The FATF Shadow Report: Nonprofits, Financial Access, and the U.S. Mutual Evaluation

The FATF Shadow Report: Nonprofits, Financial Access, and the U.S. Mutual Evaluation

In this special episode of AML Conversations, John Byrne is joined by Ashleigh Subramanian Montgomery of the Charity & Security Network to discuss C&SN’s newly released Shadow Report on the U.S. FATF Mutual Evaluation and what it means for nonprofits, financial institutions, and regulators. The conversation explores how U.S. government actions since the last FATF evaluation in 2016 have affected nonprofit financial access, particularly for humanitarian organizations operating in high‑risk and conflict environments. Ashleigh walks through the findings of the Shadow Report, including both positive developments—such as humanitarian carve-outs and improved risk-based language—and ongoing concerns around de-risking, executive actions, and the expanding use of counterterrorism authorities. John and Ashleigh also discuss recent Treasury risk assessments, the gap between policy and on‑the‑ground implementation, and emerging concerns about nonprofit investigations tied to domestic terrorism. The episode concludes with practical guidance for financial institutions on communication, due diligence, and balancing AML/CFT obligations with humanitarian imperatives as FATF assessors finalize the U.S. review.

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AML Conversations - Monthly Chat with Sarah Beth Felix

AML Conversations - Monthly Chat with Sarah Beth Felix

In this monthly regulatory roundup, John Byrne sits down with Sarah Beth Felix of Palmero Consulting to examine some of the most important AML, CTF, and sanctions developments from the past month. The...

15 Loka 29min

Fraud Is Fraud - FinCEN Withdrawals, DOJ Enforcement Factors, and AI Bank Breaches

Fraud Is Fraud - FinCEN Withdrawals, DOJ Enforcement Factors, and AI Bank Breaches

In this week's episode of This Week in AML, John Byrne is joined by Joe McNamara, filling in for Elliot Berman, to flag a wide range of global and domestic developments. They open with OCCRP reporting...

9 Loka 20min

From FATF to FinCEN - Key AML, AI, and Regulatory Developments This Week

From FATF to FinCEN - Key AML, AI, and Regulatory Developments This Week

In this week's episode of This Week in AML, John Byrne and Elliot Berman examine Canada's newly released FATF mutual evaluation and what it may signal as the AML community awaits the upcoming U.S. ass...

2 Loka 20min

OCC Layoffs, AI Regulation, and a $6.9 Billion Sanctions Evasion Scheme

OCC Layoffs, AI Regulation, and a $6.9 Billion Sanctions Evasion Scheme

In this week's episode of This Week in AML, Elliot Berman and John Byrne examine how workforce reductions at the OCC could affect bank supervision at a time when new national bank charters are on the ...

25 Syys 20min

John Roth on 9/11, Terrorist Financing, and Why Independent Watchdogs Matter

John Roth on 9/11, Terrorist Financing, and Why Independent Watchdogs Matter

In this episode of AML Conversations, host John Byrne sits down with former federal prosecutor, 9/11 Commission staff member, and former Department of Homeland Security Inspector General John Roth to ...

24 Syys 29min

Clarity Stalls, Deepfakes Come Down, and VTB Gets Designated Again

Clarity Stalls, Deepfakes Come Down, and VTB Gets Designated Again

Joe McNamara sits in for Elliot Berman this week alongside John Byrne. Joe and John discuss the Senate vote that failed to advance the Clarity Act, the interagency proposal to rescind and replace thir...

18 Syys 19min

Treasury Actions, Digital Asset Risks, and 25 Years After 9/11

Treasury Actions, Digital Asset Risks, and 25 Years After 9/11

This week, John Byrne and Elliot Berman examine a wave of regulatory and enforcement developments shaping the AML landscape. Topics include new U.S. Treasury sanctions targeting Iran's aviation sector...

11 Syys 21min

Never Forget 25 Years After 9 11, Where We've Been and Where We're Going

Never Forget 25 Years After 9 11, Where We've Been and Where We're Going

Twenty-five years after the attacks of September 11, 2001, John Byrne sits down with Dennis Lormel, who led the FBI's Financial Crimes Program on 9/11 and stood up the Bureau's first Terrorist Financi...

11 Syys 49min

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