AML Conversations

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.

Joe McNamara sits in for Elliot Berman this week alongside John Byrne. Joe and John discuss the Senate vote that failed to advance the Clarity Act, the interagency proposal to rescind and replace third-party risk management guidance, and the CJEU ruling on Latvia's public shareholder disclosure law and what it signals for beneficial ownership transparency. They also cover the DOJ indictment of a Russian intelligence services network, the Manhattan DA's seizure of 12 deepfake websites and the payment infrastructure behind them, Transparency International's analysis of seven years of EU rule of law reporting, and OFAC's designation of VTB Bank under Operation Economic Outcast. They close with CSIS's look at the terrorism landscape 25 years after 9/11, the shift toward lone actor threats, and the underused potential of 314(a) and 314(b) information sharing.

Resources mentioned in this episode:

Senate cloture vote on the Clarity Act: https://www.cnbc.com/2026/09/15/senate-cloture-vote-on-clarity-act-fails-dealing-regulatory-setback-...
Proposed interagency third-party risk management guidance: https://www.federalregister.gov/documents/2026/09/15/2026-18859/proposed-third-party-risk-management...
CJEU ruling on Latvian shareholder disclosure (Case C-798/24): https://cyprus-mail.com/2026/09/13/european-court-decides-on-public-access-to-shareholder-informatio...
DOJ release on the Russian intelligence services network indictment: https://www.justice.gov/opa/pr/members-russian-intelligence-services-network-charged-conspiring-fina...
Manhattan DA seizure of 12 deepfake websites: https://manhattanda.org/manhattan-d-a-s-office-seizes-domains-of-12-illegal-websites-selling-ai-gene...
Transparency International, Anti-Corruption Gaps Are Leaving Democracy in Europe Exposed: https://www.transparency.org/en/news/anti-corruption-gaps-leaving-democracy-europe-exposed
Treasury designation of VTB Bank under Operation Economic Outcast: https://home.treasury.gov/news/press-releases/sb0629/
Riley McCabe, CSIS, Adapting to the New Terrorism Landscape 25 Years After 9/11: https://www.csis.org/analysis/adapting-new-terrorism-landscape-25-years-after-911
ProPublica reporting on the Trump Jr. wedding financing: https://www.propublica.org/article/donald-trump-jr-wedding-bankrolled-russian-oligarch-umar-kremlev-...

This week, John Byrne and Elliot Berman examine a wave of regulatory and enforcement developments shaping the AML landscape. Topics include new U.S. Treasury sanctions targeting Iran's aviation sector, FinCEN's renewal of Southwest Border Geographic Targeting Orders, guidance on SAR confidentiality, and growing concerns over digital asset scams and cryptocurrency regulation. They also discuss FATF's latest reports on underground banking networks, money-laundering risks in the gambling sector, and AUSTRAC's enforcement actions against remittance and crypto firms.

In recognition of the 25th anniversary of 9/11, the conversation turns to the lasting impact the attacks had on anti-money laundering, counter-terrorist financing, and public-private partnerships. John and Elliot reflect on how the Patriot Act transformed financial crime prevention, why collaboration between financial institutions and law enforcement remains essential, and the importance of ensuring future generations understand the role AML professionals play in protecting the financial system.

Twenty-five years after the attacks of September 11, 2001, John Byrne sits down with Dennis Lormel, who led the FBI's Financial Crimes Program on 9/11 and stood up the Bureau's first Terrorist Financing Operations Section (TFOS) in its aftermath. Dennis shares his firsthand account from inside FBI headquarters that morning, the plan he wrote that night for a centralized financial investigation, and the unprecedented cooperation from banks and government agencies that followed. The conversation covers the warning signs that preceded the attacks, the three-week passage of the PATRIOT Act, the findings of the 9/11 Commission and its terrorist financing monograph, FATF's special recommendations, and the unintended consequences for charities. Dennis closes with an assessment of the threat landscape in 2026 and a call for the proactive, imaginative use of financial intelligence. As this episode marks both the 25th anniversary of 9/11 and the 25th anniversary of counter-terrorist financing, one theme carries throughout: never forget.