AML Conversations AML RightSource

This week, the White House released a new National Security Memorandum on Critical Infrastructure Security and Resilience. The Attorney General recommended reducing restrictions on marijuana. Global Financial Integrity and several other organizations released a report identifying 25 cases in which illegal, allegedly illicit, or suspicious funds were funneled into commercial property in the US. John and Elliot discuss these and other events of the week that are important to members of the global financial crime prevention community.

This week, John and Elliot discuss several items issued by FinCEN, including elder financial abuse and environmental crime, Treasury Undersecretary Nelson’s visit to Puerto Rico, and BaFin’s fining of Commerzbank.

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.