AML Conversations

In this episode of This Week In AML, Joe McNamara fills in for Elliot Berman and joins John Byrne for a packed week of AML news on both sides of the Atlantic. The conversation opens with the fallout from Treasury and FinCEN's final rule eliminating domestic beneficial ownership reporting under the Corporate Transparency Act, then moves to Transparency International's guidance for EU member states that have not yet published a national anti-corruption strategy. Ireland, one of the six late adopters named in that report, has now released its first national AML/CFT/CPF strategy, and John walks through its five strategic goals and three pillars ahead of AMLA supervision and FATF evaluation.

The hosts also cover the UN Security Council's 38th Monitoring Team report on ISIL, AMLA's warning that money laundering in the EU property sector could deepen the housing crisis, and the OCC's conditional approval of a national trust bank charter for World Liberty Trust Company, along with the sharp objections raised by Senator Elizabeth Warren and others over conflicts of interest. Stateside, they close on Treasury: an unreleased internal report on the risks of an AI bubble, and the department's public request for comment on GENIUS Act implementation. John rounds out the episode with a $165 million crypto Ponzi indictment reported by OCCRP.

Links Referenced
Transparency International, Good Practices for National Anti-Corruption Strategies in EU Member States: https://knowledgehub.transparency.org/helpdesk/good-practices-for-national-anti-corruption-strategie...
Ireland Department of Finance, Ireland's First National Anti-Money Laundering Strategy: https://www.gov.ie/en/department-of-finance/press-releases/t%C3%A1naiste-and-minister-for-finance-si...
UN Security Council, 38th Report of the Analytical Support and Sanctions Monitoring Team (S/2026/651): https://docs.un.org/en/S/2026/651
AML Intelligence, AMLA Urges Crackdown on Money Laundering in EU Property Sector: https://www.amlintelligence.com/2026/08/news-amla-urges-crackdown-on-money-laundering-in-eu-property...
OCC, Conditional Approval for World Liberty Trust Company (CD 1385): https://www.occ.gov/topics/charters-and-licensing/interpretations-and-decisions/2026/cd1385.pdf
NOTUS, Treasury Internal Report Warns of the Dangers of an AI Bubble: https://www.notus.org/economy/treasury-internal-report-warning-dangers-ai-bubble?utm_source=content_...
U.S. Treasury, Request for Public Comment on GENIUS Act Implementation: https://home.treasury.gov/news/press-releases/sb0605

John Byrne is joined by Sarah Beth Felix, author of Dirty Money Weekly, for their monthly conversation on financial crime developments. They start with FinCEN's final rule ending Corporate Transparency Act reporting and what it means in practice: the detection burden for shell companies shifts back to financial institutions, the CDD rule remains in force, and beneficial ownership data belongs in SAR backup documentation to support law enforcement. Sarah Beth shares practical red flags for spotting shell companies, from formation mill documents to companies with no online presence and unexplained revenue.

The conversation then turns to the Wise enforcement action and why a clean exam history is the wrong benchmark for a compliance program, including the OCC's pointed finding that leadership lacked financial crime expertise at the board level. They also discuss the Capital One litigation and the safety risks of demands to identify individual investigators, and close on the operational obstacles AML teams face in responding to the executive order on credit risk and illegal immigration, where citizenship indicators are buried across lending and deposit systems that financial crime teams rarely see.

In this episode of This Week in AML, Elliot Berman and John Byrne break down FinCEN's final rule eliminating beneficial ownership reporting requirements for millions of small businesses and discuss what the move means for AML compliance, transparency, and financial crime prevention.

The conversation also explores the renewal of FinCEN's Minnesota Geographic Targeting Order and the growing debate over whether the U.S. is experiencing a true fraud crisis, including insights from Jonathan Rusch's recent analysis of federal fraud enforcement efforts.

Beyond the U.S., the hosts examine OCC concerns that led to the rejection of a European fintech's national bank charter application, the Luxembourg FIU's new authority to freeze fraud-linked payments, developments surrounding European beneficial ownership registries, Russia's reported sanctions-evasion payment network, and Australia's enforcement action against a major cryptocurrency ATM operator. The episode concludes with a discussion of a new de-risking resource for nonprofits.

This week on This Week in AML, John Byrne and Elliot Berman examine FinCEN's record-setting $125 million enforcement action against UBS, the largest civil money penalty ever imposed against a broker-dealer for Bank Secrecy Act violations. They discuss what made the case significant, the consequences of repeated compliance failures, and the lessons financial institutions should take from the enforcement action.

The conversation also covers FinCEN Director Andrea Gacki's departure for Citibank and what the appointment of Acting Director Jenna Casanova could mean for future enforcement priorities.

John and Elliot then explore Senator Ron Wyden's report on financial institutions' handling of Jeffrey Epstein-related accounts, including proposed changes to suspicious activity reporting requirements and concerns about SAR confidentiality. They also review Capital One's defense of account closures tied to AML obligations and the broader debate surrounding claims of "debanking."

Internationally, the hosts discuss the FCA's planned overhaul of transaction reporting requirements in the UK, ongoing challenges in accessing beneficial ownership registries across the European Union, and Transparency International's push for stronger global anti-corruption measures.

In this episode of This Week in AML, John Byrne and Elliot Berman unpack several significant developments across the AML, sanctions, fraud, and compliance landscape.

They begin with the U.S. Senate's overwhelming bipartisan vote to advance new Russia and Iran sanctions legislation, then turn to FinCEN Director Andrea Gacki's recent congressional testimony, including her emphasis on fraud prevention, BSA modernization, SAR guidance, and the industry's ongoing uncertainty about AML priorities and effectiveness standards.

The conversation also explores Transparency International's 2025 achievements in advancing anti-corruption reforms worldwide and raises important questions about whether corruption will remain a formal U.S. AML priority. John and Elliot review FinCEN's new alert on financial student aid fraud, discuss the continued role of shell companies in fraud schemes, and examine a House Financial Services Committee report on scams and fraud.

Additional topics include Treasury's review of the SDN List, the growing industry around sanctions delisting petitions, the closure of crypto exchange BitMEX despite presidential pardons for its founders, the OCC's denial of Wise US's national trust charter application due to AML compliance concerns, and new reporting linking crypto-to-cash storefronts to money laundering activity.