AML Conversations

If transaction monitoring thresholds are too sensitive or not sensitive enough, financial institutions run the risk of missing genuine criminal behavior. Likewise, without periodic tuning and optimization, systems may fail to detect emerging criminal methodologies or comply with the latest AML rules. In this episode, our advisory experts, Joshua and Jonathan, take a deep dive into the technical process of tuning and optimizing, sharing best practices and insights to ensure systems operate effectively and support a risk-based approach.

FinCEN issued a Notice about fraud schemes using counterfeit US passport cards this week. The FBI uncovered a complex money laundering strategy using casinos, sportsbooks, and FanDuel accounts. New bi-partisan stablecoin legislation was introduced in the US Senate. John and Elliot discuss these and more happenings and how they impact the financial crime prevention community.

This week, John and Elliot discuss Treasury testimony in the US Senate Banking Committee, Treasury’s updated cybersecurity MOU with Ukraine, a DOJ report on pandemic fraud, an interesting article on the impact of Russia sanctions, and more.

The money laundering challenges and potential abuse of the myriad “Residency and Citizenship by Investment Programmes.”: A FATF-OECD Report. Our panellists discuss the 2023 Report and the need for improved awareness of enabling the movement of illicit funds without proper oversight and reporting. Graham Peachey: UK Home Office Senior Policy Advisor and Project Co-lead for the Financial Action Task Force project on Misuse of Residency and Citizenship by Investment Programmes. Tivon Sterin: Senior Policy Advisor, Office of Terrorist Financing and Financial Crimes, U.S. Department of the Treasury. Co-lead for the FATF project team on Misuse of Residency and Citizenship by Investment Programmes.

American Mother: A conversation with Diane Foley, President and Founder of the James W. Foley Legacy Foundation. Diane discusses her book, her decade-long effort to change American policy on hostage negotiations, the continued need to ensure the safety of journalists traveling aboard, and the overall importance of journalism in a world racked with terrorist activity.

This week, the US Department of Commerce issued a report about investigations of export control and antiboycott violations. FATF published information about countries’ progress in complying with its Recommendation 15 about VASPs. FinCEN requested information on a possible change to the CIP rule. John and Elliot discuss these items and others and their meaning for the financial crime compliance community.

What is Tuning and Optimization? Why should financial institutions do this exercise? Are there any benefits or regulatory prescriptions for it? Josh and Jon, our experts in this field, provide a comprehensive overview of tuning and optimization, delving into the details of why it's essential, how it's done, the benefits for financial institutions, and what it looks like from a transaction monitoring perspective. Tune in now!

This week, the US Department of Justice filed a forfeiture action to seize New York apartments allegedly purchased with funds from a corruption scheme in Mongolia. FATF upgraded its assessment of the US’s response to Recommendation 24 on beneficial ownership. The Wolfsberg Group issued new guidance on internal audit programs for financial crime compliance programs. The US Treasury released a report on managing AI-specific cybersecurity risks in the financial sector. John and Elliot discuss these items and their meaning for the financial crime compliance community.

John and Elliot are at the AML Partnership Forum this week. They review key themes from the meeting and discuss US Homeland Security’s Global Human Trafficking: A Year in Review report, the ICIJ’s Annual Report for 2023, and a GAO anti-money laundering report.

The Office of the Director of National Intelligence has issued its Annual Threat Assessment. The Departments of Commerce, Treasury, and Justice issued a joint Compliance Note on the obligations of foreign-based persons to comply with US sanctions and export controls. John and Elliot discuss these reports, other items, and their meaning for the financial crime compliance community.

There are many things to talk about this week. A US District Court issued an opinion disrupting the beneficial ownership registry. The UK Financial Conduct Authority issued a letter to CEOs about the inadequacy of compliance with money laundering regulations. An op-ed about avoidance of sanctions in the US art market. An investigative article into facilitating shell companies. John and Elliot discuss all these items and their meaning for the financial crime compliance community.

John and Elliot discuss the outcomes from the FATF Plenary, new sanctions issued against Russia, the results of the Puerto Rican Bankers’ AML Forum, and their meaning for the financial crime compliance community.

Dr. Gerald Fitzgerald of the Schar School of Policy and Government at George Mason University discusses his recent report on the use of misinformation and how it harms the humanitarian work of Muslim charities and NGOs and causes derisking.

As financial crime evolves, so do the challenges organizations face in combating it. In this thought-provoking episode, Vesna McCreery, Managing Director for EMEA & APAC, and Patrick Bowe, our newly appointed Head of Product, delve deep into the complexities of emerging financial crime and geopolitical risks, and the intricate interplay between data management and technology. Tune in to stay informed and learn how we can navigate through these challenges!

This week, the EU published the text of its new AML Regulation and Directive, FinCEN issued guidance on the beneficial ownership registry access rule, and Puerto Rico adopted new rules for IFEs and IBEs. John and Elliot discuss these and other items and their meaning for the financial crime compliance community.

FinCEN issued a Notice of Proposed Rulemaking on giving investment advisors reporting and recordkeeping obligations under the BSA this week. FinCEN also posted a Financial Trend Analysis reviewing the use of convertible virtual currency and online child sexual exploitation and human trafficking. John and Elliot discuss these and other happenings this week and their meaning for the financial crime compliance community.

This week, there are several important items from the US Treasury. It issued its 2024 risk assessments for money laundering, terrorist financing, and proliferation financing. FinCEN sent a draft Notice of Proposed Rulemaking on residential real estate transactions to the Federal Register for publication. John and Elliot discuss these issuances and their meaning for the financial crime compliance community.

This week, Transparency International released its Corruption Perception Index for 2023. John and Elliot discuss the Index and several other items and their meaning for the financial crime compliance community.

This week, George Mason University published a report about Anti-Muslim Discrimination and Information Manipulation, the Basel Institute on Governance reported on successful efforts to improve public integrity in Peru, and the GAO issued a report on the need for more accurate collection of data on foreign investment in US farmland. John and Elliot discuss these items and others and their meaning for the financial crime compliance community.

This week Nasdaq issued its 2024 Global Financial Crime Report, the UN Office of Drugs and Crime released a report on casinos, underground banking, and money laundering, and the Anti-Defamation League published a report on the use of cryptocurrency exchanges by US extremists to foster their fundraising efforts. John and Elliot discuss these reports and their meaning for the financial crime compliance community.

Jim Lee, IRS:CI Chief, returns to AML Conversations to share his thoughts on the IRS:CI 2023 Annual Report, the work of the J5, several key IRS cases, and the first coverage of the 2023 BSA Data Challenge.

We talked with John Byrne and Elliot Berman about what they see as the trends in financial crime prevention for 2024.

This week, several interesting reports were released. Eurasia Group issued its Top Risks 2024, Human Security Collective published The Future of FATF Recommendation 8, FinCEN issued a Financial Trend Analysis and much more. John and Elliot discuss these and their meaning for the financial crime compliance community.

This week, the US Beneficial Ownership Registry went live, Senator Menendez was charged with additional allegations, export enforcement is back in the news, the US Department of Justice received new authority in foreign bribery cases and much more. John and Elliot discuss these and their meaning for the financial crime compliance community.

This episode originally aired on September 22, 2023 The Financial Crimes Enforcement Network (FinCEN) has published a Small Entity Compliance Guide for beneficial ownership information. A set of FAQs accompanies the guide. John and Elliot discuss the guide, the current compliance deadlines announced by FinCEN, and their thoughts on what may change shortly. They also chatted about a recent consent order between FinCEN and an international banking entity in Puerto Rico.

This week, an advisory on spear-phishing was issued, the US Department of Justice brought indictments for an $80 million pig butchering scheme, and several other interesting things surfaced. John and Elliot discuss these and their meaning for the financial crime compliance community.

This week, the US Treasury issued a Fact Sheet on its action to disrupt corruption, FINTRAC levied fines against another bank for AML/CFT program violations, The US House passed changes to the beneficial ownership registry rules, and several other interesting things surfaced. John and Elliot discuss these and their meaning for the financial crime compliance community.

Concluding our four-part series on Artificial Intelligence (AI), David McLaughlin, Founder of QuantaVerse and the current EVP of Technology Sales at AML RightSource, alongside our brilliant Principal Data Scientist, Leandro Loss, discuss how AI solutions are crafted and how their extraordinary capabilities are reshaping compliance; now, and in the future. Tune in to find out more about how this powerful technology can be our ally in the battle against financial crime.

We talk with Mark Freedman, an international security expert who covers how to react to terrorism by Hamas and other criminal organizations and how geopolitics and intelligence gathering assist corporations in addressing risk.

We talk to Oliver Wyman and Atlantic Council’s Dan Tannebaum about the state of sanctions, their value as a national security tool, recommendations on detecting sanctions evasions, and what to expect going forward.

This week the White House hosted the second Summit for Democracy, focusing on reducing corruption and illicit finance. Treasury Secretary Janet Yellen announced a Commitment entered into by the participating countries centered on transparency of beneficial ownership information. John and Elliot discuss these items and how they impact the financial crimes compliance community.

It has been another busy week. The Center for International Private Enterprise issued a report on the importance of business integrity to the rebuilding efforts in Ukraine. The IRS issued an alert on charity scams. The US Treasury was urged to push the IMF to increase enforcement of its 2018 Governance Framework, and FinCEN issued a statement about the Counter Terrorism Financing Taskforce. John and Elliot discuss these communications and their meaning for the financial crime compliance community.

What can we learn? In an exclusive interview with the Project Manager of the Basel AML Index, John sits down with Kateryna Boguslavska, who has overseen the Index since 2017, and covers the key themes and takeaways for the global AML community.

It has been another busy week. The Basel Institute on Governance released its AML 2023 Index. The US and the UK issued sanctions on Hamas leaders and financiers, and the US House Financial Services Committee approved several interesting new bills. John and Elliot discuss these activities and their meaning for the financial crime compliance community.

John talks with Chuck Taylor of our Financial Crime Advisory about recent discussions in the popular press about why banks close customer accounts.

It has been a busy week. FinCEN issued an alert and final rule, OFAC issued sanctions against cartel activity on fentanyl, and Canada and the UK adopted new laws on beneficial ownership reporting. John and Elliot discuss these actions and what they mean for the future.

It has been a busy week. FATF released the outcomes from its October Plenary, the Biden Administration issued an Executive Order on Artificial Intelligence, and the US Supreme Court heard arguments about asset forfeiture. John and Elliot discuss the possible impact of these actions and what you should watch for going forward.

Step into the exciting realm of cutting-edge AI technology! Join our host, Rachel Dettmer, as she welcomes back our esteemed Principal Data Scientist, Leandro Loss, for an engaging discussion on Large Language Models. Together, they delve into thought-provoking questions: How will these models revolutionize anti-money laundering and financial crime compliance? Are human investigators at risk of being superseded by these models? Why are regulators apprehensive of their inclusion into compliance programs? Tune in as they discuss the intersection of technology and compliance in an evolving financial crime landscape!

FinCEN has issued a new regulation, renewed its real estate geographic targeting orders, and published an alert regarding terrorist financing. John and Elliot discuss this flurry of activity and why each element is important in today’s operating environment.

John and Elliot examine how different things come together in financial crime prevention efforts. They discuss a recent release from AUSTRAC about the connection between cybersecurity and AML/CFT compliance and an interesting blog post from the Council on Foreign Relations on the nexus of human trafficking, democracy, and corruption.

In this episode, Leandro Loss, our Principal Data Scientist, and Kevin Lee, our Director Financial Crime Technology, delve into the trustworthiness of AI, why it's often viewed as an enigmatic 'black box', and why conventional 'white' models are falling short in the battle against financial crime.

It's clear that terrorist financing is still a global problem that demands consistent vigilance. John and Elliot discuss the importance of being vigilant and the challenges nations and organizations face worldwide.

Jonathan Lopez joins John to discuss the state of corruption, how prosecutors see their cases, advice for BSA/AML officers to avoid personal liability, and other white collar issues.

This week Elliot and John come to you from the ACAMS Assembly in Las Vegas. They discuss some of the highlights from sessions at the conference and talk about why the work of the financial crime compliance community is so important.

Kira Zalan, Investigative Editor of the Organized Crime and Corruption Reporting Project (OCCRP) discusses the continuing need for investigative journalism, the dangers of reporting, and some examples from their various projects and stories.

Learn the fundamentals with our expert and demystify the world of Artificial Intelligence! In this episode, Leandro Loss, our esteemed Principal Data Scientist, unravels the core concepts of Data Science, Artificial Intelligence, Machine Learning, and Deep Learning. Prepare to delve into the realm of AI as he shares his vast knowledge and discusses the urgent need for data-driven solutions to combat financial crime in today's fast-paced and rapidly changing world.

In a busy week, John and Elliot discuss the corruption and bribery indictment of US Senator Robert Menendez, an adverse ruling in the civil case against the Trump Organization, a recent package of bipartisan legislation from the House Financial Services Committee, and the looming shutdown of the US government.

The Financial Crimes Enforcement Network (FinCEN) has published a Small Entity Compliance Guide for beneficial ownership information. A set of FAQs accompanies the guide. John and Elliot discuss the guide, the current compliance deadlines announced by FinCEN, and their thoughts on what may change shortly. They also chat about a recent consent order between FinCEN and an international banking entity in Puerto Rico.

The US Department of State has issued its Implementation Plan for the US Strategy on Countering Corruption. The five-pillar Plan outlines actions for the department, its agencies, and its domestic and international partners. John and Elliot discuss the plan and its impact on global anti-corruption efforts.

The Inspector General from the US Treasury Department has issued an audit report on FinCEN’s BSA data retention processes. The Financial Conduct Authority in the UK is reviewing the treatment of domestic PEPs by financial services companies. Moody’s Analytics issued a white paper on wildlife trafficking. John and Elliot discuss these developments and what you should know about them.

Stef Cassella joins John for the record-breaking third appearance. They discuss: How Stef has been assisting other countries in drafting forfeiture legislation (criminal and civil) and in training their prosecutors and judges, a recognition in countries that are used as money laundering centers that they need a means to deter foreign criminals from using their financial institutions for that purpose What the congressional proposal called the “FAIR Act” would do to the civil forfeiture infrastructure and Stef’s view on an upcoming Supreme Court case, Culley v. Marshall, where Plaintiffs ask the Court to recognize a right to an immediate post-seizure hearing whenever law enforcement seizes property for civil forfeiture.

The International Crisis Group issued a report on the impact of sanctions on peacemaking. John and Elliot discuss critical insights in the report. They also examine whether or not sanctions against Russia have been effective and several other news items of the week.

The Wolfsberg Group issued a comment letter in the public consultation of FATF’s draft amendments to Recommendation 8 and its Interpretive Note and updates to its Best Practice Paper to Combat the Abuse of NPOs. John and Elliot discuss the comments and the next steps for proposals. They also talk about several other things of interest to the financial crime community.

In this episode, Rachel Dettmer, Joshua Gubitz, and Jonathan McIsaac delve into the potential obstacles that can arise during the implementation process. They discuss the warning signs to look out for, pitfalls to avoid, risks to manage, and key areas to pay close attention to in order to ensure a successful implementation. Get ready to learn from the experts!

Kevin Lee, Director, Financial Crime Technology at AML RightSource, captivated the audience at the 2023 European Anti-Financial Crime Summit in Dublin. In this episode, we recap his speech on how technology can best be harnessed for financial crime.

The American Bar Association House of Delegates has approved changes to strengthen a lawyer’s obligations as a gatekeeper. Also, FinCEN issued a Notice about the increase in worker’s compensation insurance and payroll tax fraud in the construction industry, and the US Treasury Department released information about its efforts pursuing wealthy tax evaders. John and Elliot discuss these developments and how they may shape compliance in the future.

This week, Attorney General spoke to the American Bar Association, and OFAC issued guidance on providing humanitarian assistance to Syria. John and Elliot discuss the speech and guidance and look at the recent release of SAR filing data by FinCEN.

Both the US House and Senate have been very active ahead of leaving for their August recess. John and Elliot discuss the Senate proposal to apply the AML/CFT compliance requirements to all the players in the virtual assets space and the proposals that moved to the House floor on stablecoins, limiting public company disclosures on climate change impact, and many other issues.

John Byrne and Shannon Frontanes of Thomson Reuters Special Services and a provenance expert, discuss her insight on cultural artifacts and their use for money laundering and related crimes.

The US Departments of Commerce, Treasury, and Justice recently updated their voluntary self-disclosure policies. The DOJ also announced the sentencing in a case for conspiring to violate Iranian sanctions and an indictment for a fraudulent charitable contribution tax scheme. In Europe, Interpol announced that it disrupted a transnational migrant smuggling network resulting in 62 arrests. John and Elliot discuss these announcements in a busy week in the financial crime prevention community.

The Subcommittee on National Security, Illicit Finance, and International Financial Institutions of the US House Financial Services Committee held a hearing this week on the Potential Consequences of FinCEN’s Beneficial Ownership Rulemaking. The hearing focused on the proposed beneficial ownership information registry proposed by FinCEN under the Corporate Transparency Act. John and Elliot discuss the testimony given by the witnesses and statements of the committee members.

Europol recently issued its 2023 Terrorism Situation and Trend Report. The US Treasury issued new sanctions against a top Serbian security official. Merrill Lynch was fined and more. John and Elliot discuss the many goings-on this week in financial crime prevention.

Continuing the conversation on implementation support, Rachel Dettmer, Joshua Gubitz, and Jonathan McIsaac discuss the value of having an experienced partner on your side during implementation and how a wealth of cumulative knowledge and varied experience always proves to be advantageous.

The US Department of Justice announced an indictment charging four people with fraud and money laundering. John and Elliot discuss the connection between fraud and money laundering and how the detection of one can lead to the detection of the other.

Implementation Support is a planned approach to integrate new or upgraded software or systems into the existing workflow of an organizational structure to help ensure the success of a business's overall system. In this episode, Rachel Dettmer, Joshua Gubitz, and Jonathan McIsaac discuss why it's beneficial for banks and financial institutions to have implementation support in addition to what's just provided by the system vendor.

John Byrne and Gary Shiffman, Founder of Giant Oak, Inc., discuss his recent article It’s not the algorithm, it’s the ethics. They look at the ethics and morality of adopting machine learning and artificial intelligence tools and how these impact adoption in the financial compliance space.

The FATF June Plenary has ended, and the Homeland Security & Governmental Affairs of the US Senate issued a report on intelligence failures before January 6, 2021. John and Elliot discuss some of the outcomes of the FATF meetings and look into the key findings in the Senate committee report.

The US Department of State has issued its 2023 Trafficking in Persons report. The theme of this year’s report is partnerships. John and Elliot discuss key elements of the report and its value to the financial crime prevention community.

John Byrne and Terry Pesce discuss the recent Interagency Guidance on Third-Party Relationships: Risk Management. They look at the implications of the guidance and what banks should do to assess their current risk management process for interactions with third parties.

US bank regulators have issued interagency guidance on third-party risk management. The new pronouncement combines and updates past guidance issued by the individual agencies. John and Elliot discuss key parts of the guidance and some implications for banks and their vendors.

There have been several recent articles about the effectiveness of US sanctions. John and Elliot examine this issue and discuss where the programs have succeeded or failed to achieve their stated goals.

Seven years ago, the Panama Papers were published. Recent statistics show that registrations of anonymous corporations in Panama have dropped by more than 50% in the past ten years. John and Elliot discuss the impact of Papers on corporate activities in Panama and ownership transparency across the globe.

Jonathan Fishman, one of the authors of the 2023 Treasury Department’s De-risking Strategy, discusses the various recommendations and the rationale for some of the words used to describe the problem and identifies other key areas of the report.

US law enforcement agencies recently completed a three-month campaign to disrupt frauds perpetrated by foreign actors. John and Elliot discuss the campaign’s details, why it is essential, and what financial service providers can do to support it. They also chatted about several other events this week.

Don Fort, former Chief of IRS - Criminal Investigation Division, Director of Investigations at Kostelanetz LLP, and member of the Advisory Board at AML RightSource, discusses his recent testimony before the Senate Finance Committee about potential IRS funding cuts and their impact on federal law enforcement.

John and Elliot explore how intermediaries are helping evade sanctions and bring luxury goods to Russia. They also discuss new cooperation between the sanction teams in the US and EU and touch on other financial crime prevention news.

The New York Attorney General has proposed legislation to regulate the cryptocurrency industry. The proposal includes provisions protecting investors, increasing transparency, and eliminating conflicts of interest. John and Elliot discuss key aspects of the proposal and its implications for federal regulation of the virtual currency space. They also touch on several other news items from this week.

The US Treasury has issued its 2023 De-risking Strategy. The report reviews the reasons that banks engage in de-risking and includes recommendations to reduce the impact of the practice. John and Elliot discuss their thoughts on the strategy, where they think Treasury got things right, and where it missed opportunities.

Experts from InterAction explain the continuing efforts to enhance financial access for humanitarian organizations, including UN Resolution 2664 and the US General Licenses by OFAC. Kathryn Striffolino, Senior Manager for Humanitarian Practice, has worked in international human rights and humanitarian affairs for over a decade and a half, focusing on human rights and mass atrocity crime documentation, analysis and policy, and humanitarian response in conflict settings. Andrea Hall joined InterAction in March 2022 as Senior Manager of the Together Project. She brings over ten years of experience as a policy advocate, analyst, and organizer at the state and federal levels.

Sanctions against Russia have been a meaningful part of the support for Ukraine by the United States and the European Union. A significant challenge to the sanctions has been the efforts by bad actors and supporters of Russia to evade them. John and Elliot discuss the evasion problem, how the US is working with its allies to increase the impact of the sanctions, and ideas from some economists on increasing sanctions effectiveness.

Legal Consultant Liz Fraccaro from the Antiquities Coalition joins John Byrne again to cover The Art Market Report 2023 and how to utilize the information to enhance eventual AML due diligence.

The Wolfsberg Group has published updated Anti-Bribery and Corruption Compliance Programs guidance. John and Elliot discuss critical elements of the guidance and the importance of financial service providers maintaining effective programs.

UBS and Art Basel recently issued their report, The Art Market 2023. The report includes a discussion of the concerns about the compliance burdens of market participants. John and Elliot examine those concerns and why those markets must align with others to stem money laundering and illicit finance. They also discuss the new stolen art app from the FBI.

John Byrne interviews the publisher of the Illicit Edge, Ryan Wallerstein, who shares his career journey from business to the Treasury Department to this new content endeavor.

Another very busy week in financial crime prevention. John and Elliot discuss several items, including new sanctions, a letter from the House and Senate to Treasury and FinCEN, and a financial trend analysis issued by FinCEN.

The International Consortium of Investigative Journalists (ICIJ) has published a story about artifacts in the Metropolitan Museum of Art catalog linked to possible looting and trafficking. John and Elliot discuss the global problem of antiquities trafficking and its impact on the countries from which items come.

This week the US Department of Justice announced an indictment against seven individuals for a $100 million stolen identity refund scheme. The Office of the Comptroller of the Currency announced a penalty and prohibition against a former senior official at Wells Fargo. The US Treasury Department announced it has agreed to give in camera access to certain SARs to a House oversight committee. John and Elliot unpack this busy week and share their insights on these topics.

Dr. Michael Zimmer, Director, Center for Data, Ethics, and Society and Associate Professor & Vice-Chair, Department of Computer Science at Marquette University discusses: - Privacy and data ethics - The dark web - The “spatial project” - The Center’s work with policy makers on a variety of issues.

The US Department of Justice has updated its Corporate Enforcement Policy for criminal activity. John and Elliot discuss some aspects of the voluntary self-disclosure part of the CEP and how financial crime compliance professionals can make use of the policy guidance documents in reviewing elements of their compliance programs.

Liz Fraccaro, Attorney and Legal Consultant to the Antiquities Coalition, shares her insight on FATF’s recent report, Money Laundering and Terrorist Financing in the Art and Antiquities Market.

The Financial Action Task Force (FATF) held a plenary last week. FATF also issued a report on Money Laundering and Terrorist Financing in the Art and Antiquities Market. John and Elliot discuss some of the outcomes from the plenary, including the suspension of the Russian Federation’s FATF membership. They also look at key take-aways in the report on arts and antiquities.

How can we improve the cyberworld? One author tells us. We sat down with banking expert Tom Vartanian to discuss his recent book: “The Unhackable Internet: How Rebuilding Cyberspace Can Create Real Security and Prevent Financial Collapse.” Vartanian charges that our current cyber systems are unsustainable and offers several recommendations for the private and public sectors.

It has been a year since the Russian invasion of Ukraine. One of the immediate responses to Russia’s action was an ongoing coordinated effort by the US, G7 and European Union to limit Russia’s war-making ability through sanctions and export controls. John and Elliot discuss some key elements of the sanction programs and how they have performed since being imposed.

Career agency official back over the progression of financial fraud from the Savings & Loan crisis to today. Jim Vivenzio, now with Perkins Coie LLP, provides insight on the state of the financial industry responding to the myriad of challenges they face.

John and Elliot discuss several items this week, including a posting by the International Consortium of Investigative Journalists (ICIJ), a comment letter by a group of bank trade associations on the FinCEN Beneficial Ownership Registry proposal, and the announcement that the Organized Crime and Corruption Reporting Project (OCCRP) has been nominated for the Nobel Peace Prize.

The Wolfsberg Group and the Institute of International Finance have issued a joint comment letter to the European Banking Authority on de-risking. John and Elliot discuss the details of the comment letter, including its recommendation that the EBA adopt definitions and other approaches on de-risking taken by FATF, as the EBA works toward updating its AML/CFT regime for the European Union.

Chief of the Internal Revenue Service’s Criminal Division (IRSCI) Jim Lee details the 2022 results of his “BSA Challenge” to his staff. The Challenge explores and explains the value to law enforcement of Bank Secrecy Act data---CTRs, SARs, CMIRs, FBARS and Form 8300’s.

This week Transparency International released its 2022 Corruption Perceptions Index (CPI). The CPI uses a number of criteria to evaluate the status of corruption in 180 countries. For 2022 the global average remained unchanged at 43 on a 100 point scale. The report shows that 124 countries have not made any change since 2021 and the number of countries declining has increased. John and Elliot discuss some of the findings in the CPI and the links between corruption, deterioration in human rights, the rise of authoritarianism, and the continuing assault on democracy.

his week a retired senior FBI agent Charles McGonigal was arrested on charges of money laundering and violating US sanctions. Also this week, the Financial Crimes Enforcement Network (FinCEN) issued an alert on Potential U.S. Commercial Real Estate Investments by Sanctioned Russian Elites, Oligarchs, and Their Proxies. John and Elliot discuss the arrest and its implications for national security and look at the details of the alert including the typologies and red flags included in it. They also examine McGonigal’s relationship to a sanctioned Russian oligarch and efforts by other sanctioned oligarchs to us real estate transactions to hide and preserve their wealth.