AML Conversations AML RightSource

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.