John Byrne

Will 2020 bring true AML Reform?

By John Byrne | January 7, 2020

“For what it’s worth,[1]” corruption is the key. Thirty-four years after the passage of the Money Laundering Control Act of 1986, (the real start of the current AML infrastructure we face today), our community has seen a plethora of laws, regulations, guidance and examiner subjectivity. The result: confusion, unending cost overruns and competing noise on how to fix a truly broken system; not broken because the private sector should not have a law enforcement role…

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The Song Remains the Same*

By John Byrne | November 6, 2019

AML Professionals simply want the BSA to work.. Whether in open hearings before Congress, at conferences, or in closed-door sessions such as our recent AML RightSource Symposium, when AML community leaders discuss their challenges, the themes are constant—the bifurcated nature of the Bank Secrecy Act prevents success. Success, as has been defined many times, is to get information into the hands of law enforcement. Over the course of the day, the group of AML leaders…

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The Heat is On*

By John Byrne | October 2, 2019

AML Reform needs all of us – this year or hopefully next We know that the current 116th Congress has another year before it is over; still there remains some speculation that the various AML bills in the House and Senate could move before the 2019 recess. While last week’s dramatic announcement of the start of an impeachment inquiry could prevent any legislative movement, the formal introduction in the Senate of the “Illicit Cash Act”…

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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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