AML Conversations

In this monthly regulatory roundup, John Byrne sits down with Sarah Beth Felix of Palmero Consulting to examine some of the most important AML, CTF, and sanctions developments from the past month. The conversation begins with a reflection on the 40th anniversary of the Money Laundering Control Act and its lasting impact on the compliance profession.

Sarah breaks down the recent American Express enforcement action, highlighting overlooked risks in lending products, the connection between culture and compliance effectiveness, and why every element of a BSA/AML program ultimately supports suspicious activity reporting. The discussion also explores board oversight, indicators of effectiveness, and lessons financial institutions can take from major consent orders.

The episode then turns to FINRA's latest enforcement action against Revere Securities, and FinCEN's decision to withdraw proposed cryptocurrency-related rules. The episode concludes with a candid conversation about artificial intelligence in AML compliance, including the promises, pitfalls, governance concerns, and the questions institutions should ask before relying on AI-driven monitoring and alert dispositioning.

In this week's episode of This Week in AML, John Byrne is joined by Joe McNamara, filling in for Elliot Berman, to flag a wide range of global and domestic developments. They open with OCCRP reporting on an Uzbek security official who secretly acquired Emirati citizenship and millions in Dubai real estate, then turn to New York Times reporting on conflict of interest questions in U.S.-Russia talks on Ukraine.

The conversation then shifts to FinCEN's unusual withdrawal of two proposed rules targeting unhosted wallet transactions and convertible virtual currency mixing, and what that means for institutions with crypto exposure whose SAR obligations remain unchanged. Additional topics include the Comptroller of the Currency's fraud roundtable with community bankers in Minneapolis, the Department of Justice's new memorandum on corporate fraud enforcement, and the first reported AI agent-powered intrusion into major South Korean banks. The episode closes with a preview of the October 22nd webinar on best practices in managing high-risk customers.

Resources Referenced in This Episode:

OCCRP: The Uzbek President's Son-In-Law Secretly Acquired a UAE Passport While Serving as a Top Security Chief

The New York Times: U.S.-Russia Talks on Ukraine and the Kushner and Witkoff Oil Deal

Federal Register: Proposal of Special Measure Regarding Convertible Virtual Currency Mixing, as a Class of Transactions of Primary Money Laundering Concern; Withdrawal

Federal Register: Requirements for Certain Transactions Involving Convertible Virtual Currency or Digital Assets; Withdrawal

OCC: Comptroller Gould Community Bank Fraud Roundtable in Minneapolis https://www.occ.gov/news-issuances/news-releases/2026/nr-occ-2026-86.html

U.S. Department of Justice: Directive 26-12, Corporate Enforcement in the Fight Against Fraud https://www.justice.gov/opa/media/1463571/dl?inline

The Wall Street Journal: Hackers Use Chinese AI Tool to Hit South Korean Banks, Exposing New Risk

Marquette University Center for Peacemaking: AI and Ethics with Dr. Michael Zimmer

AML RightSource: AML Voices Webinar: Best Practices in Managing Your High-Risk Customers

In this week's episode of This Week in AML, John Byrne and Elliot Berman examine Canada's newly released FATF mutual evaluation and what it may signal as the AML community awaits the upcoming U.S. assessment. They discuss FinCEN's plans to amend customer due diligence requirements related to immigration status verification, highlighting the operational and compliance challenges that institutions may face.

The conversation also explores escalating concerns surrounding artificial intelligence, including congressional calls for stronger oversight, emerging state-level initiatives, and recent reports of AI-enabled fraud targeting financial institutions. Additional topics include proposed stablecoin regulations under the GENIUS Act, new tools for measuring corruption, sanctions targeting criminal organizations, cybersecurity lessons from the reported FBI data breach, and outgoing SEC Commissioner Hester Peirce's critique of AML and KYC frameworks.

In this week's episode of This Week in AML, Elliot Berman and John Byrne examine how workforce reductions at the OCC could affect bank supervision at a time when new national bank charters are on the rise. They also discuss the OCC's updated cybersecurity supervision framework and its implications for financial institutions.

The conversation then turns global, highlighting a new Egmont Group report on strategic intelligence, the role of Financial Intelligence Units in combating money laundering and terrorist financing, and lessons organizations can apply to their own compliance programs.

Additional topics include emerging state-level AI regulation in New York and California, and allegations that a Kremlin-linked fintech network used forged documentation to move billions through the global financial system.

In this episode of AML Conversations, host John Byrne sits down with former federal prosecutor, 9/11 Commission staff member, and former Department of Homeland Security Inspector General John Roth to discuss the evolution of terrorist financing controls, the challenges facing anti-money laundering professionals, and the critical role inspectors general play in promoting accountability across government.

Drawing on his work co-authoring the 9/11 Commission’s terrorist financing monograph and his experience at DHS, Roth reflects on how AML and CTF frameworks have changed since 9/11, why financial institutions have made significant progress, and why emerging threats such as cryptocurrency, prediction markets, and changes to beneficial ownership transparency continue to present challenges.

The conversation then turns to government oversight and Roth’s recent work on restoring the independence of inspectors general. He explains why independent watchdogs are essential to uncovering waste, fraud, abuse, and misconduct, and shares his concerns about the removal of inspectors general, reduced oversight capacity, and the importance of congressional engagement and public awareness.

Joe McNamara sits in for Elliot Berman this week alongside John Byrne. Joe and John discuss the Senate vote that failed to advance the Clarity Act, the interagency proposal to rescind and replace third-party risk management guidance, and the CJEU ruling on Latvia's public shareholder disclosure law and what it signals for beneficial ownership transparency. They also cover the DOJ indictment of a Russian intelligence services network, the Manhattan DA's seizure of 12 deepfake websites and the payment infrastructure behind them, Transparency International's analysis of seven years of EU rule of law reporting, and OFAC's designation of VTB Bank under Operation Economic Outcast. They close with CSIS's look at the terrorism landscape 25 years after 9/11, the shift toward lone actor threats, and the underused potential of 314(a) and 314(b) information sharing.

Resources mentioned in this episode:

Senate cloture vote on the Clarity Act: https://www.cnbc.com/2026/09/15/senate-cloture-vote-on-clarity-act-fails-dealing-regulatory-setback-...

Proposed interagency third-party risk management guidance: https://www.federalregister.gov/documents/2026/09/15/2026-18859/proposed-third-party-risk-management...

CJEU ruling on Latvian shareholder disclosure (Case C-798/24): https://cyprus-mail.com/2026/09/13/european-court-decides-on-public-access-to-shareholder-informatio...

DOJ release on the Russian intelligence services network indictment: https://www.justice.gov/opa/pr/members-russian-intelligence-services-network-charged-conspiring-fina...

Manhattan DA seizure of 12 deepfake websites: https://manhattanda.org/manhattan-d-a-s-office-seizes-domains-of-12-illegal-websites-selling-ai-gene...

Transparency International, Anti-Corruption Gaps Are Leaving Democracy in Europe Exposed: https://www.transparency.org/en/news/anti-corruption-gaps-leaving-democracy-europe-exposed

Treasury designation of VTB Bank under Operation Economic Outcast: https://home.treasury.gov/news/press-releases/sb0629/

Riley McCabe, CSIS, Adapting to the New Terrorism Landscape 25 Years After 9/11: https://www.csis.org/analysis/adapting-new-terrorism-landscape-25-years-after-911

ProPublica reporting on the Trump Jr. wedding financing: https://www.propublica.org/article/donald-trump-jr-wedding-bankrolled-russian-oligarch-umar-kremlev-...

This week, John Byrne and Elliot Berman examine a wave of regulatory and enforcement developments shaping the AML landscape. Topics include new U.S. Treasury sanctions targeting Iran's aviation sector, FinCEN's renewal of Southwest Border Geographic Targeting Orders, guidance on SAR confidentiality, and growing concerns over digital asset scams and cryptocurrency regulation. They also discuss FATF's latest reports on underground banking networks, money-laundering risks in the gambling sector, and AUSTRAC's enforcement actions against remittance and crypto firms.

In recognition of the 25th anniversary of 9/11, the conversation turns to the lasting impact the attacks had on anti-money laundering, counter-terrorist financing, and public-private partnerships. John and Elliot reflect on how the Patriot Act transformed financial crime prevention, why collaboration between financial institutions and law enforcement remains essential, and the importance of ensuring future generations understand the role AML professionals play in protecting the financial system.

Twenty-five years after the attacks of September 11, 2001, John Byrne sits down with Dennis Lormel, who led the FBI's Financial Crimes Program on 9/11 and stood up the Bureau's first Terrorist Financing Operations Section (TFOS) in its aftermath. Dennis shares his firsthand account from inside FBI headquarters that morning, the plan he wrote that night for a centralized financial investigation, and the unprecedented cooperation from banks and government agencies that followed. The conversation covers the warning signs that preceded the attacks, the three-week passage of the PATRIOT Act, the findings of the 9/11 Commission and its terrorist financing monograph, FATF's special recommendations, and the unintended consequences for charities. Dennis closes with an assessment of the threat landscape in 2026 and a call for the proactive, imaginative use of financial intelligence. As this episode marks both the 25th anniversary of 9/11 and the 25th anniversary of counter-terrorist financing, one theme carries throughout: never forget.

John Byrne and Elliot Berman discuss a busy week in the AML, sanctions, and compliance landscape. Topics include AUSTRAC's enforcement push under Australia's new AML laws and its investigation into Western Union, fresh guidance on politically exposed persons from the Hong Kong Monetary Authority, and the FBI's Art Crime Team's recovery of Egyptian cultural artifacts.

They also examine growing concerns surrounding prediction markets, conflicting federal court rulings involving Kalshi and Polymarket, new Treasury sanctions and proposed Section 311 action against a UAE-based bank, and the OCC and FDIC's significant changes to bank examination standards.

In this episode of AML Conversations, Brad Breslin, President and General Manager, Compliance Solutions at AML RightSource, sits down with Jeff Schlanger, former Manhattan prosecutor, institutional reformer, and author of "Doing Right: From Prosecutor to Reformer — A Journey Through Crime, Corruption, Complacency, and Change."

Jeff's career spans four decades on the front lines of accountability. He prosecuted the Westies and helped build the case against John Gotti. He served as the federal monitor overseeing the LAPD consent decree after the Rampart scandal. He later became the NYPD's first Deputy Commissioner for Risk Management, and he founded IntegrAssure to bring collaborative oversight to police departments nationwide, including the Aurora, Colorado consent decree.

The conversation explores what happens when institutions designed to do good drift off course, and what it takes to bring them back. Jeff shares the moment he discovered the FBI withheld knowledge of jury tampering during the Gotti trial, why he published his NYPD resignation letter, and how the Mickey Featherstone case taught him that doing right often means acting against your own interests.

For financial crime compliance and risk professionals, the lessons translate directly. Jeff draws the line from police reform to the HSBC monitorship, where he and Brad worked together, showing that the methodology of oversight, accountability, and continuous improvement is the same whether the rulebook is an LAPD procedures manual or the FFIEC guidelines.

Link to Jeff's book: https://doingright.integrassure.com/doing-right-homepage.html