AML Conversations

In this second part of our year-in-review series, Elliot Berman and John Byrne examine the major developments from July to December 2025. From Treasury’s delay of the investment advisor rule and the adoption of the GENIUS Act to the staggering $2 billion in crypto theft, the conversation covers critical shifts in financial crime prevention. They discuss staffing cuts at the State Department, EU fintech risk assessments, FATF’s new national risk assessment toolkit, and the humanitarian toll of sanctions. Other highlights include AMLA’s growing role in EU crypto oversight, AUSTRAC’s crackdown on casino compliance, and global enforcement trends. Plus, insights on OCC’s testimony signaling regulatory priorities for 2026 and FATF’s report on combating online child exploitation. Stay informed as we close out a turbulent year in compliance.

In this special year-end episode of This Week in AML, Elliot Berman and John Byrne look back at the first half of 2025—a period marked by sweeping changes and global challenges. From the surge in executive orders and controversial pardons in the U.S. to the EU’s Digital Operational Resilience Act and FATF updates, the discussion covers key developments shaping compliance. They explore DOJ’s shifting enforcement priorities, OCC’s growing influence on crypto and banking charters, debates over the Corporate Transparency Act, and the rising costs of AML compliance. Plus, insights on human trafficking detection, cybersecurity threats, and the resurgence of check fraud. This is your comprehensive recap of a chaotic year in financial crime prevention.

In this candid year-end conversation, John Byrne and Sarah Beth Felix dissect an unprecedented year in AML enforcement. Felix, President of Palmero Consulting and creator of "Dirty Money Weekly," describes what she sees as systematic dismantling of AML infrastructure despite stated priorities of combating fentanyl and transnational criminal organizations. With only four enforcement actions from traditional federal banking agencies compared to FINRA's 20+ penalties, the landscape has shifted dramatically. The discussion explores Treasury's proposal to give FinCEN veto authority over banking agency BSA decisions - a move Felix warns could create massive bottlenecks. They examine troubling patterns in recent OFAC sanctions penalties where entities disregard guidance while violations flow through traditional banks. Felix shares skepticism about AI replacing the "hyper suspicious" human judgment essential to AML work, noting AI tools consistently fail basic sanctions questions. The conversation addresses the stark gap between U.S. and European cryptocurrency regulation, with America applying 40-year-old money service business laws to digital assets while the EU has comprehensive frameworks like MiCA. Looking ahead to 2026, Felix urges AML officers to use reduced regulatory scrutiny strategically - eliminating legacy policies that waste time while remembering everything missed now can trigger future enforcement. She emphasizes focusing on cartels and foreign terrorist organizations, which now carry criminal liability for banking officers, and proactively auditing customer sanctions programs.

In this episode of This Week in AML, Elliot Berman and John Byrne unpack the latest developments in financial crime compliance. They discuss the U.S. Court of Appeals decision upholding the Corporate Transparency Act, new guidance from France’s TracFin on detecting shell companies, and FATF’s mutual evaluation of Belgium under its updated regime. The conversation also covers global civic space concerns, major enforcement actions in the U.S. and UK, IRS-CI’s annual report highlights, and the OCC’s conditional approval of crypto trust charters. Plus, breaking news on sanctions and fentanyl designations.

In this episode of AML Conversations, John Byrne discusses the evolving landscape of communication in the context of anti-money laundering (AML) and financial crime prevention with experts Justin Cole (First Pitch Communication) and Joe McNamara (AML RightSource). They explore the paradigm shift in how communication is integrated into investigations, the importance of legal considerations, the role of data verification, and the impact of investigative journalism. The conversation also delves into the ethical implications of using AI in communication and the future challenges facing the financial crime prevention space. Link to Justin's Article: https://www.amlintelligence.com/2025/10/insight-why-the-media-has-become-the-front-line-for-fighting...