The 2019 AML List!

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 this Administration, and in several other countries, money laundering related topics will be front and center.

The following list is both serious and has some tongue-in-cheek points too. As always, please do not use the following for any wagering, and Have a Great and Safe New Year!



GTO renewal for title insurers (Nov)GTO Expansion to variety of real estate providers
CDD implementationAgency examination of CDD compliance
Confusion on AML InnovationJoint agency statement encouraging innovation
Searching for methods to address human traffickingThe STAT collaborative platform
UBS, Danske, Deutche Bank finesMore fines and penalties on FI’s
Questioning SAR filings by regulatorsHope for reason and fairness
Attempts to change BSA thresholdsLaw enforcement proving BSA data value
2018 FATF Mutual Evaluations2019 schedule to include Russian Federation and Turkey
Wondering when FFIEC Manual is updatedStill wondering
Standing by while de-risking continuesDocument to be produced by FI’s and NPO’s
Sanctions, sanctions, sanctionsMore of the same
Learning about virtual currencyRegulation and additional guidance about VC
US House hearings on deregulationHouse hearings on AML gaps and various bank scandals
Discussion on AML reformAction but with inclusion of ALL stakeholders
Reliance on best practices to prevent art/antiquity theftLaws to prosecute criminals/require CDD
Coverage of potential ML in real estateInvestigations and prosecutions worldwide
More debate on information sharingImprovement to AML regime to allow more sharing
Debate on extent of culture of complianceContinued improvement of that culture
Examiner second-guessingImproved training and communications by both sides
Private-Public PartnershipsNever goes away—too essential!
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John Byrne

John Byrne

Mr. Byrne serves as Vice Chairman of AML RightSource. He is an internationally known regulatory and legislative attorney with more than 30 years of experience in banking and financial crimes. Mr. Byrne has particular expertise in all aspects of regulatory management, anti-money laundering (AML) issues and has served in leadership positions at trade associations, financial services industry groups, and government working groups. Mr. Byrne earned his undergraduate degree at Marquette University and his juris doctor at George Mason University School of Law. He currently serves as a special advisor to the ACAMS Advisory board and on Marquette University’s Commercial Banking Board.

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