AML Conversations is dedicated to inform professionals and those interested in anti-money laundering about conversations happening in the government, private sector, and internationally. Throughout the series John Byrne, AML RightSource Vice Chairman, will interview industry experts or participate in live programming or panel discussions related to the industry.
What Do A Retired FBI Agent And Real Estate Have In Common?
his week a retired senior FBI agent Charles McGonigal was arrested on charges of money laundering and violating US sanctions. Also this week, the Financial Crimes Enforcement Network (FinCEN) issued an alert on Potential U.S. Commercial Real Estate Investments by Sanctioned Russian Elites, Oligarchs, and Their Proxies. John and Elliot discuss the arrest and its implications for national security and look at the details of the alert including the typologies and red flags included in it. They also examine McGonigal’s relationship to a sanctioned Russian oligarch and efforts by other sanctioned oligarchs to us real estate transactions to hide and preserve their wealth.
Human Smuggling Along the US Southwest Boarder – A FinCEN Alert
The Financial Crimes Enforcement Network (FinCEN) issued an alert focused on human smuggling along the southwest board of the US. John and Elliot review the major elements of the alert – including SAR filing guidance, red flags, and the difference between human smuggling and human trafficking. They also discuss the importance of financial services companies partnering with law enforcement to identify and prevent the terrible global crime.
Eurasia Group’s Top Risks for 2023
The Eurasia Group, a consultancy focusing on political risk, has published its Top Risks - 2023. John and Elliot look at the purpose of the report and how it can be helpful to the financial crime compliance community in assessing and managing risk. They also discuss some of the specific risks called out in the report.
US Banking Agencies Increase Their Focus on Crypto-Assets
The primary US bank regulators - the Federal Reserve, FDIC, and OCC - issued a joint statement on crypto-asset risks to banking organizations. The statement lists several risks on which the regulators are focusing. John and Elliot discuss some of the risks and speculate on where regulators may be heading in this space.
FATF Updates its Guidance on the Real Estate Sector (Archive Edition)
This episode originally aired on July 29, 2022.
The Financial Action Task Force (FATF) recently issued updated Guidance for a Risk-Based Approach to the Real Estate Sector. The updated guidance focuses on the importance of member countries to bring the real estate sector into their money laundering/terrorist financing regimes. John and Elliot discuss the guidance, including the breadth of its coverage, the need for understanding and training of real estate professionals, and how the timing of the guidance intersects with FinCEN’s request for information about the sector.
Basel AML Index 2022 – Moving Backward (Archive Edition)
This episode originally aired on October 7, 2022.
This week, the Basel Institute on Governance published its 2022 AML Index. The index assesses countries’ money laundering and terrorist financing risks and capacity to counter them. John and Elliot chat about how the index is constructed, what it says about the state of the global response to these risks, and other key take-aways from this year’s report.