I have always enjoyed The Washington Post’s (and I am sure various other publications) list for the next year. The uniqueness is, of course, they eliminate a popular or hot issue with a new one for the next calendar year. To say 2020 was different would be a vast understatement. What was clearly the most chaotic and challenging time for the entire world will, in most cases, sadly stay with us for a long time to come. The following are my (and mine alone) predictions for 2021, which is extremely foolish given what we just went through (and are still dealing with), but limited to AML related issues and themes.
As David Letterman would have said, this is only an exhibition, not a competition -- so please, no wagering…
|
OUT |
IN |
|
Covid Fraud |
Garden variety fraud |
|
Subjective review of risk assessments |
Risk Assessment Regulation |
|
Continued “talk” about information sharing |
Actual improved and legal information sharing |
|
Struggles for charities to receive financial access |
FI’s providing access with regulator support |
|
IRSCI Chief Don Fort (retired) |
New Chief Jim Lee |
|
BSA gaps in art and antiquities |
Eventual BSA responsibilities |
|
Geographic Targeting Orders renewed |
Same |
|
Clarity on due diligence for Hemp businesses |
Clarity on due diligence for marijuana businesses |
|
Talk talk on sharing compliance resources |
Actual sharing of resources |
|
Support for AML “innovation” |
Innovation |
|
Reliance on the 5th pillar on Beneficial Ownership |
An actual, functioning Beneficial Ownership registry |
|
Penalty against AML officer for BSA failures |
More penalties |
|
Virtual currency scams |
More cases/oversight on virtual currency issues |
|
Cybercrime as issue outside AML |
AML departments co-owning cyber issues |
|
Unclear regulatory expectations |
AML reform including training for examiners |
|
How to use AI in AML detection/reporting |
Actual use of AI (where appropriate) |
|
Media coverage on tax evasion/shell companies |
Prosecution of tax evasion/shell companies |
|
Training on financial aspects of terrorism |
New focus on domestic terrorism |
|
The FinCEN Files |
More journalists covering ML issues |
|
Studies on SARs/CTRS |
Improved reporting and efficiencies |
|
Secretary of Treasury/Attorney General |
New administration—new priorities |