AML Conversations

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.