AML Conversations

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 third-party risk management guidance, and the CJEU ruling on Latvia's public shareholder disclosure law and what it signals for beneficial ownership transparency. They also cover the DOJ indictment of a Russian intelligence services network, the Manhattan DA's seizure of 12 deepfake websites and the payment infrastructure behind them, Transparency International's analysis of seven years of EU rule of law reporting, and OFAC's designation of VTB Bank under Operation Economic Outcast. They close with CSIS's look at the terrorism landscape 25 years after 9/11, the shift toward lone actor threats, and the underused potential of 314(a) and 314(b) information sharing. Resources mentioned in this episode: Senate cloture vote on the Clarity Act: https://www.cnbc.com/2026/09/15/senate-cloture-vote-on-clarity-act-fails-dealing-regulatory-setback-... Proposed interagency third-party risk management guidance: https://www.federalregister.gov/documents/2026/09/15/2026-18859/proposed-third-party-risk-management... CJEU ruling on Latvian shareholder disclosure (Case C-798/24): https://cyprus-mail.com/2026/09/13/european-court-decides-on-public-access-to-shareholder-informatio... DOJ release on the Russian intelligence services network indictment: https://www.justice.gov/opa/pr/members-russian-intelligence-services-network-charged-conspiring-fina... Manhattan DA seizure of 12 deepfake websites: https://manhattanda.org/manhattan-d-a-s-office-seizes-domains-of-12-illegal-websites-selling-ai-gene... Transparency International, Anti-Corruption Gaps Are Leaving Democracy in Europe Exposed: https://www.transparency.org/en/news/anti-corruption-gaps-leaving-democracy-europe-exposed Treasury designation of VTB Bank under Operation Economic Outcast: https://home.treasury.gov/news/press-releases/sb0629/ Riley McCabe, CSIS, Adapting to the New Terrorism Landscape 25 Years After 9/11: https://www.csis.org/analysis/adapting-new-terrorism-landscape-25-years-after-911 ProPublica reporting on the Trump Jr. wedding financing: https://www.propublica.org/article/donald-trump-jr-wedding-bankrolled-russian-oligarch-umar-kremlev-...

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, FinCEN's renewal of Southwest Border Geographic Targeting Orders, guidance on SAR confidentiality, and growing concerns over digital asset scams and cryptocurrency regulation. They also discuss FATF's latest reports on underground banking networks, money-laundering risks in the gambling sector, and AUSTRAC's enforcement actions against remittance and crypto firms. In recognition of the 25th anniversary of 9/11, the conversation turns to the lasting impact the attacks had on anti-money laundering, counter-terrorist financing, and public-private partnerships. John and Elliot reflect on how the Patriot Act transformed financial crime prevention, why collaboration between financial institutions and law enforcement remains essential, and the importance of ensuring future generations understand the role AML professionals play in protecting the financial system.

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 Financing Operations Section (TFOS) in its aftermath. Dennis shares his firsthand account from inside FBI headquarters that morning, the plan he wrote that night for a centralized financial investigation, and the unprecedented cooperation from banks and government agencies that followed. The conversation covers the warning signs that preceded the attacks, the three-week passage of the PATRIOT Act, the findings of the 9/11 Commission and its terrorist financing monograph, FATF's special recommendations, and the unintended consequences for charities. Dennis closes with an assessment of the threat landscape in 2026 and a call for the proactive, imaginative use of financial intelligence. As this episode marks both the 25th anniversary of 9/11 and the 25th anniversary of counter-terrorist financing, one theme carries throughout: never forget.

John Byrne and Elliot Berman discuss a busy week in the AML, sanctions, and compliance landscape. Topics include AUSTRAC's enforcement push under Australia's new AML laws and its investigation into Western Union, fresh guidance on politically exposed persons from the Hong Kong Monetary Authority, and the FBI's Art Crime Team's recovery of Egyptian cultural artifacts. They also examine growing concerns surrounding prediction markets, conflicting federal court rulings involving Kalshi and Polymarket, new Treasury sanctions and proposed Section 311 action against a UAE-based bank, and the OCC and FDIC's significant changes to bank examination standards.

In this episode of AML Conversations, Brad Breslin, President and General Manager, Compliance Solutions at AML RightSource, sits down with Jeff Schlanger, former Manhattan prosecutor, institutional reformer, and author of "Doing Right: From Prosecutor to Reformer — A Journey Through Crime, Corruption, Complacency, and Change." Jeff's career spans four decades on the front lines of accountability. He prosecuted the Westies and helped build the case against John Gotti. He served as the federal monitor overseeing the LAPD consent decree after the Rampart scandal. He later became the NYPD's first Deputy Commissioner for Risk Management, and he founded IntegrAssure to bring collaborative oversight to police departments nationwide, including the Aurora, Colorado consent decree. The conversation explores what happens when institutions designed to do good drift off course, and what it takes to bring them back. Jeff shares the moment he discovered the FBI withheld knowledge of jury tampering during the Gotti trial, why he published his NYPD resignation letter, and how the Mickey Featherstone case taught him that doing right often means acting against your own interests. For financial crime compliance and risk professionals, the lessons translate directly. Jeff draws the line from police reform to the HSBC monitorship, where he and Brad worked together, showing that the methodology of oversight, accountability, and continuous improvement is the same whether the rulebook is an LAPD procedures manual or the FFIEC guidelines. Link to Jeff's book: https://doingright.integrassure.com/doing-right-homepage.html