AML Conversations

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.

In this episode of AML Conversations, host John Byrne welcomes Tess Davis, Executive Director of the Antiquities Coalition, for a timely discussion on the intersection of cultural heritage crime and financial crime. From the looting of museums and archaeological sites in conflict zones such as Ukraine and Sudan to the exploitation of the global art market for money laundering and sanctions evasion, Tess explains why antiquities trafficking is far more than a cultural issue—it is a financial crime issue.

The conversation explores the Rome Statement on Art Market Integrity, the growing role of law enforcement agencies like the Manhattan District Attorney's Antiquities Trafficking Unit, and bipartisan efforts in the United States to bring the art market under the AML regulatory framework. Tess also shares real-world examples of how stolen artifacts are laundered into legitimate collections and outlines key red flags financial institutions should understand when assessing risks tied to art and antiquities transactions.

This episode offers valuable insights into a rapidly evolving threat landscape and the collaborative efforts underway to combat it.

This week on This Week in AML, Elliot Berman and Joe McNamara examine a series of reports and regulatory updates highlighting the growing sophistication of global financial crime.

The discussion begins with a new United Nations Office on Drugs and Crime (UNODC) threat assessment that details how Southeast Asia has become a hub for interconnected criminal ecosystems, with organized crime groups increasingly offering “fraud as a service” at enterprise scale. Elliot and Joe explore how criminal organizations are evolving from trafficking goods to operating highly sophisticated criminal services businesses.

They also discuss FATF’s latest targeted update on virtual assets and VASPs, including concerns about stablecoins, regulatory gaps, and ongoing challenges in implementing the Travel Rule across jurisdictions. The conversation highlights how organized crime networks are leveraging crypto assets to move illicit funds globally.

The episode then turns to new guidance from the Wolfsberg Group on managing risks associated with non-bank payment service providers, AMLA’s growing focus on vulnerabilities in the non-financial sector, and ongoing concerns about real estate as a money-laundering vehicle.

In this week's episode of This Week in AML, John Byrne and Elliot Berman discuss the renewed push for a bipartisan U.S. sanctions bill targeting Russia and compare its approach to the European Union's existing sanctions framework. They also examine new guidance from federal banking agencies on lending to non-work authorized.

The conversation explores a notable difference in the Federal Reserve's proposed AML program rule, highlights key findings from Europol’s latest EU Terrorism Situation and Trend Report, and reviews a Transparency International report examining the illicit finance risks associated with cryptocurrency and stablecoins.

John and Elliot also discuss developments involving a high-profile IRS lawsuit and Florida's proposed designation of certain organizations as terrorist entities.