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 on an Uzbek security official who secretly acquired Emirati citizenship and millions in Dubai real estate, then turn to New York Times reporting on conflict of interest questions in U.S.-Russia talks on Ukraine. The conversation then shifts to FinCEN's unusual withdrawal of two proposed rules targeting unhosted wallet transactions and convertible virtual currency mixing, and what that means for institutions with crypto exposure whose SAR obligations remain unchanged. Additional topics include the Comptroller of the Currency's fraud roundtable with community bankers in Minneapolis, the Department of Justice's new memorandum on corporate fraud enforcement, and the first reported AI agent-powered intrusion into major South Korean banks. The episode closes with a preview of the October 22nd webinar on best practices in managing high-risk customers. Resources Referenced in This Episode: OCCRP: The Uzbek President's Son-In-Law Secretly Acquired a UAE Passport While Serving as a Top Security Chief The New York Times: U.S.-Russia Talks on Ukraine and the Kushner and Witkoff Oil Deal Federal Register: Proposal of Special Measure Regarding Convertible Virtual Currency Mixing, as a Class of Transactions of Primary Money Laundering Concern; Withdrawal Federal Register: Requirements for Certain Transactions Involving Convertible Virtual Currency or Digital Assets; Withdrawal OCC: Comptroller Gould Community Bank Fraud Roundtable in Minneapolis https://www.occ.gov/news-issuances/news-releases/2026/nr-occ-2026-86.html U.S. Department of Justice: Directive 26-12, Corporate Enforcement in the Fight Against Fraud https://www.justice.gov/opa/media/1463571/dl?inline The Wall Street Journal: Hackers Use Chinese AI Tool to Hit South Korean Banks, Exposing New Risk Marquette University Center for Peacemaking: AI and Ethics with Dr. Michael Zimmer AML RightSource: AML Voices Webinar: Best Practices in Managing Your High-Risk Customers