In this episode of AML Conversations, John Byrne is joined by Sarah Beth Felix, author of Dirty Money Weekly, for an in-depth discussion on the evolving state of AML and BSA reform. Recorded at the close of April, the conversation examines FinCEN’s proposed AML program rule, with a critical look at how concepts like “effectiveness,” “risk-based approach,” and “reasonably designed” are used—and often left undefined.

Sarah and John also dig into FinCEN’s latest annual report, ongoing challenges with SAR data and form design, and what proposed changes could mean for enforcement consistency and regulatory bottlenecks. The episode explores emerging issues, including the PACE Act, AML model validation, and what meaningful modernization of the Bank Secrecy Act should prioritize ahead of an upcoming congressional hearing on BSA reform.