Podcasts about anti money laundering act

Grant Teeple is the Founder and Senior Partner of Teeple Hall, LLP, a full-service commercial law firm. He oversees the firm's Litigation Group and participates in the Corporate & Transactional Group's Mergers & Acquisitions Practice Area. Before founding Teeple Hall in 1992, Grant worked as a civil litigation defense attorney and has litigated complex, multi-jurisdictional matters in business litigation, intellectual property disputes, fraud cases, real property disputes, and entitlement matters. He has also handled numerous acquisitions and company sales in sell-side and buy-side transactions exceeding $100 million.  In this episode… As business owners engage in M&A transactions, a crucial piece of legislation threatens steep fines and — in extreme cases — jail time for those who fail to comply. What new federal regulations must businesses navigate during the M&A process? After the Anti-Money Laundering Act of 2020, Congress passed the Corporate Transparency Act (CTA), requiring businesses to disclose information about their owners and controllers to the Financial Crimes Enforcement Network (FinCEN). The law applies to any LLC or corporation and includes operators like CPAs, lawyers, and bankers. If you fail to comply or provide FinCEN with inaccurate or outdated information, you may be charged $500 for each day of non-compliance. Corporate M&A and compliance expert Grant Teeple recommends hiring an attorney to help you update ownership information regularly, maintaining compliance while ensuring privacy through attorney-client privilege.  In this episode of Destination Business Freedom, Pat Mancuso welcomes Grant Teeple, the Founder and Senior Partner of Teeple Hall, LLP, to discuss compliance regulations for M&A transactions. Grant also talks about common mistakes buyers and sellers make during the M&A process, how to involve an attorney in business sales, and how to navigate due diligence.

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this edition, Tom Fox welcomes Frank Tumminello for an in-depth discussion on the Corporate Transparency Act (CTA) and its business implications. They delve into the reasons behind the CTA, a law established under the Anti-Money Laundering Act of 2020, and its importance in enhancing transparency and preventing criminal activities like tax evasion and money laundering. Despite being in effect for nearly a year, there needs to be more awareness, with only 15% of the 40 million affected companies having complied. Frank explains the Beneficial Ownership Information (BOI) report, its requirements, and the challenges businesses might face in staying compliant. They also touch upon the misconceptions and legal difficulties surrounding the CTA, as well as the efforts of FinCEN to facilitate compliance, including the potential for extended deadlines in hurricane-affected FEMA zones. Lastly, Frank introduces ‘File Forms,' a platform designed to streamline BOI reporting, highlighting its features, success stories, and support to businesses navigating these new requirements. Highlights in this episode: Overview of the Corporate Transparency Act Purpose and Misconceptions of the CTA Beneficial Ownership Information Reporting Constitutionality and Legal Challenges FinCEN Updates and Compliance Efforts File Forms: Features and Benefits   Resources: Frank Tumminello on LinkedIn FileForms Tom Fox Instagram Facebook YouTube Twitter LinkedIn For more information on the Ethico Toolkit for Middle Managers, available at no charge, click here. Learn more about your ad choices. Visit megaphone.fm/adchoices

Hello, and welcome to episode 98 of the Financial Crime Weekly Podcast, I'm Chris Kirkbride. It is yet another busy week for financial crime, so I think we'll just get on with it. Lots to get through, so let's crack on. As usual, I have linked the main stories flagged in the podcast in the description. These are: Bailiwick of Guernsey Financial Intelligence Unit, Annual Report 2023.Companies House, Companies House begins phased roll out of new powers to tackle fraud.Department of Health and Human Services, HHS Statement Regarding the Cyberattack on Change Healthcare.Department of Justice (Office of Public Affairs), Commodities Trading Company Will Pay Over $661M to Resolve Foreign Bribery Case.Department of Justice, Leesburg man pleads guilty to COVID relief fraud scheme.Department of Justice, Brooklyn Woman Sentenced To 33 Months In Prison For Multifaceted COVID-19 Fraud Scheme.Department of Justice, Broward Sheriff's Office deputy convicted at trial of COVID-19 relief fraud.Department of Justice, Man Charged for $10M COVID-19 Relief Fraud Scheme.Department of State, Sanctioning Human Rights Abusers and Corrupt Actors, and Termination of Zimbabwe Sanctions Authority.Department of the Treasury, Treasury Sanctions Zimbabwe's President and Key Actors for Corruption and Serious Human Rights Abuse.Eurojust, Support to halt money laundering in Italy via tax fraud and fake invoices.European Public Prosecutor's Office, Annual Report 2023: EPPO warns that serious organised crime continues to feast on EU revenue.European Public Prosecutor's Office, Annual Report 2023.Federal Communications Commission, FCC & U.K. Ofcom to Partner in Fight Against Scam Calls & Texts.Financial Conduct Authority, FCA warns firms over anti-money laundering failings (press release).Financial Conduct Authority, Dear CEO Letter: Annex 1 Firms.Financial Conduct Authority, High Court allows the FCA to pause civil case against WealthTek LLP.Foreign, Commonwealth and Development Office, Policy paper – Post-Legislative Scrutiny Memorandum: Sanctions and Anti-Money Laundering Act 2018.Home Office, Biggest ever crackdown on money mules in the UK.Office of Financial Sanctions Implementation, Financial Sanctions Notice: Russia.Office of Foreign Assets Control, Treasury Sanctions Members of the Intellexa Commercial Spyware Consortium.Office of Foreign Assets Control, Treasury Targets Companies and Vessels Facilitating Qods Force and Houthi Commodity Shipments.UK legislation, The Economic Crime and Corporate Transparency Act 2023 (Commencement No. 2 and Transitional Provision) Regulations 2024 SI No 269.National Cyber Security Centre, Connected Places Cyber Security Principles.National Cyber Security Centre, New 'Connected Places' infographic published.Serious Fraud Office, SFO secures conviction of former MoD official for taking £70k in secret kickbacks.Spotlight on Corruption, Acquittal of two men for making corrupt payments on UK-Saudi arms deal must lead to full independent inquiry into UK government's role.White House, Statement by National Security Council Spokesperson Adrienne Watson on U.S. Sanctions on Zimbabwean Individuals and Entities.Wolfsberg Group, Publication of the updated Country Risk FAQs.Wolfsberg Group, Country Risk Frequently Asked Questions (FAQs).

The Road to Victory: An Interview with Asset Protection Coach, Scherrie PrinceMastering Asset Protection and Overcoming Challenges with Scherrie PrinceIn this episode of the Walk in Victory podcast, the host, NaRon Tilman introduces and sits down with Scherrie, an asset protection coach and attorney. With her wealth of expertise in asset protection and legal matters,Scherrie shares her insights on the importance of planning and safeguarding one's hard-earned assets. Having faced significant trials herself, including the loss of her mother at a young age, failure of several businesses, and battling through the 2008 mortgage crisis,Scherrie uses these experiences to alert listeners to the realities of unpreparedness when it comes to asset protection. She advises on how to create an effective asset protection plan, how to use insurance as a vehicle to leave legacies, and the importance of having a reliable professional team. Reflecting on her career and life journey,Scherrie's story serves as an inspiration for listeners navigating their own path towards victory.Time Line00:00 Introduction and Welcome00:44 Host's Reflections on Little Richard's Life and Career06:35 Discussion on Success and Cultural Impact08:21 Introduction of Guest - Cherie08:55 Cherie's Insights on Asset Protection18:05 Cherie's Personal Journey and Motivation19:49 Cherie's Career Path and Decision to Become a Lawyer21:10 Discovering a New Career Path22:24 Transitioning into Entrepreneurship22:45 The Impact of COVID-19 on Coaching Industry23:30 The Role of Legal Advice in Business23:57 The Importance of Asset Protection24:18 The Effect of COVID-19 on Business Strategy24:51 The Intersection of Legal, Mortgage, and Real Estate Expertise25:32 The Importance of Planning in Business27:50 Understanding the Anti Money Laundering Act of 202032:31 The Importance of a Team in Business32:42 The Role of Insurance in Asset Protection34:41 The Importance of Building Trust in Business35:47 The Power of Knowledge and Wisdom in Business37:25 The Importance of Planning for the Future39:19 The Power of Continuous Learning and Improvement40:37 Conclusion: Walking Towards Victory

Hello, and welcome to episode 89 of the Financial Crime Weekly Podcast, I'm Chris Kirkbride. It's yet another busy week of financial crime news, so I'm just going to get on with it. As usual, I have linked the main stories flagged in the podcast in the description. These are: AUSTRAC, Top tips for completing your 2023 compliance report.Commodity Futures Trading Commission, Federal Court Enters Order Against Binance and Former CEO, Zhao, Concluding CFTC Enforcement Action.Council of Europe, New ISBN Publication - Means To Counter Education Fraud - Etined Volume 7.Council of Europe, Means To Counter Education Fraud: Legislation, practices and instruments: Volume 7.Council of the European Union, Anti-money laundering: Council and Parliament agree on procedure to select seat for new authority.Department of Justice, Former Special Agent In Charge Of The New York FBI Counterintelligence Division Sentenced To 50 Months In Prison For Conspiring To Violate U.S. Sanctions On Russia.Department of Justice, Metro-Atlanta man pleads guilty to money laundering of COVID-19 unemployment funds.Department of Justice, Dallas County individuals indicted in investment fraud and money laundering scheme.Department of Justice, United Kingdom Citizen Extradited to Face Charges in $99 Million Wine Fraud.Department of Justice, Seven Individuals Indicted on Fraud and Money Laundering Charges Relating to International Lottery Scam Targeting Elderly.Department of Justice, Justice Department Announces Crackdown on Networks That Steal Money from Consumer Accounts and Use Fraudulent “Microtransactions” to Hide the Activity from Banks.Department of Justice, Manvel resident charged for creating fake businesses to obtain COVID-19 funds.Department of Justice, Man Charged for $2M COVID-19 Relief Fraud Scheme.Department of the Treasury, Remarks by Under Secretary for Terrorism and Financial Intelligence Brian Nelson at Bank Roundtable in Mumbai, India.European Commission, EU adopts 12th package of sanctions against Russia for its continued illegal war against Ukraine.European Council, Russia's war of aggression against Ukraine: EU adopts 12th package of economic and individual sanctions.Europol, IOCTA – Online Fraud Schemes: A Web of Deceit.Financial Crimes Enforcement Network, Beneficial Ownership Information Access and Safeguards.Insolvency Service, Couple sentenced for abusing Covid loan then dissolving their company.Insolvency Service, Annual Report and Accounts 2022-2023.Interpol, USD 300 million seized and 3,500 suspects arrested in international financial crime operation.Office of Financial Sanctions Implementation, Financial Sanctions Notice (Iran).Office of Financial Sanctions Implementation, Financial Sanctions Notice (Russia).Office of Financial Sanctions Implementation, Guidance: Who is subject to financial sanctions in the UK?Office of Financial Sanctions Implementation, General Licences.Office of Financial Sanctions Implementation, OFSI Publishes Details of Frozen Asset Reporting for Financial Year 2022-23.Office of Financial Sanctions Implementation, Guidance: Russian Oil Services ban.Office of Financial Sanctions Implementation, Financial Sanctions Notice (Russia).Office of Financial Sanctions Implementation, Updates to Correspondent Banking Restrictions (blog post).Office of Financial Sanctions Implementation, UK Financial Sanctions: General guidance for financial sanctions under the Sanctions and Anti-Money Laundering Act 2018.Office of Financial Sanctions Implementation, Russia Guidance: Guidance for the financial and investment restrictions in Russia (Sanctions) (EU Exit) Regulations 2019.Office of Financial Sanctions Implementation, OFSI enforcement and monetary penalties for breaches of financial sanctions: Guidance.Office of Financial Sanctions Implementation, General Licence – Continuation of Business of Evraz plc's North American Subsidiaries (INT/2022/1710676).Office of Foreign Assets Control, Treasury Sanctions Human Smuggling and Drug Trafficking Organization Operating on Southwest Border.Office of Foreign Assets Control, Treasury Tightens the Price Cap with New Sanctions and Updated Guidance.Payment Systems Regulator, PSR continues to take bold action on APP fraud as it publishes final reimbursement details ahead of 2024 implementation.Securities and Exchange Commission, SEC Charges Former CEO of Medical Device Startup Stimwave with $41 Million Fraud.UK Judgments, Ames v Rex (Serious Fraud Office) [2023] EWCA Crim 1463.UK Judgments, Eurasian Natural Resources Corporation Limited v Dechert LLP, David Neil Gerrard, and The Director of the Serious Fraud Office [2023] EWHC 3280.UK legislation, Russia (Sanctions) (EU Exit) (Amendment) (No 5) Regulations 2023 (SI 2023/1367).UK legislation, The Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2023 (SI 2023/1364).United Nations, ‘Illegal betting is the number one factor fuelling corruption in sports', UN conference hears.Wilmer Hale, Congress Enacts the Foreign Extortion Prevention Act Targeting Foreign Officials' Conduct. 

NCUA Chairman Todd M. Harper's Written Testimony Before the House Financial Services CommitteeNCUA Chairman Todd M. Harper testifying before the House Financial Services Committee in 2023.Chairman McHenry, Ranking Member Waters, and members of the committee, thank you for inviting me to discuss the work of the National Credit Union Administration (NCUA).The NCUA insures deposits at federally insured credit unions, protects credit union members, and charters and regulates federal credit unions. The NCUA also protects the safety and soundness of the credit union system by identifying, monitoring, and managing risks to the National Credit Union Share Insurance Fund (Share Insurance Fund). In my testimony today, I will discuss the state of the credit union system, recent efforts by the agency to strengthen the system, and several legislative requests.State of the Credit Union SystemThe credit union system over the last year has remained largely stable in its performance and relatively resilient against economic disruptions. However, during the last few quarters, the NCUA has seen growing signs of financial strain on credit union balance sheets and in household budgets. Economists are also forecasting an economic slowdown as the lagged effects of elevated interest rates take hold. Each of these developments could affect credit union performance in the coming quarters.Over the same period, the NCUA has also seen growing stress within the system because of a rise in interest rate and liquidity risks. In fact, this financial stress is reflected in the increasing number of composite CAMELS code 3, 4, and 5 credit unions.1 Assets in composite CAMELS code 3 institutions increased sizably in the second quarter, especially among those complex credit unions with more than $500 million in assets. Such increases may well continue in future quarters. We have additionally seen more credit unions fall into the composite CAMELS code 4 and 5 ratings during the second quarter.Credit Union System PerformanceAs of June 30, 2023, the system's net worth ratio stood at 10.63 percent. There was continued year-over-year growth in assets and lending, with system assets surpassing $2.2 trillion and outstanding loans at more than $1.5 trillion. Although insured shares and deposits decreased slightly compared to the previous quarter, they stood almost 2 percent higher than one year earlier.Second quarter data also demonstrate some indications of growing consumer financial stress. The delinquency rate for loans rose slightly to 63 basis points, although it remains below historic averages. Credit cards and automobile loans, however, show increased delinquency levels at 154 and 67 basis points, respectively. Additionally, net charge-off levels have risen over the last year, returning to pre-pandemic averages.Additionally, funding costs for credit unions have increased significantly in the rising interest rate environment. Credit unions have increased their issuances of time deposits, leading to total interest expenses growing substantially over the year. However, the industry's return on average assets remains sound at 79 basis points. Together, these numbers show the credit union system continues to rest on a solid footing.External Factors Affecting the SystemThe NCUA is closely monitoring the financial markets and the economy as the current environment has created challenges for some consumers and credit unions. Inflation and interest rates are affecting household budgets, which could lead to an increase in credit risk in future quarters. In addition, the prevalence of hybrid work environments has placed pressure on commercial real estate lending. While the credit union system overall has modest exposure to this type of lending, the NCUA is closely monitoring individual credit unions with material exposure to commercial real estate.The rise in interest rates has also increased liquidity and interest rate risks in the credit union system, including at several of the 421 federally insured credit unions with more than $1 billion in assets. Accordingly, the NCUA has emphasized the importance of liquidity risk management and contingency planning in its industry communications and will continue to ensure credit unions conduct liquidity and asset-liability management planning to address current challenges and future uncertainties.With respect to all these risks and to protect the Share Insurance Fund against potential losses, the NCUA will continue to vigilantly monitor credit union performance through the examination process, offsite monitoring, and tailored supervision. The NCUA will also, when appropriate, take action to protect credit union members and their deposits.Share Insurance Fund PerformanceBacked by the full faith and credit of the United States, the Share Insurance Fund provides insurance coverage for individual accounts at federally insured credit unions up to $250,000.2 As of June 30, 2023, the Share Insurance Fund insured $1.7 trillion in deposits and shares. Notably, the Share Insurance Fund protects nearly 92 percent of total share deposits in the credit union system. In comparison, uninsured shares and deposits equaled approximately $160 billion in the second quarter or 8 percent of total share deposits.The Share Insurance Fund continues to perform well, with no premiums currently expected. As of June 30, 2023, the Share Insurance Fund reported a year-to-date net income of $79 million, a net position of $20.3 billion, and an equity ratio of 1.27 percent.3 The NCUA projects that the equity ratio of the Share Insurance Fund will end the year at 1.27 percent, which is sufficient but below the 1.33 percent normal operating level target set by the NCUA Board.Given the liquidity events in 2023, economic conditions, and the growing stress in the credit union system from liquidity and interest rate risks, the NCUA Board decided to build up the liquidity position of the Share Insurance Fund to a targeted amount of $4 billion. The Share Insurance Fund reached that target in September. The NCUA Board continues to monitor liquidity in the Share Insurance Fund.State of the Central Liquidity FacilityThe COVID-19 pandemic, inflationary pressures, interest rate volatility, and liquidity risk have all underscored the importance of the NCUA's Central Liquidity Facility (CLF).4 The CLF is an important tool and acts as a shock absorber when unexpected liquidity events occur.Under the NCUA's regulations, credit unions with assets more than $250 million must have access to a federal emergency liquidity source as part of their contingency funding plans. This federal emergency liquidity backstop can be the CLF, the Federal Reserve's Discount Window, or both. Credit unions with less than $250 million in assets are not required to have membership with a contingent federal liquidity source; however, they must identify external sources as part of their liquidity policy.5As of September 30, 2023, the CLF had 399 consumer credit union members, providing $19.8 billion in lending capacity. These credit unions range in asset size from less than $50 million to more than $10 billion. Their access to the CLF helps protect approximately $360 billion in credit union members' assets.The more members the CLF has, the more effective it is as a liquidity facility. As of December 2022, the CLF had a much greater total membership of 3,673 consumer credit unions with a combined $537 billion in member assets and a lending capacity of $27.5 billion. This rapid decline in membership assets followed the expiration of the temporary statutory enhancements that: Increased the CLF's maximum legal borrowing authority; Permitted access for corporate credit unions, as agent members, to borrow for their own needs; Provided greater flexibility and affordability to agent members to join the CLF to serve smaller groups of their covered institutions; and Gave the NCUA Board the clarity and flexibility about the loans it can approve by removing the phrase, “the Board shall not approve an application for credit the intent of which is to expand credit union portfolios.” Among other benefits, these statutory provisions facilitated agent membership of corporate credit unions. These enhancements, however, ended on January 1, 2023, resulting in 3,322 credit unions with less than $250 million in assets losing access to the CLF. Consequently, the CLF's borrowing capacity has decreased by almost $10 billion.To address this expiration and growing liquidity risks, the NCUA Board has unanimously requested that Congress allow corporate credit unions to purchase capital stock in the CLF to help smaller credit unions access to the facility. This change would make the CLF more affordable for corporate credit unions subscribing for a subset of their members. The Congressional Budget Office has scored the CLF reforms at no cost to taxpayers.6NCUA's Efforts to Protect and Strengthen the Credit Union SystemIn recent months, the NCUA has undertaken several actions to respond to cybersecurity risk; support minority depository institutions; enhance the credit union system's and the NCUA's diversity, equity, and inclusion efforts; and consider and adopt new rules to strengthen the system.Enhancing CybersecurityCybersecurity threats within the financial services industry are high and expected to remain so for the foreseeable future. To maintain vigilance against these threats, the NCUA is committed to ensuring consistency, transparency, and accountability in its cybersecurity examination program and related activities.Earlier this year, the NCUA deployed its updated, scalable, and risk-focused Information Security Examination (ISE) procedures. The ISE examination initiative offers flexibility for credit unions while providing examiners with standardized review steps to facilitate advanced data collection and analysis. Together with the agency's voluntary Automated Cybersecurity Evaluation Toolbox maturity assessment, the new ISE procedures will assist the NCUA in protecting the credit union system from cyberattacks.In addition, the NCUA's recently implemented cyber incident reporting rule has proven to be helpful to the agency and credit union industry.7 The final rule requires a federally insured credit union to report a substantial cyber incident to the NCUA as soon as possible but no later than 72 hours after the credit union reasonably believes a reportable cyber incident has occurred. In the first 30 days after the rule became effective, the NCUA received 146 incident reports, more than it had received in total in the previous year. More than 60 percent of these incident reports involve third-party service providers and credit union service organizations (CUSOs).The NCUA also actively communicates with credit unions about the increased likelihood of cyberattacks resulting from geopolitical and other cyber events. Credit unions of all sizes are a part of the U.S. critical infrastructure and should implement appropriate controls in the technology they use to deliver member services.Maintaining Consumer Financial ProtectionAn important part of the NCUA's mission is to examine credit unions with less than $10 billion in assets for compliance with consumer financial protection laws. The agency's consumer compliance efforts are integral to maintaining a safe-and-sound credit union system.In 2023, the agency's consumer financial protection supervisory priorities have included overdraft protection, fair lending, residential real estate appraisal bias, and Truth in Lending Act and Fair Credit Reporting Act compliance. The NCUA also prioritized examining credit union compliance with the Flood Disaster Protection Act, including disclosure requirements.In addition, the agency increased its review of overdraft programs and non-sufficient funds fee practices at credit unions to assess whether providing those services and charging the fees are potentially unfair practices. The NCUA's supervision of the services aims to create a more equitable system that supports financial stability for credit union members, improves transparency, and advances the statutory mission of credit unions to meet the credit and savings needs of their members, especially those of modest means.8Furthermore, the NCUA conducts targeted fair lending examinations and supervision at federal credit unions to assess compliance with federal fair lending laws and regulations. These reviews are critical to identifying discrimination and fostering financial inclusion. In August 2023, the NCUA encouraged the industry to review and comply with previously issued guidance addressing prohibited discriminatory practices in automated underwriting systems. Specifically, the agency encouraged credit unions to review system parameters to ensure compliance with the Equal Credit Opportunity Act and its implementing regulation.In addition to appraisal bias oversight examinations, the NCUA joined with the other Federal Financial Institution Examination Council agencies in June to issue proposed guidance for reconsideration of value for residential real estate valuations. The proposed guidance advises on policies that financial institutions may implement to allow consumers to provide information that may not have been considered during an appraisal or if deficiencies are identified in the original appraisal.As part of its consumer financial protection efforts, the NCUA's Consumer Assistance Center also resolves consumer complaints against federal credit unions with total assets up to $10 billion and, in certain instances, federally insured, state-chartered credit unions. In 2022, the Consumer Assistance Center responded to 10,589 written complaints, 1,842 inquiries, and 30,232 telephone calls from consumers and credit unions concerning consumer financial protection regulations.Finally, the NCUA regularly presents webinars promoting financial literacy and financial inclusion. Over the past year, the agency has hosted webinars on appraisal bias, elder financial abuse, and minority depository institutions. In addition, the agency participates in national financial literacy initiatives, including the interagency Financial Literacy and Education Commission.Supporting Minority Depository InstitutionsSupporting minority depository institution (MDI) credit unions is a longstanding priority for the NCUA. MDI credit unions represent approximately 10 percent of federally insured credit unions, and there are presently 498 such credit unions. These MDIs have more than five million members and exceed $66 billion in assets.In 2015, the NCUA established its MDI Preservation Program and has since sought new ways to assist MDI credit unions, their members, and the communities they serve. In 2022, the NCUA launched the Small Credit Union and MDI Support Program, allocating resources to assist MDIs in addressing operational challenges such as staff training, examinations, and improving earnings. In 2023, the NCUA allocated 10,000 staff hours across its three regional offices for the program.This year, the agency also issued customized guidance to examiners to provide insights into MDIs' unique business models and members' needs. The guidance assists examiners in understanding MDIs' distinct business model compared to other mainstream financial institutions by providing instruction on how to use MDI peer metrics instead of traditional peer metrics.Notably, while MDIs tend to be smaller institutions, they have relatively strong financial performance. As of the end of the second quarter of this year, MDIs averaged about $133 million in total assets, yet their return on average assets and net worth ratios were higher than federally insured credit unions overall and equal to credit unions with assets exceeding $1 billion. Meanwhile, their charge-off levels were consistent with the levels reported for both larger credit unions and credit unions overall.Congress recently authorized all MDIs to be eligible for Community Development Revolving Loan Fund grants and loans. Previously, MDIs required the low-income credit union designation to qualify. In the 2023 grant round, 42 MDIs received more than $1.4 million in technical assistance grants. The amount of funding MDIs received was a five-fold increase from the level of funding provided in 2022.Finally, the NCUA in October hosted an MDI Symposium that discussed how the agency can better serve these institutions. The MDI Symposium brought together MDI credit unions and industry stakeholders to learn about the challenges faced by MDIs. Sessions included case studies of successful MDI business models for replication. The NCUA plans to leverage this information to further support its MDI Preservation Program. And, as part of the NCUA's Diversity, Equity, and Inclusion Summit for credit unions in early November, the NCUA held a session that discussed MDI challenges and strategies for success.Advancing Diversity, Equity, and InclusionThe NCUA is fully committed to fostering diversity, equity, and inclusion (DEI) within the agency and the credit union system.The agency uses data from the Federal Employee Viewpoint Survey, including the Office of Personnel Management's Diversity, Equity, Inclusion, and Accessibility index, to inform its data-driven DEI strategies and activities.9 The agency's internal practices to promote DEI are also wide-ranging. For example, the NCUA's employee resource groups serve more than 30 percent of agency staff, surpassing the industry standard membership goal of 10 percent. Further, the NCUA's special emphasis program educates staff on cultural diversity and provides dedicated support for employees and managers with disabilities.In addition, the NCUA routinely recruits employees with diverse backgrounds and seeks to ensure broad applicant pools for vacancies. These diversity recruitment efforts are aimed at attracting and retaining highly qualified individuals from underrepresented groups, including Hispanics and candidates with disabilities. In 2023, the NCUA conducted a targeted barrier analysis to identify hiring and retention challenges for women and Hispanic employees. In addition, the agency has consistently exceeded the federal employment rate goals for employees with disabilities and targeted disabilities since 2017.10 Slightly more than 59 percent of the NCUA's managers are women.The NCUA has additionally built a diverse supplier network to obtain innovative solutions and the best value, particularly in technology and IT solutions. During 2022, the agency awarded $32.8 million of reportable contract dollars to minority and women-owned businesses. That figure represents 45 percent of the agency's contracting dollars, an increase of 8 percentage points from the prior year.Credit unions may also assess their DEI policies and programs through a voluntary credit union diversity self-assessment offered annually.11 Credit union submissions of their self-assessment have no bearing on their CAMELS rating, and examiners cannot access the data. The NCUA reports credit union diversity data only in the aggregate. The agency encourages credit unions to use this tool to support their DEI efforts.In 2022, 481, or 10 percent of all credit unions, submitted a self-assessment. The figure represents an all-time high for submissions to the NCUA. Of those submissions, 302 were federally chartered credit unions, 178 were federally insured and state-chartered, and one was a non-federally insured, state-chartered credit union. The number of CUDSA responses in 2022 is twice as much as the 240 self-assessments submitted in 2021.Finally, to support credit union accomplishments in DEI and provide further guidance, the NCUA hosted its fourth DEI Summit in Washington, D.C., in early November. This now annual event provided a forum for hundreds of credit union stakeholders to network, share best practices, and meet with thought leaders on ways to expand their DEI efforts. The event also highlighted the importance of allyship in helping to achieve the NCUA's and credit unions' DEI goals and improve the financial prospects and futures of families across the country.Rulemaking ActivitiesSince May, the NCUA Board has engaged in several rulemakings on topics like MDI preservation, member expulsion, financial innovation, fair hiring, and charitable donations. These rulemakings have aimed to implement laws required by Congress and strengthen the credit union system.In May, the NCUA Board approved a proposed rule that would add “war veterans' organizations” to the definition of a “qualified charity” that a federal credit union may contribute to using a charitable donation account. The NCUA Board approved the proposed rule noting the attributes of “veterans' organizations” as defined by section 501(c)(19) of the Internal Revenue Code are aligned with the purposes of the current charitable donation account rule. A “qualified charity” is a section 501(c)(3) entity defined by the Internal Revenue Code and must be both a non-profit and be organized for a charitable purpose. The final rule will be considered on November 16.In June, the NCUA Board approved proposed changes to the interpretive ruling and policy statement on the agency's Minority Depository Institution Preservation Program. The proposal would amend an existing interpretive ruling and policy statement to update the program's features, clarify the requirements for a credit union to receive and maintain an MDI designation, and reflect the transfer of the MDI Preservation Program administration from the agency's Office of Minority and Women Inclusion to its Office of Credit Union Resources and Expansion. Proposed amendments to the interpretive ruling and policy statement also include incorporating recent program initiatives, providing examples of technical assistance an MDI may receive, establishing a new standard for MDIs to assess their designation periodically, and updating how the NCUA will review an MDI's designation status, among other changes. This rule is pending.Additionally, the Board finalized a rule in July to implement requirements of the Credit Union Governance Modernization Act of 2022.12 This regulation streamlines procedures for credit unions to expel a member in cases of serious misconduct.In September, the NCUA Board approved a financial innovation final rule that provides flexibility for federally insured credit unions to utilize advanced technologies and opportunities offered by the financial technology sector. The final rule specifically provides credit unions with options to participate in loans acquired through indirect lending arrangements and financial technology. With the adoption of this final rule, the limits previously found in the NCUA's regulations are replaced with policy, due diligence, and risk-management requirements that can be tailored to match each credit union's risk levels and activities.Lastly, the NCUA Board in October approved a proposed rule that would incorporate the NCUA's Second Chance Interpretive Ruling and Policy Statement, and statutory prohibitions imposed by Section 205(d) of the Federal Credit Union Act into the agency's regulations. This proposed rule would allow people convicted of certain minor offenses to work in the credit union industry without applying for the NCUA Board's approval. It would also amend requirements governing the conditions under which newly chartered or troubled federally insured credit unions must notify the NCUA of proposed changes to their board of directors, committee members, or senior executive staff. The comment period closes on January 8, 2024.Legislative RequestsWhile the credit union system continues to perform well overall, several amendments to the Federal Credit Union Act would provide the NCUA with greater flexibility to effectively regulate the credit union system and protect the Share Insurance Fund in light of an evolving economic environment, a changing marketplace, and technological advancements.Central Liquidity Facility ReformsAs noted previously, the NCUA Board unanimously supports a statutory change to restore the ability of corporate credit unions to serve as CLF agents on behalf of a subset of their member credit unions. Such legislation would better allow the CLF to serve as a shock absorber for liquidity events within the credit union system.On February 28, 2023, lawmakers introduced bipartisan legislation that would allow corporate credit unions to purchase CLF capital stock on behalf of a subset of their members.13 This legislation would permit corporate credit unions to contribute capital to provide coverage for smaller members with less than $250 million in assets. Liquidity risks within the credit union system are rising, and timely consideration of this bill would better protect the credit union system from future liquidity events.Restoration of Third-Party Vendor AuthorityThe risks resulting from the NCUA's lack of vendor authority are real, expanding, and potentially dangerous for the nation's financial infrastructure. Other independent entities, including the Government Accountability Office, the Financial Stability Oversight Council, and the NCUA's Office of Inspector General, have identified this deficiency as inhibiting the NCUA from fulfilling its mission to safeguard credit union members and the financial system. And, it is the NCUA Board's continuing policy to seek third-party vendor authority from Congress.14The agency is working within its current authority to address this growing regulatory blind spot, but it is evident that additional authority is needed. There has also been a shift in credit union leaders' understanding of the value of the NCUA having the same vendor authority as the federal banking agencies. The benefits include credit union access to NCUA examination information when conducting due diligence of vendors, fewer requests from the NCUA to credit unions to intervene with vendors experiencing problems, and fewer losses to the Share Insurance Fund.The potential for such resulting losses to the Share Insurance Fund is real. The NCUA's Office of Inspector General stated that between 2008 and 2015, nine CUSOs contributed to material losses to the Share Insurance Fund. The report noted one of the CUSOs caused losses in 24 credit unions, some of which failed. According to NCUA staff calculations, at least 73 credit unions incurred losses between 2007 and 2020 as losses at CUSOs roll onto credit union ledgers and lead to liquidations.15The absence of third-party vendor examination authority limits the NCUA's ability to assess and mitigate potential risks associated with these vendors. Vendors typically decline these requests or refuse to implement recommended actions. This limitation exacerbates any exposure credit unions have to the operational, cybersecurity, and compliance risks that can arise from these relationships. Without the authority to enforce recommended corrective actions, the NCUA is unable to effectively protect credit unions and their members.Furthermore, the growing reliance on third-party services in the credit union industry poses a systemic risk to the credit union system. Five core banking processors, for example, handle more than 90 percent of the credit union system's assets. A failure of one of these critical third parties could cause hundreds of credit unions and potentially tens of millions of their members to lose access to their funds simultaneously. Such a vendor failure, in turn, may result in a loss of confidence in the financial sector. Ensuring proper oversight is imperative, as CUSOs and third-party vendors are poised to capitalize on financial institutions' growing appetite for artificial intelligence and real-time payment services.If granted third-party vendor authority, the NCUA would implement a risk-based examination program focusing on services that relate to safety and soundness, cybersecurity, Bank Secrecy Act and Anti-Money Laundering Act compliance, consumer financial protection, and areas posing significant financial risk for the Share Insurance Fund.Additional Flexibility for Administering the Share Insurance FundThe recent turmoil in the banking sector, growing liquidity risks within the credit union system, and rising interest rate risk all highlight the need for the NCUA to have additional flexibility for administering the Share Insurance Fund.Specifically, the NCUA requests amending the Federal Credit Union Act to remove the 1.50 percent ceiling for the Share Insurance Fund's equity ratio from the current statutory definition of “normal operating level,” which limits the ability of the Board to establish a higher normal operating level for the Share Insurance Fund. A statutory change should also remove the limitations on assessing Share Insurance Fund premiums when the equity ratio of the Share Insurance Fund is greater than 1.30 percent and if the premium charged exceeds the amount necessary to restore the equity ratio to 1.30 percent.16Together, these amendments would bring the NCUA's statutory authority over the Share Insurance Fund more in line with the FDIC's authority as it relates to administering the Deposit Insurance Fund. These amendments would also better enable the NCUA Board to proactively manage the Share Insurance Fund by building reserves during economic upturns so that sufficient money is available during economic downturns. This more counter-cyclical approach to managing the Share Insurance Fund would better ensure that credit unions will not need to impair their one percent contributed capital deposit or pay premiums during times of economic stress, when they can least afford it.ConclusionThe NCUA stands ready to address the impact of the evolving economic and business cycles within the credit union system. The NCUA will continue to monitor credit union performance and coordinate with other federal financial institution regulators, as appropriate, to ensure the overall resiliency and stability of our nation's financial services system and economy.Thank you again for the invitation to testify about the NCUA's programs and operations. 

Today's blockchain and cryptocurrency news Bitcoin is up slightly at $36,496 Eth is up slightly at $1,954 Binance Coin is down slightly at $243 Senator  Elizabeth Warren continues her narrative of crypto is bad. FTX creditors may ultimately see more $ than expected Kronos Research suffers exploit. dYdX loses part of insurance fund in market manipulation OpenChat to test facial recognition. Get 15% off OneSkin with the code DCR at https://www.oneskin.co/ #oneskinpod Learn more about your ad choices. Visit megaphone.fm/adchoices

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.

Hello, and welcome to episode 69 of the Financial Crime Weekly Podcast, I'm your host, Chris Kirkbride. It's been quite a very quiet week this week. I think most sensible people must be on holiday. Still, I have managed to find just enough financial crimes news to keep things ticking over. Let's crack on. As usual, I have linked the main stories flagged in the podcast in the description. These are: BBC News, Bank staff defy customers to prevent £55m of fraud in 2022.Crown Prosecution Service, A former Governor of Nigeria's Delta State has been ordered to pay over £100 million and his solicitor over £28 million.European Commission, Evaluation of Directive 2018/1673.Financial Conduct Authority, FCA secures Confiscation Order against convicted money launderer.Home Office, UK-Australia joint statement from the Illicit Financing Co-ordination Dialogue.Office of Financial Sanctions Implementation, UK Financial Sanctions: General guidance for financial sanctions under the Sanctions and Anti-Money Laundering Act 2018.Office of Financial Sanctions Implementation, General Licence – Mongolia Energy Payments INT/2022/2085212.Office of Financial Sanctions Implementation, Financial Sanctions Notice: ISIL (Da'esh) and Al-Qaida.Office of Financial Sanctions Implementation, Guidance: Who is subject to financial sanctions in the UK?Office of Foreign Assets Control, Counter Terrorism Designation: Specially Designated Nationals List Update.Office of Foreign Assets Control, Treasury Targets Malian Officials Facilitating Wagner Group.Office of Foreign Assets Control, Russia-related Designations: Specially Designated Nationals List Update.Serious Fraud Office, Notice of discontinuance: G4S Care & Justice Services (UK) Limited.Solicitors' Regulation Authority, Sectoral Risk Assessment: Anti-money laundering and terrorist financing.UK Finance, Over £55 Million of Fraud Prevented in 2022 by Rapid Response Scheme.UK Finance, Why the Banking Protocol Matters.US Attorney's Office, British Investor and Billionaire Businessman Joseph Lewis Charged with Insider Trading and Financial Fraud.US Department of State, Designating Senior ISIS-Somalia Financier.

Today in Daily Web 3 News: We are going over the top news for Wednesday, May 31st. Hosted on Acast. See acast.com/privacy for more information.

Mark Penrith interviews Michael Swain, of ForSA regarding the Anti-Money Laundering Act Michael Swain is the Executive Director of ForSA. He studied law abroad, has been successful in business, and is a co-founder of the His People/Every Nation church movement in South Africa. FOR SA (Freedom of Religion South Africa) is a legal advocacy organisation working to protect and promote the constitutional right to religious freedom in South Africa. Live stream · Full episode · FORSA · Table Talk

OUTLINE of today's show with TIMECODES Why is alt media so excited that Tucker Carlson finally realizes the CIA killed JFK? 2:05 Ken explains why we need to be careful not to put our trust in people who have character issues.9:46 Listener: "The military has a saying: 'Leave no man behind' - we've left behind JFK, 9/11 victims"14:29 Tucker Carlson: “In 5 years every fifth grader will believe that 911 was committed by white supremacists”. But does Tucker STILL dismiss the mountain of 9/11 evidence as he did 10 yrs ago?24:46 Tucker Carlson's discounts 9/11 Truth because…in his own words… 28:42FBI said they didn't have Seth Rich's laptop data. They lied. Then they said they didn't have his laptop. They lied. Now they say they won't comply with FOIA order about the laptop b/c the laptop is not "a record" but "physical object". Are these the same people who are killing Assange?35:13 Could a gel made out of human protein create the next generation of bullet-proof body armor? It's better than any bullet proof vest45:12 Fauxcahontas jumps in with Republican Marshall to take advantage of the FTX collapse with a proposed Anti-Money Laundering Act treating crypto, not the Democrat Party, as criminal53:27 Lawsuit seeks to get Republican state legislator removed merely for having been a member of Oath Keepers (he never attended Jan6). Former FBI agent takes on clueless "experts" on "extremism" in court testimony.1:05:01Open borders, Dreamers, and the Death of the American Dream1:17:56 Tennessee has put right to work in the state constitution. To show why NOT being forced to join a union is important, here's my personal experience with how that worked1:23:25 Gates & Bezos invest in yet another Brain-Computer Interface company to rival Neuralink. Why are these billionaires obsessed with mind control?1:33:17 Yet ANOTHER study showing that masks don't work for surgeons conducting surgery — actually makes things WORSE.1:45:58Public health officials and media are pushing masks AGAIN, in a big way1:53:27 David Stockman (former Reagan official) destroys the lockdown and the politicians who imposed it2:02:31The new normal is an admission that we failed to stop a virus that is now circulating amongst us.2:09:07 Press and GOP establishment come after DeSantis for changing sides on the vaccine. While he's moving in the right direction, we should remember what he was saying about the vaccine just a few months ago. 2:13:44 More BigPharma deaths — Remdesivir is not safe and could be fatal to Fauci's as Mr. Science. It's far easier to prove corruption with Remdesivir than with any of his other crimes. 2:21:41 A nanotech "solution" for obesity.2:31:11Dr. Ryan Cole's study: what's in the vaccines.2:36:07 When mRNA TrumpShots are not stored at -90F, do they become ineffective or do they become toxic?2:44:08Kissinger warns NATO about both World War 3 and autonomous killer robots2:56:22Find out more about the show and where you can watch it at TheDavidKnightShow.com If you would like to support the show and our family please consider subscribing monthly here: SubscribeStar https://www.subscribestar.com/the-david-knight-showOr you can send a donation through Zelle: @DavidKnightShow@protonmail.comCash App at: $davidknightshowBTC to: bc1qkuec29hkuye4xse9unh7nptvu3y9qmv24vanh7Mail: David Knight POB 994 Kodak, TN 37764Money is only what YOU hold: Go to DavidKnight.gold for great deals on physical gold/silver

OUTLINE of today's show with TIMECODES Why is alt media so excited that Tucker Carlson finally realizes the CIA killed JFK? 2:05 Ken explains why we need to be careful not to put our trust in people who have character issues.9:46 Listener: "The military has a saying: 'Leave no man behind' - we've left behind JFK, 9/11 victims"14:29 Tucker Carlson: “In 5 years every fifth grader will believe that 911 was committed by white supremacists”. But does Tucker STILL dismiss the mountain of 9/11 evidence as he did 10 yrs ago?24:46 Tucker Carlson's discounts 9/11 Truth because…in his own words… 28:42FBI said they didn't have Seth Rich's laptop data. They lied. Then they said they didn't have his laptop. They lied. Now they say they won't comply with FOIA order about the laptop b/c the laptop is not "a record" but "physical object". Are these the same people who are killing Assange?35:13 Could a gel made out of human protein create the next generation of bullet-proof body armor? It's better than any bullet proof vest45:12 Fauxcahontas jumps in with Republican Marshall to take advantage of the FTX collapse with a proposed Anti-Money Laundering Act treating crypto, not the Democrat Party, as criminal53:27 Lawsuit seeks to get Republican state legislator removed merely for having been a member of Oath Keepers (he never attended Jan6). Former FBI agent takes on clueless "experts" on "extremism" in court testimony.1:05:01Open borders, Dreamers, and the Death of the American Dream1:17:56 Tennessee has put right to work in the state constitution. To show why NOT being forced to join a union is important, here's my personal experience with how that worked1:23:25 Gates & Bezos invest in yet another Brain-Computer Interface company to rival Neuralink. Why are these billionaires obsessed with mind control?1:33:17 Yet ANOTHER study showing that masks don't work for surgeons conducting surgery — actually makes things WORSE.1:45:58Public health officials and media are pushing masks AGAIN, in a big way1:53:27 David Stockman (former Reagan official) destroys the lockdown and the politicians who imposed it2:02:31The new normal is an admission that we failed to stop a virus that is now circulating amongst us.2:09:07 Press and GOP establishment come after DeSantis for changing sides on the vaccine. While he's moving in the right direction, we should remember what he was saying about the vaccine just a few months ago. 2:13:44 More BigPharma deaths — Remdesivir is not safe and could be fatal to Fauci's as Mr. Science. It's far easier to prove corruption with Remdesivir than with any of his other crimes. 2:21:41 A nanotech "solution" for obesity.2:31:11Dr. Ryan Cole's study: what's in the vaccines.2:36:07 When mRNA TrumpShots are not stored at -90F, do they become ineffective or do they become toxic?2:44:08Kissinger warns NATO about both World War 3 and autonomous killer robots2:56:22Find out more about the show and where you can watch it at TheDavidKnightShow.com If you would like to support the show and our family please consider subscribing monthly here: SubscribeStar https://www.subscribestar.com/the-david-knight-showOr you can send a donation through Zelle: @DavidKnightShow@protonmail.comCash App at: $davidknightshowBTC to: bc1qkuec29hkuye4xse9unh7nptvu3y9qmv24vanh7Mail: David Knight POB 994 Kodak, TN 37764Money is only what YOU hold: Go to DavidKnight.gold for great deals on physical gold/silver

Senator Warren introduces a new crypto bill, Canada bans margin crypto trading, PartyDAO refreshes its PartyBid app, and PayPal integrates with MetaMask. Newsletter: https://ethdaily.substack.com

After reviewing how the AMLA expands the BSA's goals, we look at which AMLA provisions have the most impact on BSA compliance, including the AMLA's emphasis on information sharing, the Financial Crimes Enforcement Network's “national priorities” and the value of threat pattern and trend information to bank compliance efforts, and the AMLA's expansion of the U.S. government's authority to subpoena information from foreign financial institutions that maintain correspondent banking relationships with U.S. banks. We also review the CTA's new beneficial ownership reporting requirements and discuss how they interact with existing customer due diligence (CDD) requirements and the need to align CTA and CDD regulations. Peter Hardy and Terence Grugan, Ballard Spahr partners and co-leaders of the firm's AML Team, host the conversation.

In this episode, we welcome back Maya Lester KC, barrister at Brick Court Chambers, to teach a lesson on the Sanctions and Anti-Money Laundering Act. Maya walks us through the implications of leaving the European Union on UK sanctions, asset freezing financial sanctions, travel bans, trade sanctions, and much more. Join us to learn more about this fascinating jurisdiction and the ongoing developments of UK SAMLA.

Webcast URL: https://knowledgewebcasts.com/know-portfolio/bsa-aml-enforcement-trends-cle-2022/ In response to a prevailing view that the US was becoming a haven for money laundering, as well as emerging risks posed by advances in financial technology and the advent of virtual currencies, Congress passed the Anti-Money Laundering Act of 2020 (AMLA 2020) as part of the National Defense Authorization Act. AMLA 2020 represents the most significant changes to federal anti-money laundering legislation since the passage of the Patriot Act in 2001. Within this expansive new legislation is the Corporate Transparency Act, which created the framework for a nationwide registry for beneficial ownership. AMLA 2020 also created new mandates for reporting and record-keeping, expanded subpoenas of U.S. law enforcement, and enhanced the role of whistleblowers in detecting and reporting financial crime. These enhancements to existing anti-money laundering laws will force financial institutions to remain vigilant while increasing the compliance requirements for market “gatekeepers” previously unaffected by AML laws. Join a panel of key thought leaders and professionals assembled by The Knowledge Group as they delve into an in-depth analysis of the significant reforms proposed in AMLA 2020. Speakers will also provide comprehensive guidance on how to respond to these enhanced regulatory requirements. For any more information please click on the webcast URL at the top of this description.

This week, Kara Brockmeyer, partner in Debevoise & Plimpton's Washington, D.C. office, discusses the impact of the U.S. Anti-Money Laundering Act on anti-corruption compliance and enforcement. This podcast was recorded at TRACE's 2022 Forum, which brings together compliance professionals for meaningful discussions.

Former Senator and Arent Fox Counsel Doug Jones and former National Security Adviser and Arent Fox Counsel Cissy Jackson discuss the Anti-Money Laundering Act and what businesses should keep in mind moving forward. Highlights of the conversation include: Recent developments in the Anti-Money Laundering Act (the Act) Where things stand on the Act What the priorities of the Act are

Webcast URL: https://knowledgewebcasts.com/know-portfolio/bank-secrecy-act-title-31-regulations-cle/ Regulatory supervision of reporting companies is expected to intensify with the Anti-Money Laundering Act of 2020 (AMLA) amendment of Title 31 of the Bank Secrecy Act (BSA). Title 31 revisions include new BSA violations and penalties regarding incomplete or false reports and transactions that involve entities labeled as “primary money laundering concerns.” Reporting requirements concerning beneficial ownership and expansion of the U.S. law's authority to subpoena foreign banks have also been added. This notable regulatory development underscores the need for companies to have thorough record-keeping and reporting practices. They must also revisit their compliance programs to mitigate lapses and thwart potential criminal activities. In this LIVE webcast, financial regulatory compliance experts Maureen Kiedaisch (FTI Consulting, Inc.) and Ari Good, JD LLM (Good Attorneys At Law, P.A.) will provide a comprehensive discussion of the recent developments surrounding BSA Title 31 regulations. Speakers will also present critical issues and best practices to ensure compliance in today's increasingly complex regulatory landscape. For any more information please click on the webcast URL at the top of this description.

Tom Fox welcomes back Alexander Dill on this week's episode of the Innovation in Compliance Podcast. Alexander is a lecturer at UCLA, as well as an author and advisor, specializing in financial regulation, risk management, and compliance. Alexander and Tom talk about anti-money laundering and the key problems compliance professionals encounter. The Importance of Compliance Ratings Compliance Systems Compliance rating systems were created to measure accuracy and integrity. After the events of Enron and WorldCom, there was a general criticism of credit rating agencies. Moody's Investors Service, where Alexander spent a considerable amount of time working, got a great deal of that criticism due to the organization's poor ratings performance and its lack of fraud rating. Moody's wanted to continue to self-regulate as opposed to being regulated by the global regulators, and so the creation of these compliance systems helped with that. Alexander explains that the initial work that was done with respect to the ratings systems, helped lay the foundation for compliance when it became heavily regulated after the financial crisis of Dodd Frank. The Compliance Regulators Tom asks Alexander to explain the different types of regulators and what OFAC is. The main regulator for compliance is FinCen, which is the Financial Crimes Enforcement Network. FinCen is the primary rule making authority but delegates supervisory and examination authority to other agencies. Alexander goes on to list the other regulatory agencies. The regulatory agencies overlap, however the conflict that arises is that their objectives often do not align. "Banking agencies are focused on safety and soundness, and the law enforcement authorities spearheaded by FinCen focus on the law enforcement objective, so those don't always come together in a uniform manner," Alexander remarks.  The Role of Corporate Governance and Risk Management The main role of corporate governance in anti-money laundering is to maximize shareholder welfare. Corporate governance systems are designed to protect franchise value. The systems cover all material risks that arise from conflicts of interest within agencies. Risk management is important to anti-money laundering as it is a component of corporate governance. Alexander stresses that the risk management function should fit into the corporate governance framework to be effective. COVID-19 and Beyond The pandemic has impacted the field of anti-money laundering and compliance in many ways, but perhaps the most notable way is that it enhanced fraudulent schemes. With a great deal of the world's population migrating online, it opened up the pathway for various cyber attacks and cyber related crimes. COVID-19 unfortunately created various opportunities for people to exploit online platforms. Alexander hoped that in the future the Anti-Money Laundering Act that was introduced last year 2020, will begin to bear fruit and that red tech innovation and machine learning will help to curb these issues.  Resources Alexander Dill | LinkedIn | Twitter Check out Professor Dill's book, Anti-Money Laundering Regulation and Compliance here.   

In this episode of S&C's Critical Insights, Annie Ostrager and Kamil Shields discuss the recent increased focus by the Department of the Treasury, the Securities and Exchange Commission, and the Department of Justice on the use of whistleblowers in investigations involving alleged money laundering and corruption. Annie and Kamil address the role of whistleblowers in these matters from multiple angles, including regulatory, criminal and employment perspectives.

Sanctions are weapons of economic war. In this episode, learn the troubling history of ever-expanding sanctions powers granted to the President designed to allow him to cut off people, companies, and governments from our financial system. You'll also hear fascinating testimony to Congress about how the targets of U.S. sanctions are getting around them. Their evasion techniques are probably not what you think. Please Support Congressional Dish – Quick Links Click here to contribute monthly or a lump sum via PayPal Click here to support Congressional Dish for each episode via Patreon Send Zelle payments to: Donation@congressionaldish.com Send Venmo payments to: @Jennifer-Briney Send Cash App payments to: $CongressionalDish or Donation@congressionaldish.com Use your bank's online bill pay function to mail contributions to: 5753 Hwy 85 North, Number 4576, Crestview, FL 32536 Please make checks payable to Congressional Dish Thank you for supporting truly independent media! Recommended Congressional Dish Episodes CD230: Pacific Deterrence Initiative CD190: A Coup for Capitalism CD187: Combating China CD176: Target Venezuela: Regime Change in Progress CD167: Combating Russia (NDAA 2018) LIVE CD156: Sanctions – Russia, North Korea & Iran CD102: The World Trade Organization: COOL? Articles/Documents Article: HSBC's Money Laundering Scandal by Marc L. Ross, Investopedia, June 13, 2021 Document: Impact of Sanctions in Africa by Eric B. Lorber, House Committee on Foreign Affairs, Subcommittee on Africa, Global Health, and Global Human Rights, May 25, 2021 Document: FinCEN Reissues Real Estate Geographic Targeting Orders for 12 Metropolitan Areas by Financial Crimes Enforcement Network, April 29, 2021 Document: 2020 YEAR-END SANCTIONS AND EXPORT CONTROLS UPDATE by Gibson Dunn, February 5, 2021 Document: Economic Sanctions: Overview for the 117th Congress by Dianne E. Rennack and Rebecca M. Nelson, Congressional Research Service, January 15, 2021 Article: China's “Blocking Statute” – New Chinese Rules to Counter the Application of Extraterritorial Foreign Laws by Gibson, Dunn & Crutcher, January 13, 2021 Document: The International Emergency Economic Powers Act: Origins, Evolution, and Use by Dianne E. Rennack, Ian F. Fergusson, Jennifer K. Elsea, and Christopher A. Casey, Congressional Research Service, July 14, 2020 Document: International Criminal Court: U.S. Sanctions in Response to Investigation of War Crimes in Afghanistan by Dianne E. Rennack and Matthew C. Weed, Congressional Research Service, June 19, 2020 Article: US Treasury to Apply Bank Secrecy Act Rules to Crypto Wallets by Jeff Benson, Decrypt, December 18, 2020 Article: EU adopts a global human rights sanctions regime by Maria Daniela Lenzu, European Council, Council of the European Union, December 7, 2020 Article: The Global Magnitsky Human Rights Accountability Act by Edward J. Collins-Chas and Michael A. Weber, Congressional Research Service, December 7, 2020 Article: War brings business to Feinstein spouse / Blum's firms win multimillion-dollar defense contracts in Iraq, Afghanistan by Phillip Matier and Andrew Ross, SFGATE, January 20, 2012 Article: Feinstein Violated Rules in Awarding Military Contracts by Tom Fitton, The Hill, May 15, 2007 Press Release: Feinstein Caught in Conflict of Interest on Military Contracts by Association of Alternative News Media, January 25, 2007 Document: Document by Financial Services, U.S. House Additional Resources EB-5 OVERVIEW EB5Capital List of national emergencies in the United States Wikipedia Office of Foreign Assets Control - Sanctions Programs and Information U.S. Department of the Treasury Specially Designated Nationals And Blocked Persons List (SDN) Human Readable Lists U.S. Department of the Treasury The American Presidency Project UC Santa Barbara Customer Due Diligence Requirements for Financial Institutions Federal Register, May 11, 2016 Sound Clip Sources Speeches & Remarks: Remarks by President Biden in Press Conference, White House Briefing Room, June 16, 2021 Watch on C-SPAN Transcript: 12:10 President Joe Biden: How would it be if the United States were viewed by the rest of the world as interfering with the elections directly of other countries, and everybody knew it? What would it be like if we engaged in activities that he is engaged in? It diminishes the standing of a country that is desperately trying to make sure it maintains its standing as a major world power. President Joe Biden: And, by the way, we talked about trade. I don't have any problem with doing business with Russia, as long as they do it based upon international norms. It's in our interest to see the Russian people do well economically. I don't have a problem with that. But if they do not act according to international norms, then guess what? That will not — that only won't it happen with us, it will not happen with other nations." Hearing: Schemes and Subversion: How Bad Actors and Foreign Governments Undermine and Evade Sanctions Regimes, House Committee on Financial Services: Subcommittee on National Security, International Development and Monetary Policy, June 16, 2021 Watch on Youtube Witnesses Eric Lorber Senior Director at the Center on Economic and Financial Power at the Foundation for Defense of Democracies Managing Director at K2 Integrity Former Senior Advisor to the Under Secretary for Terrorism and Financial Intelligence at the Department of the Treasury Former corporate lawyer at Gibson, Dunn & Crutcher Lakshmi Kumar Policy Director at Global Financial Integrity Jesse Spiro Global Head of Policy & Regulatory Affairs at Chainalysis Dr. Jeffrey Taliaferro Professor of Political Science at Tufts University Ivan Garces Principal and Chair of Risk Advisory Services at Kaufmann Rossin Transcript: 07:13 Rep. Jim Himes (CT): Sanctions are an important instrument in foreign policy designed to be both a carrot and a stick in persuading an entity, an individual, a group or a country to change its behavior. A step beyond traditional diplomacy. It also avoids the downsides of kinetic action. We've seen the success of our sanctions regimes in bringing the Iranians to the table and isolating human rights violators through the Global Magnitsky Act amongst others. Our sanctions programs can only be as impactful as they are effective. When designated entities evade our sanctions, we lose an important tool from our diplomatic toolbox, increasing the likelihood that military action would be necessary to maintain international order. 08:09 Rep. Jim Himes (CT): This committee has worked to address some of these issues through the passage of the Corporate Transparency Act authored by Chairwoman Carolyn Maloney and the Anti Money Laundering Act sponsored by Chairman Emanuel Cleaver as part of the 2021 National Defense Authorization Act. These bills give law enforcement the resources and authority to better track money launderers, including sanction evaders, and their success will depend in large part on this body adequately funding their implementation. 11:20 Rep. Andy Barr (KY): The US employs a robust sanctions program to deny adversaries the funding, logistics and resources to conduct illicit behavior or to compel them to change misguided behaviors. 12:14 Rep. Andy Barr (KY): The US maintains four major sanctions programs against Iran, North Korea, Russia and Venezuela. These sanctions are a result of actions by those nations that are in direct conflict with US national security and global economic stability. 17:09 Dr. Jeffrey Taliaferro: The primary aim of sanctions whether unilateral or multilateral, whether comprehensive or targeted, is to induce a change in the cost benefit calculations of the target and thus a change in the targets behavior. 18:13 Dr. Jeffrey Taliaferro: Having won the Cold War and pushed the crumbling Soviet Union out of the ranks of the great powers, the United States emerged as the unit pole, the only great power left standing in 1990 and 1991. And for better or worse for two decades, weak systemic that has international constraints and the availability of opportunities to further improve its strategic position before the United States wide latitude in the definition and in the pursuit of its foreign policy, and national security objectives. This extreme imbalance of international power, however, had several consequences which are relevant to the subject of today's subcommittee hearing. First, the United States impose sanctions and even waged wars against recalcitrant states such as Iraq, Syria, Libya, and Afghanistan and non state actors such as Al Qaeda and later the Islamic State with relative impunity. And even when confronting state adversaries against whom the use of kinetic force would have been prohibitively costly, such as North Korea and Iran, the imposition of sanctions became a preferred tool of statecraft for successive administrations and Congresses second US military command of the comments along with American Economic and Technological dominance gave various state and non state actors and incentive to pursue asymmetric strategies, for example, the clandestine employment of cyber criminal organizations and individual hackers by the foreign intelligence services of Russia, China, North Korea and other states. Third, this uni polar distribution of power gave targeted states and other disadvantaged actors and incentive to collaborate with one another to evade or subvert US sanctions. And finally, as the Biden administration's interim national security, strategic guidance acknowledges the distribution of power across the world is changing, creating new threats. 20:13 Dr. Jeffrey Taliaferro: The United States now faces two great power adversaries a rising China and a declining and revanchist Russia, along with two regional power adversaries, Iran and North Korea. All four including their irrespective and their respective clients and allies will seek to evade sanctions. 20:38 Dr. Jeffrey Taliaferro: Might behoove policymakers to perhaps lower their expectations about what coercive economic diplomacy alone can achieve. 25:39 Ivan Garces: We can benefit from increased cooperation between public and private sectors such as is contemplated with the proposed OFAC exchange and the Combating Illicit Finance Public Private Partnership Act, legislation noted for this hearing. Government should be in a position to be able to take, analyze and interpret information we see not only from financial institutions, but other industry stakeholders and connect the dots identifying trends and relationships across the financial system. 26:46 Lakshmi Kumar: US sanctions regime is expansive and currently includes more than 30 different sanctions programs. 27:00 Lakshmi Kumar: Despite the ever increasing reach of sanctions, with evidence showing that the number of sanction vessels imports rather than annual rate of 6%. oil exports by Iran and Venezuela and oil imports by North Korea keep increasing every year. 27:56 Lakshmi Kumar: It is unsurprising that a leading mechanism to evade sanctions involves the use of TBML techniques, I've learned after a year of the pandemic. TBML or trade based money laundering is the process of disguising the proceeds of crime and moving value to trade transactions. It includes tech in techniques like falsifying the origins of a commodity of good over invoicing under invoicing and Phantom invoicing where no goods really move for just money. 28:14 Lakshmi Kumar: TBML was particularly challenging because there are no international standards, even at the level of a financial Task Force and little regulation internationally. It is therefore the perfect ally for sanctions evaders. 28:35 Lakshmi Kumar: The Iranian government was able to pocket $100 billion by falsifying trade records. 28:42 Lakshmi Kumar: Similarly, the Venezuelan Government to get around US sanctions on its gold sector has flown its gold all over the world changing its origins. So the gold is now supposed to be from the Caribbean, from Colombia from Uganda from Dubai, barely anywhere but Venezuela. 29:08 Lakshmi Kumar: Erasing its history in this way means that the US has no way of knowing whether the gold it imports is the same goal that it is seeking to sanction. Sanctioned entities continues to look at the US as a safe haven to get around sanctions. 29:35 Lakshmi Kumar: Professionals that have helped Iran and North Korea evade sanctions invested their lucrative commissions in real estate through the EB five investor program and invest in commercial real estate and buying real estate in states like Alaska. Both commercial real estate in many of the jurisdictions where these investments take place are not part of the geographic targeting orders for real estate. Similarly, vehicles like private equity, hedge funds, venture capital funds that are exempt from carrying out customer due diligence obligations are also involved in sanctions evasion schemes. A recent FBI leak showed that London and New York hedge funds proposed using a scheme to sell prohibited items from sanctioned countries to the US. 30:12 Lakshmi Kumar: Finally, sanctions evasion does not just exploit the gaps in regulation. It exploits the lack of resources that enforcement agencies need to protect. The FinCEN files one problematic, revealed two different sanctions evasion schemes tied to Russia and Syria. It will file their source for financial institutions, but did not necessarily receive the treatment they should have given the resource constraints of the agency. The way forward therefore, is to prompt addressing regulatory gaps but also providing the requisite support to enforcement supervision and oversight agencies. 34:27 Jesse Spiro: Through blockchain analysis, we can confirm that adversarial nations terrorist organizations, malicious enabled cyber actors and transnational criminal organizations under US sanctions have used cryptocurrency in an attempt to weaken the impact or fully circumvent sanctions, just as they have done through traditional banks, trade based money laundering and cash. 40:10 Eric Lorber: The key to countering sanctions evasion is the ability to detect such activity. The Treasury Department's Office of Intelligence and Analysis along with other members of the intelligence community as well as FinCEN should be provided with the tools necessary to identify sanctions evasion. A legislative proposal under consideration by this can be the OFAC fusion center act could help achieve this. This legislation would create an interagency group designed to share data and allow for better detection and disruption of illicit networks, providing the private sector with the right tools. In recent years, Treasury has armed the private sector with information on sanctions, evasion tactics and red flags that can help companies spot such evasion through a series of advisories combined with clearly signaling to the private sector, their compliance obligations and pursuing aggressive enforcement actions against those who fail to comply. This additional information can help the private sector more effectively counter evasion. 43:33 Eric Lorber: The number of transactions which are elicit that use Bitcoin or blockchain technology is actually fairly low percentage wise it's in I believe, below 1% or somewhere around there. So it's fairly small. 49:40 Eric Lorber: There needs to be political pressure put on those who are supporting and continue to support North Korea. It's it's not a secret that for example, China has created at least a permissive environment for North Korean operators to to work in the country. That was detailed most recently, I believe in that in the UN DPRK panel of experts report from I believe is March 2021. As well as North Korea maintains a series of financial facilitators throughout the world, including in I believe in Russia and China and other jurisdictions that helps North Korea evade US and UN sanctions and these individuals need to be shut down, need to be targeted, and pressure to put on the governments that are hosting them to kick them out of the country. 51:35 Eric Lorber: That's something that we tried to do and I tried to do while we were at Treasury was that clarify very clear the sanctions targets if you change the behavior you're engaged in, these sanctions will be lifted. 1:04:29 Rep. Madeleine Dean (PA): Ms. Kumar, I'd like to start with you. In your testimony, I read with interest how you discussed the role that United States real estate, especially commercial real estate plays in sanction evasion regimes. You specifically mentioned the geographic targeting order GTO issued by FINcen, which I might note includes 12 metropolitan areas only to require us title insurance companies to identify natural persons behind shell companies used in all cash purchases of residential real estate. Given the limited Metropolitan list covered by GTO and the fact that commercial real estate is not covered, can you can you speak to both of those problems? Number one, the limited number of metropolitan areas my own suburban Philadelphia or Philadelphia count among them, and also the fact that it's residential, not commercial. Where does this fall short in terms of our regulating evasion? 1:05:42 Lakshmi Kumar: The sanctions program doesn't just target big actors like Iran, North Korea. The sanctions program also targets individuals involved in drug trafficking. And what we see is a lot of those individuals often to evade sanctions, including sort of former officials of the Venezuelan administration, all move or hide assets and move it into real estate and the US real estate market is a popular Avenue. Now, when we talk about commercial real estate, you're absolutely right. And that the sort of often cited example of the Iranians owning that massive skyscraper in New York was a purchase of commercial real estate, it continues to be unrecognized. The EB5 investor program is investments that ultimately go into commercial real estate. Now a lot of this is particularly complex because commercial real estate involves multiple investors, it is not as simple as a residential purchase by a homeowner. To that end, we have to what is necessary is to sort of rethink how we are going to apply the GTO. The title insurance agents may not be the most relevant actors, however, to sort of identify gatekeepers that do continue to play a critical role in sort of putting together these transactions because commercial real estate transaction always take place through legal structures, they are never in the names of an individual. So identifying actors like lawyers, who often play a critical role in this as sort of the the pressure point at which you can conduct due diligence to know who is behind these transactions is one way forward. You've also rightly said that it only covers 12 metropolitan areas, and a lot of the evasion schemes that we often see tied to individuals, but also generally more generally, the use of real estate, you often see an equal split between cases that occur in GTO areas versus cases that occur in non GTO areas. And I will say that we have a report forthcoming in the next month that will actually that shows evidence that when looks at a series of reported cases that actually shows that over the last five years, the number of cases that occur in non-GTO areas actually slightly significantly more than GTO areas. 1:43:57 Rep. Warren Davidson (OH): Currently the SDN list statistics as of yesterday the 15th we have 277 aircraft, 3668 entities, 4603 individuals and 406 vessels. 1:44:40 Eric Lorber: The end goal is is twofold one or one of two. It's either to prevent them from engaging in illicit activity, right? So you mentioned an aircraft prevent that aircraft from shuffling or sending illicit drugs to a destination. Or it's to get the targets to actually change their behavior. So to essentially impose restrictions on them, to get them to say, 'well, this is not worth it.' We are no longer going to engage in material support for terrorism. 1:51:12 Rep. Jake Auchincloss (MA): Blockchain offer you an advantage in authenticating your identity over a different type of currency. Jesse Spiro: No, I would actually posit the complete opposite Congressman, what I would say is that the only vulnerabilities that I would address in relation to KYC are the fact that people could circumvent them. But even if they were to, if they're engaged in illicit activity that can be seen in relation to illicit crypto activity. It is going to be very difficult for them to do anything within the ecosystem. 1:51:59 Rep. Jake Auchincloss (MA): If you are able to advise Congress to take any steps that would influence OFAC's measures, what would you advise that we do? Jesse Spiro: I would just imply to apply congressmen more resources to that agency specifically in relation to the risks associated with cryptocurrency and sanctions evasion, wherein they can produce more designations that include cryptocurrency wallets, because as identifiers for the private sector when they have access to that information, that is how they can potentially mitigate the illicit activity. And because of the activity with cryptocurrency, when a wallet is put on that designation list, any associated activity, or within a designation, excuse me, any associated activity and legacy activity in relation to that look back can also be visible. Hearing: Dollars Against Democracy: Domestic Terrorist Financing in the Aftermath of Insurrection, Committee on Financial Services: Subcommittee on National Security, International Development, and Monetary Policy, February 25, 2021 Watch on Youtube Witnesses Iman Boukadoum Senior Manager, The Leadership Conference on Civil and Human Rights Lecia Brooks Executive Director of the Southern Poverty Law Center Daniel Glaser Global Head Jurisdictional Services and Head of Washington, DC Office at K2 Integrity Senior Advisor at the Foundation for Defense of Democracies Board member at the Qatar Financial Centre Regulatory Authority Former Assistant Secretary for Terrorist Financing and Financial Crimes, U.S. Department of the Treasury Daniel Rogers Co-Founder and Chief Technical Officer at Global Disinformation Index Daveed Gertenstein-Ross CEO of Valens Global Transcript: 03:02 Rep. Jim Himes (CT): As we heard from Merrick Garland during his confirmation hearing earlier this week, the country faces a 'more dangerous period in the wake of January 6th, than we did after the Oklahoma City bombing,' the single deadliest act of domestic terrorism in American history. 03:28 Rep. Jim Himes (CT): In the wake of the attacks of September 11th, we recast the entire federal government and worked feverishly to defund terrorist streams. To effectively disrupt domestic extremist groups, we need to better understand their financing. 03:54 Rep. Jim Himes (CT): Unlike ISIS, for example, these organizations are not pyramid shaped where funding comes from a handful of easily disruptable areas. An online fundraising drive for a legitimate charity, and one that helps support an extremist group can look very similar. 04:57 Rep. Jim Himes (CT): We need to conscientiously be mindful of the civil liberties concerns at play here. Unlike international extremist groups, law enforcement is constrained by the Constitution when dealing with domestic extremists, balancing the desire to give law enforcement the tools necessary to disrupt these groups with the need to respect the rights of all Americans and the Constitution to which we have all pledged an oath is essential. 05:36 Rep. Jim Himes (CT): While we all live through a brutal event on January 6th, undertaken by right wing extremists, no location on the political spectrum has a monopoly on extremism or violence. 10:08 Rep. Maxine Waters (CA): We're here against the backdrop of the January 6th insurrection. A deplorable yet predictable display of white supremacists such as the Proud Boys, the oathkeepers QAnon and others and nationalist violence incited by President Trump against the members of this body and against democracy itself. 12:51 Iman Boukadoum: Last month violent insurrection heavily fueled by white supremacy and white nationalism shocked the world. 13:52 Iman Boukadoum: We know, however, that even well intentioned national security laws are invariably weaponized against black, brown and Muslim communities. And that white nationalist violence is not prioritized making that policy failure the fundamental reason for what transpired on January 6th, not lack of legal authority. For this reason we oppose any legislation that would create new charges for domestic terrorism or any enhanced or additional criminal penalties. The federal government, including the Treasury Department, has many tools at its disposal to investigate. And also the FBI and DOJ have 50 statutes, at least 50 statutes and over a dozen criminal statutes, 50 terrorism related statutes, excuse me and over a dozen criminal statutes that they can use. They just need to use them to target white nationalist violence. 19:33 Lecia Brooks: Today, some white nationalist groups and personalities are raising funds through the distribution of propaganda itself. In November SPLC researchers reported that dozens of extremist groups were earning 1000s of dollars per month on a popular live streaming platform called D-Live. 20:21 Lecia Brooks: Crowdfunding is also being exploited by hate groups to earn money in this new decentralized landscape. Crowdfunding sites played a critical role in the capital insurrection, providing monetary support that allowed people to travel to Washington DC. They've also played a crucial role in raising hundreds of 1000s of dollars in legal fees for extremists. 20:43 Lecia Brooks: The violent insurrection at the US Capitol on January 6 should serve as a wake up call for Congress, the Biden administration, Internet companies, law enforcement and public officials at every level. 23:11 Daniel Glaser: Thank you for the opportunity to appear before you today to talk about how the US government can employ similar tools and strategies against white nationalists and other domestic terrorist groups as it has employed against global jihadist groups over the past two decades. 23:33 Daniel Glaser: During my time at the Treasury Department, I fought to cut off funding to terrorist groups such as Al Qaeda, the Islamic State and Hezbollah, as a Deputy Assistant Secretary in the Bush Administration, and eventually as the Assistant Secretary for Terrorist Financing in the Obama Administration. My primary responsibility was to lead the design and implementation of strategies to attack the financial networks of these groups and other threats to our country's national security. And while we should never let down our guard with respect to those still potent terrorist organizations, it has become tragically clear that there are domestic extremist groups that in some ways present an even greater threat to our ideals and our democracy. We have the responsibility to target those groups with the same determination, creativity and sense of purpose that we displayed in the years following 9/11. 27:42 Daniel Glaser: Potential measures in Treasury's toolbox include the issuance of guidance to financial institutions on financial type policies, methodologies and red flags, the establishment of public private partnerships the use of information sharing authorities and the use of geographic targeting orders. Taken together these measures will strengthen the ability of financial institutions to identify, report and impede the financial activity of domestic extremist groups and will ensure that the US financial system is a hostile environment for these groups. 30:10 Daniel Rogers: These groups leverage the Internet as a primary means of disseminating their toxic ideologies and soliciting funds. One only needs to search Amazon or Etsy for the term q anon to uncover shirts, hats, mugs, books and other paraphernalia that both monetize and further popular popularized the domestic violent extremist threat. Images from that fateful day last month are rife with sweatshirts that say, Camp outfits that until recently were for sale on websites like Teespring and cafe press. As we speak at least 24 individuals indicted for their role in the January 6 insurrection, including eight members of the proud boys have used crowdfunding site gifts and go to raise nearly a quarter million dollars in donations. And it's not just about the money. This merchandise acts as a sort of team jersey that helps these groups recruit new members and form further hatred towards their targets. We analyze the digital footprints of 73 groups across 60 websites, and 225 social media accounts and their use of 54 different online fundraising mechanisms, including 47 payment platforms and five different cryptocurrencies, ultimately finding 191 instances of hate groups using online fundraising services to support their activities. The funding mechanisms including included both primary platforms like Amazon, intermediary platforms, such as Stripe or Shopify crowdfunding sites like GoFundMe, payments facilitators like PayPal, monetized content streaming services, such as YouTube, super chats, and cryptocurrencies, such as Bitcoin. All of these payment mechanisms were linked to websites or social media accounts on Facebook, Instagram, YouTube, telegram, LinkedIn, Pinterest, gab, picshoot and others. The sheer number of companies I just mentioned, is the first clue to the scale and the scope of the problem. 31:40 Daniel Rogers: We also found that a large fraction of the groups we studied have a tax exempt status with the IRS, a full 100% of anti muslim groups. 75% of anti-immigrant groups, and 70% of anti LGBTQ groups have 501-C-3 or 501-C-4 status. Over 1/3 of the militia groups that we identified, including the oathkeepers, whose leadership was recently indicted on charges related to January 6, have tax exempt status. This status gives them access to a whole spectrum of charity fundraising tools, from Facebook donations to amazon smile, to the point where most of the most common fundraising platform we identified across all of our data was Charity Navigator. 32:30 Daniel Glaser: I think it's important to remember that if you want to be able to use a cryptocurrency in the real economy, to any scale, it at some point doesn't need to be converted into actual fiat currency into dollars. That's the place where the Treasury Department does regulate cryptocurrencies. 42:10 Daniel Glaser: Cryptocurrency exchanges are regarded as money service businesses. They have full customer due diligence requirements. They have full money laundering program requirements, they have reporting requirements. The US Treasury Department just last month, issued a proposed rule relating to unhosted wallets of cryptocurrencies. And that's out for notice and comment. Right now. It addresses the particular issue of, of wallets that are not hosted on a particular exchange. And I think it's an important rule that's out there and I do encourage people to take a look at it, the comment period closes in May, and then hopefully, Treasury will be able to take regulatory action to close that particular vulnerability. 42:46 Rep. Jim Himes (CT): Mr. Glaser, you you, though suggested something new that I'd like to give you a maybe 30 seconds, 42 seconds I have left to elaborate on you said you were taught you were hopeful for sanctions like authorities against domestic actors. You did not to constitutional civil liberties concerns. But give us another 30 seconds on exactly what you mean. And perhaps most importantly, what sort of fourth amendment overlay should accompany such authority? Daniel Glaser: Well, thank you, thank you for the question. The fact is, the Treasury Department really does not have a lot of authority to go after purely domestic groups in the way that it goes after global terrorist organizations that simply doesn't have that authority. You could imagine an authority that does allow for the designation of domestic organizations, it would have to take into account that, the constitutional restrictions. When you look when you read the a lot of the court decisions, there's concerns could be addressed in the statute, there's concerns. A lot of the scrutiny is heightened because sanctions are usually accompanied with acid freezes. But you could imagine sanctions that don't involve asset freezes that involve transaction bounds that involve regulatory type of requirements that you see in Section 311 of the Patriot Act. So there's a variety of ways that both the due process standards could be raised from what we see in the global context. 44:37 Daniel Rogers: The days leading up to the insurrection, the oathkeepers founder Stuart Rhodes appeared on a podcast and solicited charitable donations to the oathkeepers Educational Fund. It can only be presumed that these funds which listeners were notably able to deduct from their federal taxes, went to transporting and lodging members of the group slated to participate in the ensuing riots. 46:06 Rep. French Hill (AZ): In looking at the draft legislation that the majority noticed with this hearing, one bill stuck out to me and I think it's a good follow up for your from your most recent exchange. It seeks to amend title 31 to require the Secretary of the Treasury to establish a program to allow designated employees of financial institutions to access classified information related to terrorism, sedition, and insurrection. Now, over the past three congresses, we've talked about the concept of a fusion center, not unlike we do in monitoring cyber risk and cyber crimes for this terror finance arena. We've never been able to come ashore on it legislatively. So I found that interesting. However, I'm concerned that when you deputize bank employees without any oversight, as to how the information would be protected or if there's really even a need for that. 46:53 Rep. French Hill (AZ): Could you describe how banks share information with law enforcement today and how they provide feedback on how we might change these protocols or if they're if that protocol change is necessary. Daveed Gertenstein-Ross: Thank you ranking member, there are four primary ways that banks share information now. The first is suspicious activity reports or the SAR. Financial institutions have to file these documents with the Financial Crimes Enforcement Network or FinCEN. When there's a suspected case of money laundering or fraud, the star is designed to monitor activity and finance related industries that are out of the ordinary are a precursor to illegal activity, or can threaten public safety. Second, there's law enforcement's 314 a power under the Patriot Act, in which obtains potential lead information from financial institutions via FinCEN. Third, law enforcement can use its subpoena power, if a court issues a subpoena pursuant to an investigation, or to an administrative proceeding and forth where there are blocked assets pursuant to OFAC authorities, sanctions or otherwise, banks are required to report block assets back to OFAC. The information sharing in my view is currently quite effective. Treasury in particular has a very strong relationship with the US financial institutions. 48:24 Rep. French Hill (AZ): On 314 in the Patriot Act, is that a place where we could, in a protected appropriate way make a change that relates to this domestic issue? Or is that, in your view, too challenging? Daveed Gertenstein-Ross: No, I think it's a place where you could definitely make a change. The 314-A process allows an investigator to canvass financial institutions for potential lead information that might otherwise never be uncovered. It's designed to allow disparate pieces of information to be identified, centralized and evaluated. So when law enforcement submits a request to Finicen, to get information from financial institutions, it has to submit a written certification that each individual or entity about which the information is sought is engaged in or reasonably suspected of engaging in terrorist activity or money laundering. I think that in some cases 314-A, may already be usable, but I think it's worth looking at the 314-A process to see if in this particular context, when you're looking at domestic violent extremism, as opposed to foreign terrorist organizations, there are some tweaks that would provide ability to get leads in this manner. 1:15:15 Iman Boukadoum: What we submit is that the material support for terrorism statute, as we know, there are two of them. There's one with an international Nexus that is required. And there's one that allows for investigating material support for terrorism, domestic terrorism, in particular, as defined in the patriot act with underlying statutes that allows for any crimes that take place within the United States that have no international nexus. And we believe that that second piece of material support for terrorism statute has been neglected and can be nicely used with the domestic terrorism definition as laid out in the Patriot Act. And we hope that statutory framework will be used to actually go after violent white nationalists and others. 1:50:25 Daniel Rogers: I think there are a number of regulatory fronts that all kind of go to the general problem of disinformation as a whole. And I don't know that we have the time to get into all of them here, but I think they, they certainly fall into three three big categories, with the one most relevant to today's discussion being this idea of platform government and platform liability, that, you know, our data is showing how what a key role, these sorts of platforms play in facilitating the activities of these groups. And the fact that the liability is so nebulous or non existent through things like Section 230 and whatnot, which what we found is that there's there's already policies in place against all of these hate and extremist groups, but they're just simply not enforced. And so updating that kind of platform liability to help drive enforcement I think is one of the key areas that that that we can focus on. Cover Art Design by Only Child Imaginations Music Presented in This Episode Intro & Exit: Tired of Being Lied To by David Ippolito (found on Music Alley by mevio)

Featuring: Bruce Zagaris of Berliner Corcoran and RoweBruce joins us to discuss the new Anti-Money Laundering Act of 2020. Bruce walks us through the enforcement changes that will be implemented by Act. Additionally, Bruce discusses the comment period for this Act and how CJS will be participating.Want to get involved with the Criminal Justice Section? Join us! https://www.americanbar.org/membership/join-now

In this Episode of the FCPA Compliance Report, I am joined by Greg Keating, well-known employment lawyer who focuses on whistleblower regulation and litigation.  In this episode we take a look at the current state of whistleblower regulations, case law and recent SEC awards. Highlights include: Greg recently changed firms, moving to Epstein Becker & Green, P.C. He tells us about your new firm? Why was the whistleblower provision of the Anti-Money Laundering Act of 2020 so controversial? What are you counseling clients on regarding whistleblower claims under the Biden Administration? In addition to the AMLA of 2020, what other regulatory changes have you seen from the federal government regarding whistleblowers? Are there any court cases involving whistleblowers that have gotten your attention in 2021?  2002 was the Year of the Whistleblower with Sherron Watkins of Enron, Cynthia Cooper of WorldCom and Collen Rowley of the FBI. Could 2021 be in the running for such a designation? Why is listening to those employees who raise their hands and speak up so critical? Why is a proactive approach to whistleblowers so critical?   Resources  Greg Keating on LinkedIn Epstein Becker & Green, P.C. firm profile Learn more about your ad choices. Visit megaphone.fm/adchoices

Elizabeth Slim joins Sam Sheen and Marie Lundberg to chat about the Anti-Money Laundering Act 2020 (AMLA) and how this significant reform will impact areas such as Beneficial Ownership rules, FinCen's planned review of the art market from an AML perspective and whether overseas businesses with subsidiaries in the US need to comply with these requirements. They also consider the not-so-simple UBO rules, when companies must register their owners and the many exemptions offered under the AMLA Act , expanded provisions for US government to obtain records from non-US banks and how they could lose their correspondent bank account if they fail to cooperate. And of course, sharing of information between entities as part of a new pilot project.  Part one of two.  

Elizabeth Slim joins Sam Sheen and Marie Lundberg for part 2 to chat about the Anti-Money Laundering Act 2020 (AMLA) and how this significant reform will impact areas such as new protections for corporate whistleblowers that now includes MLROs, auditors or even an attorney, along with the upping of the payments made to them. They also consider whether an overseas staff member is protected under the AMLA if they blow the whistle on financial crime in their sister company in the US, an update on Virtual Asset Service Providers, antiquity dealers joining the regulated AML family and new provisions for enforcement actions and penalties.  Look out - bonus claw backs and banning from acting as a director in the future are now in the goody bag of penalties!

Today's episode features a discussion of the new whistleblower provisions in the Anti-Money Laundering Act of 2020. We'll discuss the types of businesses covered, who can be a whistleblower under the Act, the increased incentives now provided, new protections against retaliation, the impact of a whistleblower being involved in the conduct, and practical advice for affected institutions. Peter Hardy, co-practice leader of the firm's Anti-Money Laundering Team is joined by Ballard Spahr attorneys Meredith Dante and Diana Joskowicz.

Tune in as IIB's CEO, Briget Polichene, joins Trish Sullivan, former Managing Director and Global AML Head at Standard Chartered Bank and UBS and founder of the FCC Partnership Group, Chris Boehning, Partner at Paul Weiss, and Matt Levine, President, Financial and Regulatory Compliance Services at IIB Gold APM, Guidepost Solutions, as they discuss the Anti-Money Laundering Act of 2020 Amendments and their ramifications, especially as they apply to FBOs.

GameStop is an American video game company and an USA listed retail company and traded at the New York Stock Exchange. Ok, understood. What happened? GameStop's stock price skyrocketed due to a “short squeeze” orchestrated by users of Reddit - a news aggregation web content rating and discussion website. Just in 2021, and this year has just began, its stock price valued 858%. You heard it right - 858%. GameStop shares got to a point that it was worth $347.51 and, fyi, three weeks before it cost $19. There are different ways to make money in the Stock Markets. Some of them are: 1) By buying shares on a low price and selling it on a high price; or 2) !Warning: Bullying Alert! By betting that a company's shares are going to go down. In other words, you bet against the company or market - called "shorting stocks". Reddit users saw that hedge funds were betting against GameStop. But hedge funds' scheme didn't go as planned. Other cases: - Philippines filed a diplomatic protest against China | International Tribunal on UK's sovereignty over the Chagos Islands | Philippines' President signed the Anti-Money Laundering Act; - Portuguese Parliament legalised euthanasia; - We like to keep you updated: Federal Republic of Germany v. Philipp; Germany v. Afghan Officer (and its implications on the Germany v. Syrian Officers case).

From the 1st January 2021 the new UK sanctions framework officially came into force under the Sanctions and Anti-Money Laundering Act 2018 (SAMLA). Notably, SAMLA was one of the first of the first Acts passed as a direct result of Brexit. In this podcast episode, we are joined by guest speaker Alex Haines, a Barrister at Outer Temple Chambers specialising in international law, business crime and sanctions. Alex shares his considerable insight on sanctions, how they affect trade and the changes SAMLA will now bring about.Show referencesThe Association of Certified Sanctions Specialists OFSI guidanceSmith, Owen, and Bodnar on Asset Recovery – Criminal Confiscation and Civil Recovery See acast.com/privacy for privacy and opt-out information.

Congress enacts Anti-Money Laundering Act of 2020. ISDA looks at CCP risk management during pandemic. OFAC issues additional guidance on sanctions against Chinese military companies. OFAC issues new and amended guidance on CAATSA. CFPB offers recommendations to enhance consumer protection in the financial marketplace. Broker-Dealer settles FINRA charges for recordkeeping violations. Broker-Dealer settles FINRA charges for supervisory and suitability violations. Effective date set for SEC framework to "modernize" fund valuation practices. Effective date set for final rule to limit interconnectedness of large banks. Brass Tax: Biden's Tax Plan.

SAMLA, the Sanctions and Anti-Money Laundering Act of 2018, represents the United Kingdom's establishment of an independent sanctions policy in preparation for Brexit at the end of 2020. The legislation's sanctions provisions are now in force and the UK Foreign Office has already designated several sanctioned parties. While these initially sanctioned parties have been carefully limited to those who have participated in unambiguous and high-level violations of human rights, the new regime shows the potential to become more expansive both in terms of the scope of targeted persons and the possible secondary effects for businesses around the world. PSA's Michael Olver spoke with Adam Wolstenholme of Simmons and Simmons about the impact of these sanctions on the global compliance environment. Adam provides insights into how SAMLA may fit into Whitehall's newly independent approach to regulating UK-connected transactions and highlights some potentially unanticipated risks for businesses arising from the new regime. _ To learn more about Pacific Strategies & Assessment's investigative and due diligence capabilities go to www.psagroup.com