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“Stop Making Sense”*

Election-year insanity, policy makers attacking. Where are the adults?

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.

In this age of social media, 24-hour news cycles, and society filled with attention deficits, a comprehensive review of how to address AML now seems beyond our collective reach.

For me, there are many reasons why it is essential our community stays both engaged in addressing terrorist financing and up-to-date with methods by which it succeeds.

In August 2014, James W. Foley, a journalist and alumni from my school, Marquette University, was beheaded by subhumans in Syria, better known as ISIS. His crime? Being a voice for those attacked in that region of the world. [Information about a foundation created in his name.]

While no financial institution may have been able to report any transactions that assisted in this horrific crime, we in AML want to do all we can to detect, report, and prevent terrorist financing.

Sadly, outside influences make that a major challenge.

What’s out there

For example, this morning, someone tweeted (yes I both can’t believe I now say this daily and am a frequent participant on Twitter) an interview with a U.S. lawyer who told the BBC that banks intentionally commit financial crime as the “cost of doing business.”

Several in public office add that more bankers need to go to jail and the New York Department of Financial Services will have compliance officers “certify” under penalty of criminal law that their institutions have appropriate transaction monitoring and sanctions filters. 

Regardless of your political persuasion in the U.S., the yelling and deliberate manufacturing of “facts,” particularly in the area of terrorism, certainly tells me that a coherent strategy to stay current with the acts of ISIS, Boko Haram, and Al Qaida may lose out to creating lines of demarcation between the private and public sectors.

We cannot let that happen—or in the words of the Talking Heads, let there be a “Burning down the House.”

Time to ignore the idiots

So if we are to improve the culture of compliance, the level of AML education within financial institutions, and utilize the expertise of analysts in all areas, there needs to be a comprehensive plan. And that plan must include all parts of the AML community.

So those who attack from the sidelines need to be ignored or, at best, not given the platform they so crave.

Those of us that have been fortunate to be part of AML throughout the years know that there is a commitment to success and those that come in and out of this area neglect that fact in the search for headlines.

Let us continue without them…

FATF’s February plenary

In a very positive sign for the AML community’s collective goal of staying current with terrorist financing, the most recent plenary of the Financial Action Task Force (FATF) approved a new consolidated strategy on combating this ongoing problem, pointing out how they worked with the private sector:

“A meeting with the private sector provided valuable insights into the operational aspects of terrorist financing. It involved a wide range of experts including from a full range of operational authorities and from the banking and money service business sectors. The experts exchanged views on how to identify terrorist financing, as well as on enhancing information exchange. Deeper knowledge of all aspects of terrorist financing will allow FATF to more accurately gauge whether its measures provide countries with the strongest possible tools to combat terrorist financing.” [Read more]

The last line is particularly important because it is only through working together that we can hope to exchange information and strategies to fight our common foe. FATF added a specific focus on information sharing, an age-old challenge that, sadly, unearths more reasons to stymie sharing than to allow it.

It is comforting to see FATF state that it “… will continue its analysis which will help to identify steps to strengthen information exchange at all levels.”

Read the outcomes of the FATF plenary and ignore those that want to “stop making sense.”

* “Stop Making Sense” was a 1984 concert movie of the Talking Heads, with their lead singer David Byrne (no relation) to push their album that had a single called “Burning Down the House” that was #9 on the Billboard 100 in 1983.

John Byrne

John Byrne is Senior Advisor to the Advisory Board  of the Association of Certified Anti-Money Laundering Specialists and Vice-Chairman of AML RightSource. ACAMS, with more than 70,000 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 over 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 received a Gold Hermes Award in 2016. John received the ACAMS Lifetime Service Award in September. Byrne can be e-mailed at [email protected]; and don't miss John's updates on Twitter! You can find him at @jbacams2011

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