John Byrne


By John Byrne | August 28, 2019

4th Quarter of 2019—What will it take for useful action? As we approach the Labor Day weekend and the unofficial end to summer, the 2019 calendar turns to last opportunities for any successes that can be tied to this year. For the AML community, the standard calendar year doesn’t impact our work but it can dictate things such as legislation, regulation or sometimes policy. AML reform, for example, can still occur in 2020 since we…

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Can you take “statements” to the bank? Risk-Focused BSA? “Showdown.”*

By John Byrne | August 2, 2019

“Banks that operate in compliance with applicable law, properly manage customer relationships and effectively mitigate risks by implementing controls commensurate with those risks are neither prohibited nor discouraged from providing banking services.” (From the July 22nd Statement) “Governments and banking regulators should focus on ways they can send an appropriate message that not all NPOs are high-risk and that, with proper due diligence, FIs can open bank accounts for NPOs and provide them with banking…

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We Can Change the World*

By John Byrne | June 28, 2019

Working together always works While I have always believed that what we do in the AML community makes a difference, the past two years (at least) have seen the expansion of challenges that demand proactivity. When we work together with groups outside of AML toward a common goal, our impact can be immeasurable. A perfect example is a webinar I participated in this week with the Charity & Security Network on “Tips for Successful Banking…

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Work to Do*

By John Byrne | May 28, 2019

How to Assess Corporate Compliance: DOJ weighs in…   While the debate continues on what role “guidance” plays in compliance, it is clear that we ignore what agencies say at our regulatory peril. Recent Department of Justice guidance adds more information for us to consider as we grapple with improving compliance throughout an institution. AML professionals are well aware of the 2014 advisory from FinCEN on promoting a culture of compliance and it has certainly…

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Where do we go from here?*

By John Byrne | May 13, 2019

House moving on AML Reform—Can it both occur, and be valuable this year?! Since the enactment of the Money Laundering Control Act in 1986, the United States has added, without ever eliminating, a myriad of requirements on the private sector (mainly the financial sector) regarding the detection and reporting of financial crime. Our AML community has consistently called for a comprehensive review of this infrastructure to improve efficiency, set realistic regulatory expectations, and actually fulfill…

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Don’t Come Around Here No More*

By John Byrne | May 3, 2019

Looting and Trafficking of Cultural Artifacts and Art Enables Terrorism (and many other crimes) In February 2015, the FATF pointed out: “Reports on the smuggling of cultural artefacts by ISIL are limited, given that they are sold on the black market.  ISIL’s ability to earn revenue from the illicit sale of antiquities is contingent upon the presence of antiquities within territory where ISIL operates, knowledge of their existence, and ISIL’s ability to recognize materials as…

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Beware of Darkness*

By John Byrne | March 26, 2019

AML legislation as a light? Despite universal A.D.D. in all aspects of policy debate, and the consistent chase for the shiny object, for the first time in years there seems to be an appetite for AML reform, or at least partial change. After attending two programs and watching a House hearing in the past two weeks, I wanted to identify some areas that may see some actual movement. Bipartisanship—Really? I have realized over time that…

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What Were Once Vices Are Now Habits*

By John Byrne | February 26, 2019

A review of “Dark Commerce” Age old corruption still exists and is really part of the economic fabric One of the most interesting parts of the very broad-based AML (anti-money laundering) community is how much we are challenged with and how much we can still learn. Years ago, a compliance officer or policy professional only needed to know about some very basic recordkeeping and reporting and most of the crimes being identified were related to…

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“Do you want to know a secret?”

By John Byrne | February 19, 2019

One of the most essential activities the AML community can engage in is sharing information, best practices and expertise on the myriad of challenges facing all of us. We at AML RightSource saw that, up close and personal, in late 2018 when we held a closed-door symposium with clients, AML peers and other global experts. In a way, the symposium was modeled after a process I originated while at ACAMS— taking the age-old notion of…

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By John Byrne | January 30, 2019

Beginnings* Only just a start Congress starts on a bipartisan basis There have been a few posts and stories (to say the least) about how the change in power in the US congress in 2019 can impact the financial community. With the potential for investigations on everything from consumer abuse to compliance deficiencies and any other scandals, the AML community ignores the legislative branch at their peril. For several previous sessions, it was easy to…

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