AML Conversations

The AML landscape continues to evolve as political, regulatory, and technological developments reshape compliance expectations around the world. In this episode, John Byrne and Elliot Berman discuss the potential impact of the U.S. midterm elections on financial crime oversight, including possible congressional scrutiny of artificial intelligence, cryptocurrency, and corruption-related issues. The conversation explores the OCC's newly released framework for evaluating banks' use of AI, emphasizing the regulator's position that AI should not be treated as a separate risk category while still requiring strong governance and risk management practices. They also examine the reported $6.3 billion Binance hack, the ongoing cybersecurity risks facing digital asset platforms, and the broader implications for crypto regulation and oversight. Additional topics include key outcomes from the latest FATF plenary, updates to the FATF gray list, new anti-corruption guidance from the United Nations Office on Drugs and Crime, and fresh guidance from the Egmont Group on FIU independence and autonomy. The hosts also review developments in Germany's AML supervision framework, concerns surrounding the State Department's latest Trafficking in Persons Report, AML enforcement actions in New Zealand, and an SEC fraud case involving falsified regulatory filings that raised more than $130 million from retail investors.

This week, John Byrne and Elliot Berman reflect on the 40th anniversary of the Money Laundering Control Act of 1986, the landmark legislation that helped shape modern anti-money laundering compliance in the United States and influenced global AML standards. The conversation also examines a series of corruption-related developments, including investigations involving political figures in Brazil and the United States, concerns about the weakening of public corruption enforcement, and the launch of new civil society initiatives focused on accountability and the rule of law. John and Elliot explore why anti-corruption efforts remain essential to protecting democratic institutions, economic stability, and public trust. Additional topics include leadership changes at the Egmont Group, calls for a U.S. national fraud strategy, and a multistate legal challenge seeking to restore key provisions of the Corporate Transparency Act.

Understanding who truly owns and controls a third party is becoming increasingly important for organizations managing risk, compliance, and due diligence obligations. In this episode of Third Party Risk Perspectives, Elliot Berman of AML RightSource is joined by Christopher Sindik and Sudip Iyer from Blue Umbrella to discuss the growing role of Ultimate Beneficial Ownership (UBO) intelligence in third-party risk management. The conversation explores why ownership transparency matters, how hidden ownership structures can conceal sanctions exposure, corruption risk, connections to organized crime, or other reputational concerns, and why understanding ownership is about much more than simply identifying a legal entity. Chris and Sudip explain the challenges organizations face when gathering UBO data across jurisdictions with differing disclosure requirements, the impact of evolving regulations, and the practical realities of using corporate registries, commercial databases, and investigative research to uncover ownership structures. The discussion also examines how organizations can integrate UBO intelligence into broader third-party risk management programs by combining ownership analysis with sanctions screening, adverse media monitoring, and risk-based decision-making. Whether you're navigating new markets or strengthening your compliance framework, this episode offers practical insights to help you stay ahead of emerging third-party risks.

This week on This Week in AML, John Byrne and Elliot Berman examine several significant developments shaping the financial crime compliance landscape. The episode highlights FATF's upcoming consultation on information sharing, a topic with major implications for public-private partnerships, cross-border collaboration, and the future effectiveness of AML programs. The hosts also discuss reports of a proposed U.S.-Russia diesel fuel arrangement, new concerns involving Iran, and the broader sanctions implications for compliance professionals. Additional topics include the FCA's estimate that fraud in the UK exceeded £220 billion, forthcoming crypto registration requirements, new AI risk management guidance from the Monetary Authority of Singapore, and congressional questions surrounding FinCEN's AML/CFT priorities and the Corporate Transparency Act rollback. The episode concludes with breaking news: a record enforcement action against Bank of America, including a reported $1.21 billion penalty involving BSA/AML, sanctions, and suspicious activity reporting failures.

This week on This Week in AML, John Byrne and Elliot Berman unpack a wide-ranging set of developments affecting compliance, sanctions, financial crime prevention, and regulatory oversight. From geopolitical controversies surrounding Russia sanctions and international enforcement efforts to the OCC's latest report on so-called "de-banking," the discussion examines what these developments mean for financial institutions trying to maintain a risk-based approach in an increasingly politicized environment. The conversation explores the OCC's recommendations on customer access to banking services, concerns about regulatory whipsawing between administrations, and the potential implications for AML officers, boards, and senior management. John and Elliot also review New York's $33 million enforcement action against SEB, highlighting the continued importance of state-level AML enforcement. Additional topics include FinCEN's alert regarding Iranian abuse of religious charity networks and newly identified suspicious activity tied to student aid fraud.

In this monthly regulatory roundup, John Byrne sits down with Sarah Beth Felix of Palmero Consulting to examine some of the most important AML, CTF, and sanctions developments from the past month. The conversation begins with a reflection on the 40th anniversary of the Money Laundering Control Act and its lasting impact on the compliance profession. Sarah breaks down the recent American Express enforcement action, highlighting overlooked risks in lending products, the connection between culture and compliance effectiveness, and why every element of a BSA/AML program ultimately supports suspicious activity reporting. The discussion also explores board oversight, indicators of effectiveness, and lessons financial institutions can take from major consent orders. The episode then turns to FINRA's latest enforcement action against Revere Securities, and FinCEN's decision to withdraw proposed cryptocurrency-related rules. The episode concludes with a candid conversation about artificial intelligence in AML compliance, including the promises, pitfalls, governance concerns, and the questions institutions should ask before relying on AI-driven monitoring and alert dispositioning.

In this week's episode of This Week in AML, John Byrne is joined by Joe McNamara, filling in for Elliot Berman, to flag a wide range of global and domestic developments. They open with OCCRP reporting on an Uzbek security official who secretly acquired Emirati citizenship and millions in Dubai real estate, then turn to New York Times reporting on conflict of interest questions in U.S.-Russia talks on Ukraine. The conversation then shifts to FinCEN's unusual withdrawal of two proposed rules targeting unhosted wallet transactions and convertible virtual currency mixing, and what that means for institutions with crypto exposure whose SAR obligations remain unchanged. Additional topics include the Comptroller of the Currency's fraud roundtable with community bankers in Minneapolis, the Department of Justice's new memorandum on corporate fraud enforcement, and the first reported AI agent-powered intrusion into major South Korean banks. The episode closes with a preview of the October 22nd webinar on best practices in managing high-risk customers. Resources Referenced in This Episode: OCCRP: The Uzbek President's Son-In-Law Secretly Acquired a UAE Passport While Serving as a Top Security Chief The New York Times: U.S.-Russia Talks on Ukraine and the Kushner and Witkoff Oil Deal Federal Register: Proposal of Special Measure Regarding Convertible Virtual Currency Mixing, as a Class of Transactions of Primary Money Laundering Concern; Withdrawal Federal Register: Requirements for Certain Transactions Involving Convertible Virtual Currency or Digital Assets; Withdrawal OCC: Comptroller Gould Community Bank Fraud Roundtable in Minneapolis https://www.occ.gov/news-issuances/news-releases/2026/nr-occ-2026-86.html U.S. Department of Justice: Directive 26-12, Corporate Enforcement in the Fight Against Fraud https://www.justice.gov/opa/media/1463571/dl?inline The Wall Street Journal: Hackers Use Chinese AI Tool to Hit South Korean Banks, Exposing New Risk Marquette University Center for Peacemaking: AI and Ethics with Dr. Michael Zimmer AML RightSource: AML Voices Webinar: Best Practices in Managing Your High-Risk Customers

In this week's episode of This Week in AML, John Byrne and Elliot Berman examine Canada's newly released FATF mutual evaluation and what it may signal as the AML community awaits the upcoming U.S. assessment. They discuss FinCEN's plans to amend customer due diligence requirements related to immigration status verification, highlighting the operational and compliance challenges that institutions may face. The conversation also explores escalating concerns surrounding artificial intelligence, including congressional calls for stronger oversight, emerging state-level initiatives, and recent reports of AI-enabled fraud targeting financial institutions. Additional topics include proposed stablecoin regulations under the GENIUS Act, new tools for measuring corruption, sanctions targeting criminal organizations, cybersecurity lessons from the reported FBI data breach, and outgoing SEC Commissioner Hester Peirce's critique of AML and KYC frameworks.

In this week's episode of This Week in AML, Elliot Berman and John Byrne examine how workforce reductions at the OCC could affect bank supervision at a time when new national bank charters are on the rise. They also discuss the OCC's updated cybersecurity supervision framework and its implications for financial institutions. The conversation then turns global, highlighting a new Egmont Group report on strategic intelligence, the role of Financial Intelligence Units in combating money laundering and terrorist financing, and lessons organizations can apply to their own compliance programs. Additional topics include emerging state-level AI regulation in New York and California, and allegations that a Kremlin-linked fintech network used forged documentation to move billions through the global financial system.

In this episode of AML Conversations, host John Byrne sits down with former federal prosecutor, 9/11 Commission staff member, and former Department of Homeland Security Inspector General John Roth to discuss the evolution of terrorist financing controls, the challenges facing anti-money laundering professionals, and the critical role inspectors general play in promoting accountability across government. Drawing on his work co-authoring the 9/11 Commission’s terrorist financing monograph and his experience at DHS, Roth reflects on how AML and CTF frameworks have changed since 9/11, why financial institutions have made significant progress, and why emerging threats such as cryptocurrency, prediction markets, and changes to beneficial ownership transparency continue to present challenges. The conversation then turns to government oversight and Roth’s recent work on restoring the independence of inspectors general. He explains why independent watchdogs are essential to uncovering waste, fraud, abuse, and misconduct, and shares his concerns about the removal of inspectors general, reduced oversight capacity, and the importance of congressional engagement and public awareness.