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.

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Corporate Transparency Rollback, Ireland's First AML Strategy, and Trump's Bank Charter

Corporate Transparency Rollback, Ireland's First AML Strategy, and Trump's Bank Charter

In this episode of This Week In AML, Joe McNamara fills in for Elliot Berman and joins John Byrne for a packed week of AML news on both sides of the Atlantic. The conversation opens with the fallout f...

21 Aug 24min

AML Conversations - Monthly Chat with Sarah Beth Felix

AML Conversations - Monthly Chat with Sarah Beth Felix

John Byrne is joined by Sarah Beth Felix, author of Dirty Money Weekly, for their monthly conversation on financial crime developments. They start with FinCEN's final rule ending Corporate Transparenc...

20 Aug 32min

FinCEN Ends BOI Reporting, Fraud Enforcement Expands, and Global Compliance Shifts

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In this episode of This Week in AML, Elliot Berman and John Byrne break down FinCEN's final rule eliminating beneficial ownership reporting requirements for millions of small businesses and discuss wh...

14 Aug 15min

The Largest Broker-Dealer AML Penalty Ever - UBS, FinCEN Leadership Changes, and the Future of SAR Reporting

The Largest Broker-Dealer AML Penalty Ever - UBS, FinCEN Leadership Changes, and the Future of SAR Reporting

This week on This Week in AML, John Byrne and Elliot Berman examine FinCEN's record-setting $125 million enforcement action against UBS, the largest civil money penalty ever imposed against a broker-d...

7 Aug 18min

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FinCEN's Fraud Focus, Corruption Questions, and Crypto Compliance Challenges

In this episode of This Week in AML, John Byrne and Elliot Berman unpack several significant developments across the AML, sanctions, fraud, and compliance landscape. They begin with the U.S. Senate's...

31 Juli 17min

Art, Antiquities, and Financial Crime - Protecting Cultural Heritage in a Global Threat Landscape with Tess Davis

Art, Antiquities, and Financial Crime - Protecting Cultural Heritage in a Global Threat Landscape with Tess Davis

In this episode of AML Conversations, host John Byrne welcomes Tess Davis, Executive Director of the Antiquities Coalition, for a timely discussion on the intersection of cultural heritage crime and f...

29 Juli 31min

Southeast Asia’s Criminal Economy, Crypto Crime Risks, and AMLA’s Compliance Wake-Up Call

Southeast Asia’s Criminal Economy, Crypto Crime Risks, and AMLA’s Compliance Wake-Up Call

This week on This Week in AML, Elliot Berman and Joe McNamara examine a series of reports and regulatory updates highlighting the growing sophistication of global financial crime. The discussion begi...

24 Juli 24min

Russia Sanctions Resurface, New Lending Guidance, and Europol’s EU Terrorism Report

Russia Sanctions Resurface, New Lending Guidance, and Europol’s EU Terrorism Report

In this week's episode of This Week in AML, John Byrne and Elliot Berman discuss the renewed push for a bipartisan U.S. sanctions bill targeting Russia and compare its approach to the European Union's...

17 Juli 18min

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