AML Conversations

This week, John Byrne and Elliot Berman reflect on the 40th anniversary of the Money Laundering Control Act of 1986, the landmark legislation that helped shape modern anti-money laundering compliance in the United States and influenced global AML standards.

The conversation also examines a series of corruption-related developments, including investigations involving political figures in Brazil and the United States, concerns about the weakening of public corruption enforcement, and the launch of new civil society initiatives focused on accountability and the rule of law. John and Elliot explore why anti-corruption efforts remain essential to protecting democratic institutions, economic stability, and public trust.

Additional topics include leadership changes at the Egmont Group, calls for a U.S. national fraud strategy, and a multistate legal challenge seeking to restore key provisions of the Corporate Transparency Act.

Understanding who truly owns and controls a third party is becoming increasingly important for organizations managing risk, compliance, and due diligence obligations. In this episode of Third Party Risk Perspectives, Elliot Berman of AML RightSource is joined by Christopher Sindik and Sudip Iyer from Blue Umbrella to discuss the growing role of Ultimate Beneficial Ownership (UBO) intelligence in third-party risk management.

The conversation explores why ownership transparency matters, how hidden ownership structures can conceal sanctions exposure, corruption risk, connections to organized crime, or other reputational concerns, and why understanding ownership is about much more than simply identifying a legal entity.

Chris and Sudip explain the challenges organizations face when gathering UBO data across jurisdictions with differing disclosure requirements, the impact of evolving regulations, and the practical realities of using corporate registries, commercial databases, and investigative research to uncover ownership structures.

The discussion also examines how organizations can integrate UBO intelligence into broader third-party risk management programs by combining ownership analysis with sanctions screening, adverse media monitoring, and risk-based decision-making.

Whether you're navigating new markets or strengthening your compliance framework, this episode offers practical insights to help you stay ahead of emerging third-party risks.

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.