet

By AML RightSource | November 6, 2020
This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff talk about the announcement from the Department of Justice of the seizure of 27 domain names being used by the Iranian Revolutionary Guard Corps – a designated terrorist organization. The websites were being used to manipulate public opinion in many countries including the United States.

The Latest From the FATF October Plenary

By AML RightSource | October 30, 2020
This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff talk about the recent Plenary held by the Financial Action Task Force (FATF). John and Elliot discuss how FATF is moving its work forward during the pandemic and the progress being made on the organization's strategic initiatives.      

What Guidance May Mean in the Future

By AML RightSource | October 23, 2020
This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff talk about the recent action by the Board of Directors of the FDIC to authorize publishing a proposed rule to clarify that supervisory guidance is not regulation. John and Elliot discuss the value of such a rulemaking and the need for all of the agencies which were part of the original statement in 2018 to take similar action.     This Week in AML: October 23, 2020 Transcript

FinCEN Advisory on Human Trafficking

By AML RightSource | October 16, 2020
This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff to talk about the new Supplemental Advisory that FinCEN issued on identifying and reporting human trafficking. John and Elliot discuss who in FIs should be aware of the new guidance and some of the key points made in the issuance.

Flows of Illegal Funds Magnify Inequality

By AML RightSource | October 9, 2020
This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss a blog post on the website of Transparency International about the rise of corruption during the pandemic and its impact on inequality. John and Elliot examine the premise of the post that flows of illicit funds increase inequality in economies and societies.

Responding to Written Agreements with the Federal Reserve Banks

By AML RightSource | October 2, 2020
This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss a written agreement entered into between the Federal Reserve Bank of Philadelphia and a bankers’ bank, as well as the requirements set out for the bank to repair the deficiencies in its BSA compliance program.

The FinCEN Files

By AML RightSource | September 25, 2020
This week, Vice Chairman John Byrne, and Creative Director Elliot Berman of the AML RightSource staff the publication of information from leaked suspicious activity reports (SARs) and the implications for BSA reform and the impact on FI compliance programs.

Will Regulations Change? FinCEN Asks for Input

By AML RightSource | September 18, 2020
This week, Vice Chairman John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss FinCEN’s Advanced Notice of Proposed Rulemaking in which it asks for comment on a number of ideas for possible changes to current BSA regulations.

Our Compliance Journey Since 9/11

By AML RightSource | September 11, 2020
This week, Vice Chairman John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss the anniversary of the attacks on 9/11 and how those events have shaped financial crimes compliance for almost two decades.

The Confidentiality of SARs

By AML RightSource | September 4, 2020
This week, Vice Chairman John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss the recent press release published by FinCEN regarding the confidentiality of SARs, as well as the heavy criminal penalties around the inappropriate release of them. John discusses previous issues, and regulatory changes that helped bolster the security around the access to SARs, as well as the timing around the press release and the potential catalyst behind the release itself.

Are There Any PEPs at Home?

By AML RightSource | August 28, 2020
This week, Vice Chairman John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss recent guidance by financial institution regulators about politically exposed persons – PEPs - and a call by Transparency International EU for increased vigilance on money laundering enforcement by EU regulators.

Global Disruption of Three Terror Finance Cyber-enabled Campaigns

By AML RightSource | August 14, 2020
This week, Vice Chairman John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss the announced seizure by the Justice Department, the IRS and other federal agencies of cryptocurrency accounts from several terrorist organizations. The seizures related to terrorist financing campaigns by the Al-Qassam Brigades, Al-Qaeda and ISIS.

The Largest Unregulated Business in the US

By AML RightSource | August 7, 2020
This week, Vice Chairman John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss the recent report by the Senate Permanent Subcommittee on Investigations on The Art Industry and US Policies the Undermine Sanctions. The report discusses the largest unregulated – from a BSA perspective – in the US and how it is being used to launder illegal funds and evade sanctions.

The Implications of Ransomware Attacks by Sanctioned Entities

By AML RightSource | July 31, 2020
This week, Creative Director Elliot Berman and Special Advisor Tim White of the AML RightSource staff discuss the recent ransomware attack against Garmin and the implications of the attack which was perpetrated by a sanctioned entity.

BSA/AML Reform Takes Another Step Forward

By AML RightSource | July 24, 2020
This week, Vice Chairman John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss the latest actions in Congress to pass sweeping reform to the AML infrastructure.

We Can’t Travel to Europe, But We Can Pay Attention

By AML RightSource | July 17, 2020
This week, Vice Chairman John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss two actions from the EU. The decision by European High Court to restrict storage of personal information of EU citizens on servers in the United States and the recommendation by the European Commission that Member States do not grant financial support to companies with links to countries on the EU's list of non-cooperative tax jurisdictions. Both of these actions will impact the financial crime compliance community in the US.

Gathering Information to Close Loopholes

By AML RightSource | July 10, 2020
This week, Vice Chairman John Byrne, and Creative Director Elliot Berman of the AML RightSource staff discuss the US Supreme Court decision in Trump v. Mazars regarding subpoenas issued by several congressional committees, including House Financial Services, to the president for certain personal financial records and the purpose for the subpoenas.
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