AML Conversations

AI is everywhere in financial crime compliance - but is it delivering on its promises?
In this episode of AML Conversations, host Joe McNamara and Mark Sully, Managing Director of Commercial Affairs for EMEA and APAC, dive into the escalating challenges of sanctions screening and geopolitical risk in financial crime compliance. They explore how rapidly shifting sanctions lists, surging alert volumes, and dual-use goods are straining compliance teams - and what institutions are doing about it. From list management and false positive reduction to augmenting analyst workflows with AI, the conversation maps out a pragmatic path forward that balances technology adoption with operational reality.

In this week’s This Week in AML, Elliot Berman and John Byrne break down FinCEN’s newly released notice of proposed rulemaking to modernize the AML/CFT program rule—its first major rethink in two decades. They explore what a risk-based refocus could mean in practice, including new requirements for risk assessments, changes to the four pillars, examiner discretion, and the unprecedented requirement that bank regulators consult with FinCEN before certain enforcement actions.

The conversation also covers a flurry of regulatory and enforcement developments: the OCC’s GENIUS Act proposal on stablecoins, the removal of reputation risk from bank examinations, and what both could mean for smaller financial institutions. Elliot and John look back at the 10-year anniversary of the Panama Papers, review the FBI’s 2025 Internet Crime Report, and discuss global enforcement challenges—from scam centers in Southeast Asia to resource constraints at foreign FIUs.

AML RightSource's John Byrne sits down with Dan Stipano, partner at Davis Polk's Financial Institutions and Regulation Group and former Deputy Enforcement Director at the OCC, for an immediate reaction to FinCEN's newly proposed AML/CFT Program Rule. The conversation covers the genesis of the proposal and its key structural changes — including the bifurcation of program establishment and implementation, the formal incorporation of national AML priorities, and the clarification of the US-based compliance officer requirement. Most notably, the two dig into what may be the rule's most consequential provision: FinCEN's unprecedented new role as a gatekeeper over federal banking agency supervisory and enforcement actions. They also touch on a separate final rule from the OCC, the Fed, and the FDIC that eliminates reputational risk from the supervisory framework and what that means for banks' account decisions going forward.

In this episode of AML Conversations, host Joe McNamara and Mark Sully, Managing Director of Commercial Affairs for EMEA and APAC, turn their focus to the unique compliance challenges facing crypto firms. They explore how crypto's speed and risk appetite create gaps between promised and delivered technology outcomes, why efficiency gains from AI are real but often overstated, and what "having a backup plan" actually looks like in a 24/7, never-sleeping market. The conversation also touches on the growing convergence of crypto, stablecoins, and traditional finance - and what that means for governance and oversight.

In this episode, Elliot Berman and John Byrne break down a wide‑ranging set of regulatory and enforcement developments shaping the global financial crime landscape. The conversation covers major U.S. bank settlements tied to the Epstein litigation, a closely watched Capital One debanking case involving Trump‑affiliated entities, and key overseas actions—from Australia’s expanded AML regime to the UK’s sanctions enforcement against Apple and a massive scam operation in Cambodia.

The discussion also dives into the OECD’s latest anti‑bribery report, FinCEN’s proposed whistleblower award program, emerging healthcare fraud typologies, and renewed concerns over the weakening of the U.S. Corporate Transparency Act. Wrapping up, Elliot and John assess developments tied to FATF’s mutual evaluation of the United States, nonprofit de‑risking, and new OFAC guidance on sham transactions—offering critical context for compliance professionals navigating a rapidly shifting risk environment.