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“We Are The AML World”

A continued call for collaboration*

With a nod to pop music, veteran John Byrne’s blog scans the anti-laundering and anti-terrorism world. John pierces silliness and inconsistency, and strongly believes in private-public partnership With a nod to pop music, veteran John Byrne’s blog scans the anti-laundering and anti-terrorism world. John pierces silliness and inconsistency, and strongly believes in private-public partnership

One thing remains clear to me, in 30-plus years of addressing, debating, and trying to improve the global AML infrastructure: Serious engagement demands true collaboration.

Legendary composer and arranger Quincy Jones made something clear, when working on the song “We Are The World” in 1985. He had a dream team of performers. His request to all: “Please, check your egos at the door.”

The same applies to the AML community—law enforcement, regulators, and the private sector.

There is no one group that can improve what challenges us all in 2017. We need a sincere commitment to the ultimate goal of AML—protecting global society from those that would use the financial system to harm us.

[An aside: I was challenged recently on my three-legged stool. My challenger said it was really a four-legged stool, by adding those involved in technology. I respectfully disagree, since tech is enmeshed with all in the private and public sectors and not separate by any means.]

Get off the sidelines!

Nothing annoys me more that those who chirp and complain but never engage or work to solve problems. Improvement only comes from comments and stakeholder dialogue.

I coached and refereed youth sports for many years. I found that the number of “adults” who seemed to know it all was astounding.

Similarly, when we discuss compliance and other legal responsibilities, those who condemn the infrastructure but offer nothing of substance to improve the process provide nothing of value. This is why it is so important to provide input whenever the situation presents itself. Case in point—information sharing.

As I hope most of you know, the June plenary of the Financial Action Task Force (FATF) recently concluded with a new President (Santiago Otamendi of Argentina) and of course updated objectives.

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I would urge you to review the objectives and summarize them for your management and staff. The objectives reflect the new FATF President’s priorities as well as input from the members.

I was particularly impressed with the notable push to continue engagement with the private sector; a call for partnership with the fintech and regtech sectors; and the need for FATF to enhance its public positions via social and traditional media.

At the same time, FATF has called for public comments on private sector information sharing with a draft guidance document.

While comments are due by July 31—I apologize for mentioning this so late in the process—there is ample opportunity to ask your organizations or trade groups whether they have filed comments.

And if not—why not?

There are many tenets regarding essential information in the AML field but FATF says simply:

“Information-sharing is critical for combatting money laundering, terrorist financing and financing of proliferation. Multinational money laundering schemes do not respect national boundaries.”

All of us agree with that sentiment but how we navigate privacy and jurisdictional hurdles are a major challenge. This draft guidance is well crafted but could use your operational, strategic, and legal input.

There is a section that has yet to be added in this document that cries out for help—“information-sharing between financial institutions which are not part of the same group.”

Get off the sidelines!

 Mid-Year Collaboration Updates

There are a few other projects underway that should assist our community.

• First, the ongoing projects with financial institutions and nongovernmental organizations on how to improve the hurdles to financial access. This has the strong support of the World Bank and the financial community. It is moving, but slowly. Congress is gathering more information on the use of remittances to commit terrorist activity but they have included NGO voices in those hearings.

• Concerns over human trafficking are growing and with it have been major efforts to address from both the private and public sectors. A report on new typologies has been released recently.

In addition, a project is underway to develop more red flags and indicators to help financial institutions detect and report this horrific crime.

• Finally, as we approach the May 2018 implementation deadline for FinCEN’s CDD rule, the Federal Financial Institutions Examination Council is working on examination procedures and actively seeking input on that and other possible changes to the next version of the FFIEC AML/BSA Examination Manual.

So get in the game and help. We have more than enough spectators.

*Key line from the song, “Let us realize that a change can only come, When we stand together as one.” Record of the Year in 1985 and co-written by Michael Jackson and Lionel Ritchie.

John Byrne

John Byrne is Executive Vice-President of the Association of Certified Anti-Money Laundering Specialists. ACAMS, with more than 26,000 members, develops anti-money laundering/sanctions/financial crime detection programs and certifies specialists in financial and non-financial businesses and government agencies. Byrne is a nationally known regulatory and legislative attorney with close to 30 years of experience in a vast array of financial services issues, with particular expertise in all aspects of regulatory oversight, policy and management, anti-money laundering (AML), privacy, and consumer compliance. He has written hundreds of articles on AML; represented the banking industry in this area before Congress, state legislatures and international bodies such as the Financial Action Task Force (FATF); and appeared on CNN, Good Morning America, the Today Show, and many other media outlets. Byrne has received a number of awards, including the Director's Medal for Exceptional Service from the Treasury Department's Financial Crimes Enforcement Network (FinCEN) and the ABA's Distinguished Service Award for his career work in the compliance field. His podcast, “AML Now” (on ITunes) received a 2017 Communicator Award for hosting from the Academy of Interactive and Visual Arts. Byrne’s blog on AML and Fraud on BankingExchange.com received a Gold Hermes Award in 2016. Byrne can be e-mailed at jbyrne@acams.org. And don't miss John's updates on Twitter! You can find him at @jbacams2011

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