OUT
|
IN
|
| GTO renewal for title insurers (Nov) |
GTO Expansion to variety of real estate providers |
| CDD implementation |
Agency examination of CDD compliance |
| Confusion on AML Innovation |
Joint agency statement encouraging innovation |
| Searching for methods to address human trafficking |
The STAT collaborative platform |
| UBS, Danske, Deutche Bank fines |
More fines and penalties on FI’s |
| Questioning SAR filings by regulators |
Hope for reason and fairness |
| Attempts to change BSA thresholds |
Law enforcement proving BSA data value |
| 2018 FATF Mutual Evaluations |
2019 schedule to include Russian Federation and Turkey |
| Wondering when FFIEC Manual is updated |
Still wondering |
| Standing by while de-risking continues |
Document to be produced by FI’s and NPO’s |
| Sanctions, sanctions, sanctions |
More of the same |
| Learning about virtual currency |
Regulation and additional guidance about VC |
| US House hearings on deregulation |
House hearings on AML gaps and various bank scandals |
| Discussion on AML reform |
Action but with inclusion of ALL stakeholders |
| Reliance on best practices to prevent art/antiquity theft |
Laws to prosecute criminals/require CDD |
| Coverage of potential ML in real estate |
Investigations and prosecutions worldwide |
| More debate on information sharing |
Improvement to AML regime to allow more sharing |
| Debate on extent of culture of compliance |
Continued improvement of that culture |
| Examiner second-guessing |
Improved training and communications by both sides |
| Private-Public Partnerships |
Never goes away—too essential! |
John Byrne
