AML Conversations

This week The US Treasury issued a report, Assessing the Impact of New Entrant Non-bank Firms on Competition in Consumer Finance Markets. The report examines the current state of innovation and competition between banks and non-bank financial service providers and makes several recommendations. John and Elliot discuss key aspects of the report and the recommendations. They also talk about how the recent collapse of the cryptocurrency exchange FTX may influence the approach of legislators and regulators going forward.

The US Treasury and its Office of Foreign Assets Control (OFAC) have announced new sanctions against a number of individuals and entities involved in supplying illicit fentanyl and other illegal substances. The action was coordinated with the Netherlands and the UK. John and Elliot discuss the new sanctions and the importance of the multi-lateral cooperation which led to them.

The Financial Crime Enforcement Network (FinCEN) has issued its Ransomware Trends for the second half of 2021. John and Elliot look at the process that FinCEN used in its financial trend analysis and discuss some of the conclusions in the report, including that a significant number of ransomware attacks have some connection to actors in Russia.

Kateryna Boguslavska, PhD, Project Manager Basel AML Index at the Basel Institute on Governance, discusses the 2022 AML Index and some examples of recent metrics from Eastern Europe and other regions. Dr. Boguslavska also covers the importance of “effectiveness” in understanding jurisdictional risks.

View the 2022 report here - https://baselgovernance.org/basel-aml-index

The Center for Strategic and International Studies has released a report on Mitigating Financial Access Challenges. The report focuses on ways to overcome the difficulty faced by NGOs trying to transfer humanitarian funding to areas subject to sanctions or active counterterrorism measures. John and Elliot discuss the continued impact of de-risking, some of the prior work done on the problem, and examine some of the proposals to improve financial access laid out in the report.

AMLRS Advisory Board Member Nicolas Choules-Burbidge, formerly a senior executive at the Office of the Superintendent of Financial Institutions (OSFI) in Canada, where he started and oversaw the AML/CFT and Compliance Division (AMLC) for 15 years, discusses the 2021-2022 OSFI Report to Parliament and his views on AML supervision in Canada.

Jeff Pearlman, NY Times Best Selling Author of nine books and author of a new book, “The Last Folk Hero” about Bo Jackson, discusses the recent fraud in Mississippi with public funds that involves Brett Favre and his view on the challenge of local journalism today. https://jeffpearlman.com/

Jeff Pearlman, NY Times Best Selling Author of nine books and author of a new book, “The Last Folk Hero” about Bo Jackson, discusses the recent fraud in Mississippi with public funds that involves Brett Favre and his view on the challenge of local journalism today. https://jeffpearlman.com/

Homeland Security Investigations has launched Operation Boiling Point an initiative to curb organized retail crime and cargo theft. The effort brings together public and private organizations. John and Elliot discuss the importance of the focus on this challenge which impacts many levels of the economy. They also chat about the role for the financial crime compliance community in these activities.

This week the Office of Foreign Assets Control (OFAC) and the Financial Crimes Enforcement Network (FinCEN) issued enforcement actions against Bittrex, Inc., a virtual currency exchange. John and Elliot discuss the details of the two actions, including the general AML program failures and ineffective sanctions compliance efforts. They also talk about how other financial service providers can use the orders to check the status of their own sanctions and AML compliance programs.