John Byrne

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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Maybe there will be a balanced report on the state of money laundering… In the Year 2525*

By John Byrne | January 7, 2019

Every time a report is issued in late December, you have to wonder about impact. Although the advent of active social media makes it more likely that there are no longer “news dumps”, let’s assume the best and review a recent posting of the Treasury Department’s “National Strategy for Combating Terrorist and Other Illicit Financing.” The report is actually four separate documents and I would urge everyone to read all four—mainly because several are clearly…

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The 2019 AML List!

By John Byrne | December 18, 2018

As I have done in previous years, will be looking ahead to 2019 and what may be in store for the AML/CTF/Financial Crime Prevention community. With new committee chairs in the US House and several retirements in the Senate, it is a safe bet that any policy debates in our area will be somewhat different than the last two years. If you add on what is likely to be a financial focus on investigations of…

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How do you ensure your company stays AML compliant? By following these best practices.

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