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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Kieran talks with Willem Schudel, Head of Department, Financial Crime Supervision (AML/TF) at the Central Bank of the Netherlands, live from The Assembly Europe, ACAMS’ annual conference, held this year in Dublin. Willem discusses the Dutch Central Bank’s preparations for the coming of the European Union’s Anti-Money Laundering Authority, or AMLA, and the bank’s latest initiatives with regulated entities, including expectations they adopt technology that will identify criminal activity and reinforce the risked-based approach. ---------- This Financial Crime Matters episode is sponsored by: NICE Actimize CDD-X - https://www.niceactimize.com SAS - https://www.sas.com/fraud Fenergo - https://www.fenergo.com