Navigating the AML Crossroads: 2025 in Review and What's Next

Navigating the AML Crossroads: 2025 in Review and What's Next

In this candid year-end conversation, John Byrne and Sarah Beth Felix dissect an unprecedented year in AML enforcement. Felix, President of Palmero Consulting and creator of "Dirty Money Weekly," describes what she sees as systematic dismantling of AML infrastructure despite stated priorities of combating fentanyl and transnational criminal organizations. With only four enforcement actions from traditional federal banking agencies compared to FINRA's 20+ penalties, the landscape has shifted dramatically. The discussion explores Treasury's proposal to give FinCEN veto authority over banking agency BSA decisions - a move Felix warns could create massive bottlenecks. They examine troubling patterns in recent OFAC sanctions penalties where entities disregard guidance while violations flow through traditional banks. Felix shares skepticism about AI replacing the "hyper suspicious" human judgment essential to AML work, noting AI tools consistently fail basic sanctions questions. The conversation addresses the stark gap between U.S. and European cryptocurrency regulation, with America applying 40-year-old money service business laws to digital assets while the EU has comprehensive frameworks like MiCA. Looking ahead to 2026, Felix urges AML officers to use reduced regulatory scrutiny strategically - eliminating legacy policies that waste time while remembering everything missed now can trigger future enforcement. She emphasizes focusing on cartels and foreign terrorist organizations, which now carry criminal liability for banking officers, and proactively auditing customer sanctions programs.

Episoder(500)

Italy’s FATF Review, New Russia Sanctions, and the Growing Risk of Prediction Markets

Italy’s FATF Review, New Russia Sanctions, and the Growing Risk of Prediction Markets

In this episode of This Week in AML, Elliot and John unpack a busy week in global financial crime and enforcement. They start with Italy’s latest FATF mutual evaluation, exploring what regulators prai...

1 Mai 16min

Beneficial Ownership Battles, Crypto Regulation, and Global AML Standards

Beneficial Ownership Battles, Crypto Regulation, and Global AML Standards

In this week’s episode of This Week in AML, with Elliot traveling, Joe McNamara joins John Byrne to break down a busy week in global compliance news. The big domestic story is the Corporate Transpare...

24 Apr 18min

Why Fintechs Are Turning to OCC Limited Purpose Trust Charters

Why Fintechs Are Turning to OCC Limited Purpose Trust Charters

In this episode of AML Conversations, Elliot Berman is joined by Jennie Jonas, Senior Vice President of Financial Crime Advisory, to discuss the recent surge in fintechs pursuing OCC limited-purpose t...

22 Apr 30min

AML in Gaming: Inside Casino Compliance, Cash Risk, and the Human Factor

AML in Gaming: Inside Casino Compliance, Cash Risk, and the Human Factor

Casinos operate at the intersection of entertainment, cash, and compliance—making AML in gaming fundamentally different from banking. In this episode, John Byrne sits down with Paul Camacho, Vice Pres...

20 Apr 31min

Corruption Crackdowns, Sanctions, and New Compliance Pressures

Corruption Crackdowns, Sanctions, and New Compliance Pressures

In this week’s episode of This Week in AML, John Byrne and Elliot Berman unpack a wide range of global financial crime and compliance developments shaping the risk landscape. The conversation begins ...

17 Apr 16min

Sanctions & Geopolitical Risk - What's Your Backup Plan?

Sanctions & Geopolitical Risk - What's Your Backup Plan?

AI is everywhere in financial crime compliance - but is it delivering on its promises? In this episode of AML Conversations, host Joe McNamara and Mark Sully, Managing Director of Commercial Affairs f...

13 Apr 11min

FinCEN’s AML Program Rule Overhaul, Stablecoins, and the 10-Year Legacy of the Panama Papers

FinCEN’s AML Program Rule Overhaul, Stablecoins, and the 10-Year Legacy of the Panama Papers

In this week’s This Week in AML, Elliot Berman and John Byrne break down FinCEN’s newly released notice of proposed rulemaking to modernize the AML/CFT program rule—its first major rethink in two deca...

10 Apr 18min

Unpacking the AML/CFT Program Rule: Key Changes and Industry Implications

Unpacking the AML/CFT Program Rule: Key Changes and Industry Implications

AML RightSource's John Byrne sits down with Dan Stipano, partner at Davis Polk's Financial Institutions and Regulation Group and former Deputy Enforcement Director at the OCC, for an immediate reactio...

9 Apr 26min

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