Financial Crime Matters

In this episode of “Financial Crime Matters,” Kieran talks with Andy Greenberg, senior writer at WIRED and author of the blockchain forensic thriller “Tracers In The Dark.” Halfway into their conversation, they are joined by Tigran Gambaryan, head of financial crime compliance at Binance and a former IRS-CI investigator. Andy, Tigran and Kieran discuss Tigran's detention by Nigerian authorities for 8 months as part of the government's effort to force Binance to pay billions in penalties, which was the subject of an in-depth WIRED article by Andy. They also talk about Tigran's role as a blockchain forensics pioneer documented by Andy in “Tracers In The Dark,” and what each sees as the opportunities and challenges associated with the rise of digital assets.

In this episode of “Financial Crime Matters,” Kieran talks with Dr. Hans-Jakob Schindler, Senior Director of the Counter-Extremism Project about the current violent threats posed by Islamic radicals, and right-wing and left-wing extremist groups. Drawing on his expertise as Senior Director of the Counter Extremism Project and years of diplomatic service, Hans names the extremist organizations that currently threaten to unleash global violence. While detailing some of the catalysts for the militancy of these organizations, including ongoing conflict in the Middle East and Africa, and political polarization in the United States and Europe, Hans also discusses what financial institutions and government can do individually and in concert to cut off funding to terror groups

In this episode of “Financial Crime Matters,” Kieran talks with Geoff White, the author of three crucial books on financial crime, including “The Lazarus Heist: From Hollywood to High Finance: Inside North Korea's Global Cyber War.” Drawing from “The Lazarus Heist” and a plethora of recent information, Geoff details North Korea's $1.5 billion theft of ether in February from Bybit, a large global cryptocurrency exchange. During their discussion, Geoff provides a decades long history of North Korea's efforts to steal foreign currency, particularly dollars, and describes how its hackers used a third-party vendor and long-term surveillance to empty Bybit's Ethereum wallet. Geoff also describes Bybit's ongoing efforts to recover the lost cryptocurrency and argues for a concerted worldwide effort to prevent future hacks. “If North Korea gets its hands on this money it's fairly obvious what it's going to do,” Geoff says. “It's going to be spending on, well perks for the regime partly, but its going to be spending on missile parts and nuclear weapons material.” In addition to “The Lazarus Heist,” Geoff is the author of “Rinsed: From Cartels to Crypto How the Tech Industry Washes Money for the World's Deadliest Crooks” and “Crime Dot Com: From Viruses to Vote Rigging, How Hacking Went Global.”

In this episode of “Financial Crime Matters,” Kieran talks with the U.S. Postal Inspection Service's Michael Bruno, who is anti-money laundering program manager at the service's national headquarters. Mike details some of the Inspection Service's efforts to tackle the theft of bank checks that are “washed” to fraudulently change the payees and amounts and that are all too often stolen during violent attacks on mail carriers. Crediting the Financial Crime Enforcement Network (FinCEN), the Inspection Service's law enforcement partners and a massive education effort, Mike shares how in roads have been made against check washing. He also discusses how the service is fighting money laundering and other types of fraud connected to the abuse of Postal Service money orders.

In this episode of “Financial Crime Matters,” Kieran talks with Claudia Quiroz, Director of the National Cryptocurrency Enforcement Team, or NCET, at the U.S. Justice Department. Claudia and Kieran discuss the rise in cryptocurrency-enabled crime that necessitated NCET's creation three years ago and the team's subsequent efforts to prosecute cyber predators and seize the proceeds of their crimes. Serving as a dedicated nerve center staffed by crypto experts within the Computer Crime and Intellectual Property Section of Justice, where Claudia is deputy chief, NCET pursues a variety of frauds and scams, money laundering and other abuses of cryptocurrency. During their talk, Claudia touches on some of NCET's cases, including against “Pig Butchering,” which she points out often involves two victims: the individual who is defrauded and enslaved individuals forced perpetrate the fraud.

In this episode of “Financial Crime Matters,” Kieran talks with Adam Levine, Director of Government Engagement for the Child Rescue Coalition (CRC). Adam and Kieran discuss CRC's efforts to enable law enforcement to trace online child sexual abuse material to its creators and collectors. During their discussion, Adam details some of the typologies associated with child exploitation that in tandem with CRC's training and technological support has, to date, resulted in the arrest of more than 15,500 predators in more than 100 countries.

In this episode of “Financial Crime Matters,” Kieran talks with three individuals committed to exposing cryptocurrency scams and drawing attention to imprisoned investigative journalist Mech Dara, who is responsible for uncovering the horrific conditions and practices within Cambodian-based crypto fraud compounds. Zeke Faux, author of “Number Go Up,” Danielle Keeton-Olsen, a freelance journalist based in Phnom Penh, and Erin West, Deputy District Attorney, Santa Clara County CA, discuss Dara's treatment by the Cambodian government and its seeming indifference to fraud compounds that enslave tens of thousands and operate in plain sight, causing the financial ruin of millions around the world. During the podcast, Erin touches on the success law enforcement has had in recovering some victims' money, Zeke calls on VASPs to do more to interdict crypto fraud funds, and Danielle identifies some of the organizations working for Dara's release.

In this episode of Financial Crime Matters, Kieran sits down with Michael Grady, chief of the bank integrity unit at the U.S. Department of Justice Criminal Division during the ACAMS Assembly Vegas Conference in September. Mike talks about the BIU's remit to pursue criminal infractions at banks, payment service providers, cryptocurrency exchanges and other financial businesses subject to the Bank Secrecy Act. During their conversation, Mike discusses some specific cases involving institutions actively involved in breaking anti-money laundering, terror finance and sanctions laws, which pose a threat to national security.

In this episode of “Financial Crime Matters”, Kieran talks with ACAMS colleague, Craig Timm, Senior Director of AML at ACAMS. Craig and Kieran do a deep dive into the recent settlements by TD Bank with the US Department of Justice, the Federal Reserve Board, the Office of the Comptroller of the Currency, and the Financial Crimes Enforcement Network that resulted in more than $3 billion in monetary penalties, ongoing remediation and monitorships, as well as the prosecution of two bank insiders. With more individual prosecutions likely, Craig and Kieran layout the lessons for financial institutions from settlements and discuss how compliance professionals can protect themselves from culpability when their financial institutions go astray.

Detecting True Crimes with Great Accuracy, with Oracle's Jason Somrak In this inaugural episode of “Financial Crime Matters: Industry Leaders,” Kieran sits down with Jason Somrak, Chief of Product & Strategy for Financial Crime & Compliance at Oracle Software. Jason talks about the Holy Grail of anti-financial crime practice: the ability to “detect true crime with great accuracy,” which includes canceling out the noise of false positives. Jason and Kieran also discuss the possibilities and limits of current technology as well as the promise for future advancements in fighting financial crime. During their conversation, Jason also takes a stab at defining what we really talk about when we talk about artificial intelligence.

Understanding Canada's Enhanced Regulatory Regime, with Jacqueline Shinfield. In this episode of “Financial Crime Matters,” Kieran talks with Toronto-based attorney Jacqueline Shinfield, co-lead of Blakes' Financial Services Regulatory Group. Jackie details the unfolding revolution in Canadian anti-money laundering and counter terror finance, including creation of a safe harbor for information sharing among FINTRAC regulated entities and new sanctions reporting requirements. Setting the stage for ACAMS upcoming “The Assembly Canada” November 6 and 7, Jackie also talks about how far Canada has come since the Cullen Commission Report by explaining the new role title insurers will play in verifying beneficial ownership in real estate transactions and the new powers FINTRAC will have to examine foreign interference in Canada's financial system.

In this episode of “Financial Crime Matters,” Kieran talks with Chris Ainsley, head of fraud risk management at Santander Bank. Drawing on more than 20-year history at Santander, Chris details how financial institutions like his are fighting the current spike in online fraud that utilizes elaborate schemes to get customers to authorize payments from their accounts into the accounts of scammers. With it now being possible to conduct all our banking, buying, selling and a host of other transactions online, banks are tasked with educating customers about the intricate subterfuges to trick them into authorizing payments to criminals, says Chris. Financial institutions are having “very complex conversations” with customers to save them from victimization. “It's not just “why are you making a payment at 2 pm in a foreign country'” anymore, which often involved a stolen or cloned ATM card that the bank quickly canceled and replaced, Chris says. Now, it's sometimes about engaging a client at length as to why they want to make a seemingly dodgy transaction and warning them of the risk.

Kieran talks with CJ Rinaldi, chief compliance officer at Kraken Digital Asset Exchange, about the virtual asset service provider's efforts to prevent money laundering, terror finance, sanctions busting, and fraud. Drawing on his experience as senior counsel at the SEC and at financial institutions, CJ also discusses the kind of regulatory regime the cryptocurrency industry as well as the benefits and limits of blockchain transparency for financial transactions.

In this episode of Financial Crime Matters, Kieran talks with Christina Rea about her brief tenure at Binance.US as interim chief compliance officer. Christina discusses what it was like to head U.S. compliance for Binance.com, the world's largest digital assets trading platform, as it underwent scrutiny from regulators and law enforcement that ultimately culminated in a $4.3 billion penalty against Binance.com and a guilty plea for money laundering failures by the VASP's co-founder Changpeng Zhao that resulted in his paying a $50 million fine and the possibility of up to 18 months in prison. Christina, who launched a consulting firm after resigning from Binance.US after about six months at the VASP, also touches on what it takes to protect yourself as a compliance officer whose business is facing tough oversight.

Kieran talks with Guy Ficco, the Chief of IRS Criminal Investigation. They discuss the IRS-CI's recent success in tracking illicit cryptocurrency transactions. and the threat from money mules. Guy also identifies some of the latest typologies his agency is seeing, while crediting suspicious activity reports from financial institutions as catalysts for investigations, arrests and successful prosecutions.

Kieran talks with Eliza Odom, former Section Chief of the FBI's Counterterrorism Division, about the top terror threats the bureau is currently focused on. While having since become deputy assistant director of the FBI's Weapons of Mass Destruction Directorate, Eliza discusses the seven units within the Counterterrorism Division she once oversaw, particularly focusing on the Financial Targeting and Analysis Unit, and its role interdicting terror funding. While deeply concerned about the actions of home-grown extremists, Eliza also details the need for global cooperation and vigilance from the private sector to address the rising threat of cross border financed terror attacks in the wake of war in the Middle East.

Kieran talks with Hennie Verbeek-Kusters, head of the Netherlands financial intelligence unit, about her leadership over the FIU since its founding in 2008. During their discussion, Hennie details how the Dutch FIU has evolved to face the challenge of evermore sophisticated transnational criminal organizations and the professional money launderers they now utilize. The effort to track and seize drug money has, she says, taken on a new urgency with the unprecedented rise of violence by organized drug traffickers in the Netherlands in past few years.

Kieran talks with Molly Moeser, Acting Chief, Money Laundering and Asset Recovery Section of the U.S. Justice Department, about MLARS' efforts to seize illicit assets and, when possible, bring financial restitution to victims of crime. During their talk, Molly discusses the seizure of illicit funds associated with kleptocracy and other crimes, including crypto assets, which require “a whole of government approach” that enlists experts throughout law enforcement. Molly also touches on the importance of MLARS' relationships with the private sector in identifying and seizing criminal proceeds, both as a source of intelligence and cooperative partner. ---------- This Financial Crime Matters episode is sponsored by: Moody's - www.moodys.com/KYC

Kieran talks with Jennifer Shasky Calvery, Group Head of Financial Crime Risk at HSBC, a former Director of the Financial Crime Enforcement Network, or FinCEN, and former federal prosecutor. Drawing on her public and private sector experience, Jen details the challenges faced by financial institutions and government and how in partnership they can detect illicit funds and catch bad actors. Jen also talks with Kieran about HSBC's recent partnership with Google AML AI and the promise artificial intelligence holds for financial institutions and law enforcement.

Kieran talks with Daniel Stipano, partner at Davis Polk & Wardwell and a 30-year veteran of the Office of the Comptroller of the Currency, about the unfolding requirements of the Corporate Transparency and AML Acts and their impact on law enforcement, and financial as well as non-financial institutions. Dan also weighs in on the current court challenges to the CTA, particularly the recent Federal court ruling that declared it unconstitutional, what the Financial Crime Enforcement Network's latest rule-makings mean, and what the long-awaited revised customer due diligence rule might look like.

Kieran talks with ACAMS colleagues Justine Walker, head of global sanctions and AML risk, and Craig Timm, senior AML director, about the just released “ACAMS Global AFC Threats 2024.” Drawing on 788 in-depth interactions with anti-financial crime professionals that inform the report, Justine and Craig identify the top ten threats currently facing the global AFC community, including budget cuts at financial institutions, the rise of cyber-enabled crime, the fallout from global conflict, and more. While detailing the threats, Justine and Craig also talk about how anti-financial crime professionals are responding and how financial institutions can prepare for the threats in their own AFC efforts. Read the Global AFC Threats Report 2024 here: https://www.acamstoday.org/global-afc-threats-report

Kieran talks with Grant Rabenn, Director, Financial Crimes Legal at Coinbase. Grant, a former federal prosecutor who handled some of the Department of Justice's earliest crypto cases, discusses the promise of blockchain offerings, while acknowledging the industry's need to work with regulators to stem their use in financial crime and money laundering. During their conversation, Grant also touches some of the typologies for the illicit use of crypto currency that Coinbase encounters and the value of using a variety of blockchain forensics providers to trace crypto transactions.

Kieran talks with Zeke Faux, author of critically acclaimed “Number Go Up,” a comprehensive look at cryptocurrency, DeFi, and NFTs. Zeke, an investigative reporter for Bloomberg BusinessWeek and Bloomberg News, discusses the trek he undertook to understand the boom and sometimes bust of various blockchain offerings. It was a journey that included a New York harbor NFT “ApeFest,” time in the Philippines with erstwhile Axis Infinity gamers who lost everything, a visit to a hotel in Cambodia attached to a “pig butchering” operation, and finally a marathon interview with Sam Bankman-Fried in the Bahamas days before his arrest.

Kieran talks with Kenneth Rijock, a former Miami-based lawyer who spent a decade as a bag man for drug-traffickers, investing their cash in accounts in the Caribbean and other offshore secrecy havens. Ken describes some of the classic methods he used for laundering money and how law enforcement ultimately caught up with him. Following a prison term, Ken reinvented himself as an anti-money laundering advisor to law enforcement and subsequently the private sector. His story is also told in his book, “The Laundryman,” published in 2012.

Kieran talks with Carly Yoost, CEO and founder of the Child Rescue Coalition, which has created technology that enables law enforcement to identify instances of online child exploitation and locate its perpetrators. During their discussion, Carly details the scope of online child exploitation and how the Coalition provides tools and training to law enforcement in 98 countries that has led to the arrest of over 14,700 child predators.

Kieran talks with James Barnacle, Chief of the Financial Crimes Section, Criminal Investigative Division of the FBI, and Christopher Soyez, Assistant Section Chief. Jim and Chris discuss how the FBI works to recover the proceeds of scams on behalf of victims. They credit banks' suspicious activity reports with being the primary catalyst for the bureau's successful investigations into COVID-19 related scams, while also questioning a rising reluctance within the industry to aid customers in recovering the proceeds of other kinds of fraud.

Kieran talks with Kenneth A. Blanco, Chief Compliance Officer for the Financial Crimes Unit at Citigroup, who is also a former Financial Crimes Enforcement Network (FinCEN) director and before that held several senior roles within the U.S. Department of Justice. Ken and Kieran discuss the challenges of being FinCEN's chief during the COVID-19 epidemic and his perspective on the Anti-Money Laundering and Corporate Transparency Acts created and passed during his tenure. Having now served within both the public and private sectors in the fight against financial crime, Ken also talks about what regulators, law enforcement and AFC professionals at financial institutions don't understand about each other and the importance of them joining forces in public private partnerships.

Kieran talks with Seoyoung Kim, Associate Professor of Finance, Department Chair, at Santa Clara University, about the promise and possible perils of decentralized finance. They discuss the recent implosion of several cryptocurrency exchanges and stablecoin minters and the great legal and judicial debate now raging over the regulation of digital assets. In detailing some of the regulatory definitional claims now being adjudicated in U.S. courts, Seoyoung argues that the contested offerings are all analogous to financial instruments already regulated under the extant centralized finance system. As a result, she says that the proper application of rules from the centralized finance world are sufficient for oversight of DeFi. In concluding, Seoyoung says that executing transactions on a publicly transparent blockchain, rather than on exchanges that facilitate money laundering and fraud via mixers and tumblers or privacy coins, is as essential as regulation to the ongoing integrity and promise of DeFI.

Kieran talks with Rick Small, Director Financial Crimes Program, at Truist, Dan Soto, Chief Compliance Officer, Ally Financial, and John Byrne, Executive Vice President, AML RightSource, about what's been achieved in the past 40 years in the fight against financial crime and what challenges lay ahead. In anticipation of receiving the “ACAMS Lifetime Achievement Award” at The Assembly in Las Vegas in October, Rick, Dan, and John discuss the successes and shortcomings of past Bank Secrecy Act regulation, as well as what's good and what's bad in the Anti-Money Laundering Act of 2020 and the Corporate Transparency Act. Drawing on nearly 150 years of collective public and private sector experience fighting financial crime, the three old friends celebrate the rise of the AML community, the establishment of AFC as a profession and their association with ACAMS since its inception. In concluding, they offer advice to the next wave of anti-financial crime professionals who will face variations on old crime typologies and new scenarios connected to AI and other technologies adopted by industry, law enforcement and, sadly, savvy criminals.

Kieran talks with Willem Schudel, Head of Department, Financial Crime Supervision (AML/TF) at the Central Bank of the Netherlands, live from The Assembly Europe, ACAMS' annual conference, held this year in Dublin. Willem discusses the Dutch Central Bank's preparations for the coming of the European Union's Anti-Money Laundering Authority, or AMLA, and the bank's latest initiatives with regulated entities, including expectations they adopt technology that will identify criminal activity and reinforce the risked-based approach.

Kieran talks with Sarah Paquet, Director and CEO of the Financial Transaction Reports Analysis Centre, FINTRAC, live from ACAMS' 27th annual moneylaundering.com conference in Hollywood, Florida. Sarah discusses FINTRAC's new role handling sanctions intelligence, managing the revolution in financial technology, and the financial intelligence unit's ongoing commitment to expand and further internationalize Canada's anti-financial crime public-private partnerships. While detailing the initial success of the partnerships, including initiatives around human trafficking, online child exploitation and the fentanyl trade, the FINTRAC director says “we are definitely looking to bring [all] our partnerships to an international level” because FINTRAC should be seen not just as Canada's FIU but as a trusted partner by global industry, law enforcement and the public.

Kieran talks with Steve Schindler and Katie Wilson-Milne, partners at New York litigation and art law boutique Schindler Cohen & Hochman LLP about the state of financial crime in the global antiquities and art world. Charting some of the civil and criminal actions that have resulted in a recent wave of repatriations of artworks and antiquities from the world's major museums, noted galleries and private collections, Steve and Katie also discuss the Financial Crimes Enforcement Network's (FinCEN) recent extension of anti-money laundering and counter-terror finance reporting responsibilities to antiquities dealers. In laying out some of the red flags associated with illicit art and antiquities transactions Steve and Katie, who co-host “The Art Law Podcast,” also share their sense of where regulation of the two markets is headed in the United States and the world.

Kieran talks with Tristram Hicks, co-author with Nicholas Gilmour of “The War on Dirty Money,” an examination of the promise and short-comings of the current costly global effort to combat financial crime. Drawing on his years as a New Scotland Yard detective superintendent and his role as an international criminal justice advisor on the operational effectiveness of anti-money laundering regimes, Tristram discusses why current anti-financial crime efforts are inadequate and how they can be improved.

Kieran talks with David Lewis, executive secretary of the Financial Action Task Force (FATF) from 2015 to 2022, about the FATF's recent plenary that gray listed South Africa and Nigeria, formally suspended Russia from membership, and criticized governments throughout the world for lax oversight of cryptocurrency businesses. Currently head of global AML at Kroll, David also weighs in on the United Kingdom's and European Union's latest AML efforts and shares his hope for greater transparency around corporate ownership drawing on his own experience as a senior official in the UK Treasury and the National Crime Agency.

Kieran talks with Oliver Bullough, award winning reporter for The Guardian, about his latest book, “Butler to the World: How Britain Became the Servant of Tycoons, Tax Dodgers, Kleptocrats and Criminals.” During their conversation, Oliver details how Britain and its territories became a favored facilitator for many of the world's kleptocrats, having transformed a financial system that once served the country's global empire into one adept at “investing” illicit funds and serving the whims of transnational criminals. A Russian studies specialist, Oliver expresses guarded optimism about recent U.K. legislative and regulatory developments in response to the invasion of Ukraine that may be a step toward ending Britain's role as butler to the world's financial criminals.

Kieran talks with Dan Stipano, partner at Davis Polk, and Jamal El-Hindi, Counsel at Clifford Chance, about the Financial Crime Enforcement Network's far reaching new rules for creating a U.S. beneficial ownership information (BOI) database for regulators and law enforcement, including who will be required to file personal identifying information and who will not have access to the registry. Mandated by Congress to be operational by January 2024, Dan and Jamal also detail some of the essential questions that remain unanswered about the registry, and what the regulatory landscape will look like in 2023 and beyond. Dan and Jamal come to the discussion with Kieran drawing on 50 collective years of service in the U.S. regulatory community, Dan having started in private practice after 30 years with the Office of the Comptroller of the Currency and Jamal after 20 years in the U.S. Treasury.

Kieran talks with Jonathan Dupont, a financial intelligence investigator for Western Union, and Tiffany Polyak, AFC Associate at ACAMS, about the growth in online sexual exploitation of children and the related rise in child sexual abuse materials on the Internet. In exposing the scope of the online exploitation, Jonathan and Tiffany point to the more than 100 million reports of child sexual abuse material (CSAM) in Europe and the United States in 2021, with 19,000 victims being identified in the United States alone. Drawing from their work to create ACAMS' free online anti-CSAM training program, Jonathan and Tiffany detail typologies and tools to identify financial transactions associated with the exploitation of children, with the ultimate aim of apprehending the perpetrators of this heinous crime. “ACAMS CSAM Certificate” is part of a handful of training programs available as a public service. It will be available early 2023. Visit https://www.acams.org for updates.

Kieran talks with Bryan Smith, chief of the FBI's Cybercriminal Section and a 20-year bureau veteran, about the growing threat of cybercrime to both individuals and large corporations. Bryan discusses the destruction caused by cyber hacking, identity theft and old fashion fraud and he shares some of the successes the FBI has had in recovering stolen funds – whether in fiat currencies or crypto. While concerned about future cybercrime threats from criminals who are always innovating, Bryan also argues that there is much that can be done to prevent cybercrime and catch its perpetrators when law enforcement and the private sector work closely together.

Kieran talks with Nathan Lynch, author of 'The Lucky Laundry' - an expose of how Australia became the conduit for billons of dollars in laundered funds from the proceeds of drug trafficking, corruption, the sexual exploitation of children and other heinous crimes committed by transnational criminal organizations. Nathan, Manager of Thomson Reuters Regulatory Intelligence, Asia-Pacific, details how the 'Lucky Country' (as Australians view their homeland) became the 'Lucky Laundry' undermining confidence in the nation's largest financial institutions and government, and creating a still unmet outcry for stricter anti-money laundering measures from parliament.

Kieran talks with ACAMS colleague Joby Carpenter about the current tumult in the digital asset world, including plummeting cryptocurrency prices, digital value's exploitation by money launderers, the threat from cyberhackers, and the rise in crypto-related fraud schemes. A global subject matter expert on cryptocurrency, Joby draws on 18 years of experience in strategic and risk analysis roles across the UK government, intelligence and regulatory community and concludes that there is a saner, albeit more regulated, future ahead for digital assets.

Kieran talks with Daniel Thelesklaf, Project Director for Finance Against Slavery and Trafficking (FAST) at the United Nations University Centre for Policy Research about the effort to protect refugees fleeing Russia's invasion of Ukraine from human trafficking. While many governments, organizations and individuals are offering support for refugees that includes information, food, shelter and job placements, “there are traffickers waiting at the borders” with job and other offers that Daniel says are, of course, too good to be true. Financial institutions have a vital role and a responsibility, he adds, in helping those dispossessed by the war obtain banking services if they are to be less susceptible to traffickers and successfully fit into communities where they are resettled.

Kieran talks with Ilze Znotina about the challenges Latvia has faced over the past four years she has been head of the Financial Intelligence Unit, including enforcing sanctions against Russia following its invasion of Ukraine. “Baltic states have suffered… a very similar situation that Ukraine is suffering right now, [but] thankfully not in recent years,” Ilze says, adding that the region is for that united in trying to make the sanctions work. “[Ukraine] fights for themselves and all of us in the Baltic states,” she says. Ilze, who became head of the FIU in the wake of the collapse of the country's second largest bank and under the looming threat the Financial Action Task Force would place the country on its so-called “grey list,” also details how Latvia has moved from those darker days to put in place vigorous anti-financial crime controls.

Kieran talks with Jessica Davis, a veteran of more than 20 years in defense and intelligence roles in government and the private sector in Canada. They discuss the occupation of Canada's capitol for three weeks last winter by the so-called “Freedom Convoy,” efforts to support the group via crowdfunding, cryptocurrency, and cash as well as the Canadian government's successful seizure or freezing of much of that funding. Jessica, president of Insight Threat Intelligence and author of “Illicit Money: Financing Terrorism in the Twenty-First Century,” tells Kieran that the unprecedented use of Canada's “Emergencies Act” to clear the Convoy encampment and seize its funding should kickoff a nationwide debate about financial support for extremist groups. “While there may not have been mass shootings or big riots, there were some very significant impacts that for Canada, and for Ottawa in particular, are really outside the realm of what we consider to be acceptable protests,” Jessica says, reflecting on the thousands of unemployed and million in damage resulting from the occupation.

Kieran talks with John Sifton, advocacy director, and Patti Gossman, associate Asia director, at Human Rights Watch about the dire humanitarian situation in Afghanistan following the return of the Taliban to power. “One in three families is facing food insecurity” from malnourishment to starvation, says Patti, adding that the crisis is affecting not only the already impoverished, but middle-class and working-class people who are no longer paid for their jobs and have no access to their savings. “Sanctions on Afghanistan are an important part of the economic crisis, but they are not the root cause” as actions by the U.S. Treasury have improved the flow of funds to private banks, John says. “But that's not solving any of the larger macroeconomic problems and liquidity problems,” John argues, in calling for an end to the isolation of the Afghan central bank from the international banking system.

Kieran talks with Olivia Swaak-Goldman, executive director of the Wildlife Justice Commission, about the Hague-based organization's efforts to stop the illegal wildlife trade and other forms of environmental exploitation, currently the fourth largest source of funds for transnational criminal organizations. Olivia discusses how WJC targets traffickers in endangered species and those having the greatest negative environmental impact with its team of former law enforcement investigators, intelligence officials and prosecutors. Olivia highlights WJC's recent success in prosecuting ivory and Pangolin smugglers with help from Nigeria and China as well as the ongoing struggle to take down transnational criminals throughout the world who rely on the aid of corrupt officials and are often also engaged in human and drug trafficking. “Wildlife crimes wouldn't be there without corruption, without fraud, without money laundering,” Olivia says, adding, “Addressing corruption is absolutely essential to tackling wildlife crime.” ACAMS and the World Wide Fund for Nature (WWF)collaborated with the WJC to develop a free training certificate on investigative strategies to aid law enforcement in the use of financial intelligence and other data related to the illegal wildlife trade. LEARN MORE: https://www.acams.org/en/training/certificates/ending-illegal-wildlife-trade-a-practical-guide-for-law-enforcement

Kieran talks with colleague Dr. Justine Walker, Global Head - Sanctions, Compliance and Risk at ACAMS, about the likely shape of sanctions against Russia should it invade Ukraine. In the wake of ACAM's Second Annual Sanctions Summit, Justine discusses keynote speaker and White House special advisor Peter Harrell's promise of severe sanctions against Russia should it attack Ukraine and analyzes the Summit buzz about how the United States, United Kingdom and European Union as well as the financial industry are preparing for possible sanctions. “In thinking of good practice… you do need to map your Russia exposure,” Justine says, adding that financial institutions and companies must ask, “Do you have investments in Russia? Do you have people in Russia? What type of securities exposure do you have? Are you exporting to Russia?” In the event of sanctions, she says, corporations should ask “What may you need to withdraw from and are you able to withdraw from that?”

Kieran talks with Anjana Rajan, chief technology officer for Polaris, about the work the not-for-profit does to fight human trafficking, including having helped more than 30,000 trafficking survivors via its national hotline. In looking ahead, Anjana talks about the need to recreate the Internet to end its use by the powerful to exploit the vulnerable, a reality made only worse by the accelerated digitalization of life in the wake of COVID-19. Anjana says the current debate about Web 3, the next generation of the Internet, offers us all a chance to create a better virtual world or to further the Web's capacity to be used for exploitation. “As a cryptographer, I largely believe in the potential of Web 3 to help restore economic justice to victims and survivors of human trafficking,” Anjana says, “but as a human trafficking expert, I think Web 3 only offers that possibility, not the guarantee.”

Kieran talks with Dr. Tom Robinson, chief scientist and founder of Elliptic, a blockchain forensics company, about the phenomenal growth of decentralized finance, or DeFi. Offering the promise of a wide array of financial services on an inexpensive and inclusive basis, DeFi also presents a significant fraud and money laundering threat, Tom says. Drawing on Elliptic's recently released report, “DeFi: Risk, Regulation and the Rise of DeCrime, which he co-wrote, Tom covers the need for legislation and greater regulatory oversight to stem fraud and money laundering as well as ways in which blockchain forensics are being used to track illicit funds on DeFi platforms. “I think it is reasonable to describe this as the ‘Wild West' in that there are fortunes to be made here and fortunes to be lost and that's happening every day,” says Tom.

Kieran talks with Casey Michel about his just published book, “American Kleptocracy,” which details how the United States has become a favored destination for laundering money for corrupt politicians and other criminals. Competition among states such as Delaware, Wyoming and Nevada for fees for forming corporations and trusts as well as carveouts from oversight won by special interest groups are to blame, Casey says. Casey, an investigative journalist who has been published widely, including in Foreign Affairs, Foreign Policy, The Atlantic, Washington Post, and The Guardian, talks about how financial intermediaries, including real estate agents and lawyers, have profited from aiding criminals by creating instruments to obscure the ownership of illicit funds. And, while optimistic that new legislation and regulation will curtail some of those practices, Casey says other industries used to launder money lack transparency and oversight, including hedge funds and private investment companies.

Kieran talks with Alex Zerden about his time as Treasury attaché at the United States Embassy in Kabul, the worsening humanitarian crisis in Afghanistan and the renewed terrorism threat related to the Taliban's return to power. Alex, the principal and founder of Capital Peak Strategies, a financial technology and digital asset advisory firm, talks about how the United States presence in Afghanistan was marked by corruption connected to an inflow of money the Afghan economy was incapable of absorbing. He adds that it was nonetheless “seeing the work and sacrifices made by my Afghan counterparts” that got him through his worst days. “By my own research I have identified 17 terrorist organizations [now] operating in Afghanistan,” says Alex, in reflecting on the ongoing challenge the world faces to not reward the Taliban for “bad behavior” but to ease the humanitarian crisis now threatening Afghans.

Kieran talks with Jacqueline Shinfield, partner at Blakes, Cassels & Graydon about the latest legislative and regulatory requirements from Finance Canada and FINTRAC that are part of the nation's renewed vigor to fight financial crime. Ahead of the ACAMS Annual Canada Conference on 3, 4 November, Jackie and Kieran discuss Canada's new cost recovery plan's impact on FINTRAC regulated entities, issues arising from ongoing regulatory examinations, technological gaps in implementing the new electronic fund transfer reporting requirements and lessons from the Cullen Commission. “If anyone is interested in learning about money laundering, ways to launder money, trade-based money laundering, there are so many incredible papers, affidavits online that make compelling reading if you are an AML geek,” Jackie says of the work of the Cullen Commission, which is set to end oral submission this month and due to release a final report by 15 December.