Blog Entries for John Byrne

FREEDOM*: A CONCEPT WE ALL EMBRACE, BUT DIFFER ON ITS MEANING

Byrne — Fri, 26 Apr 2013 00:00:00 +0100

Boston attacks put BSA/AML into perspective

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The sad truth behind last week's horrific attacks in Boston is that absolute prevention is impossible.

Fortunately, in order to break the case, investigators were able to take advantage of video cameras, cell phone records, and possibly financial transactions (we don't know that yet but i [...]

�ROAD TO FOREVER'*: WILL THE AML COMMUNITY EVER GET IT RIGHT?

Byrne — Wed, 27 Mar 2013 00:00:00 +0100

Conference debates say no

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Don Felder was the lead guitarist for the Eagles for 27 years, and many non-music geeks do not know his name. Some of us who did strange things like have radio shows (DJ's ) in the 70s in college, remember his value to a very popular band and also know he has recently released a solo album with the title listed above.

&nbs [...]

�YOU CAN CHECK OUT ANY TIME YOU LIKE---BUT YOU CAN NEVER LEAVE'*

Byrne — Tue, 12 Mar 2013 00:00:00 +0100

AML professionals face the same issues

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Having just finished watching the "History of the Eagles" on Showtime, besides the lyrics to "Hotel California" mentioned above, I thought about how the AML community is like a band--relatively small, fighting constantly to see who is in charge (oh we could tell stories,) but always joined in the battle against the same is [...]

�I GUESS I JUST WASN'T MADE FOR THESE TIMES' *

Byrne — Fri, 22 Feb 2013 00:00:00 +0100

(Don't sit around when change is possible)

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Followers of this blog, any of my speeches, or now my tweets, know that I have attempted to advocate over the years for a "participatory regulatory democracy."

What I mean is that when there are formal opportunities to offer advice and counsel or actual opposition to a proposal, affected parties should [...]

FOR WHAT IT'S WORTH *

Byrne — Fri, 01 Feb 2013 00:00:00 +0100

Trends and issues in AML from the MENA region, plus general musings

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I have just returned from the ACAMS 3rd Annual AML and Financial Crime Conference--MENA, held in Dubai, UAE. MENA stands for Middle East and North Africa.

What struck me was how similar the challenges facing AML professionals are no matter where they ar [...]

IN/OUT IN BSA/AML: JOHN BYRNE'S 2013 AML LIST

Byrne — Fri, 28 Dec 2012 00:00:00 +0100

Trends, not tunes, this week

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I usually work a song or movie title into my blog headlines, but the only one that might tie in with this week's is "Auld Lang Syne"-- and we'll all be hearing that one enough over the next few days.

But I think, in the spirit of looking backward and forward at this time of year, it is appropriate to think about what is "out" and what is "in" [...]

'DON'T BRING ME DOWN'

Byrne — Fri, 14 Dec 2012 00:00:00 +0100

Learning from enforcement actions

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Readers of this blog know that I strongly believe that the entire AML community (private and public sector) can benefit from studying the themes from enforcement actions.

No matter how dramatic the penalty, we need to remember that these actions are negotiated and what is public is never the whole story. Also, you won't benefit from just skimming an action; you need t [...]

STAND*: AND GET ACTIVE ON AML CHANGES

Byrne — Tue, 20 Nov 2012 00:00:00 +0100

ABA/ABA conference underscores

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Way back in the 1960s, a diverse band--Sly and Family Stone--was extremely popular for a few short years. One of their hits, "Stand," had a great line:

"You've been sitting much too long."

That reminded me about the need to actually do something.

WHERE DO WE GO FROM HERE?

Byrne — Mon, 29 Oct 2012 01:00:00 +0100

AML changes regardless of the election winner?

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The lyrics to the Alicia Keys or the Chicago song (you can guess which one I know) are not relevant to my theme today--but the title certainly is. (Note: I've used this title before but acknowledged a Pink Floyd son--what can I say, song lyrics and titles were better years ago than now.)

'NO PLAN B*'

Byrne — Mon, 08 Oct 2012 01:00:00 +0100
AML professionals meet in Vegas

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The release this week of a new (and tremendous) Van Morrison album (*Born to Sing: No Plan B), serves as a good reminder that there is no Plan B to working together to combat illicit funds movement.

The timing of that reminder is fitting, as the ACAMS 11th Annual AML and Financial Crime Conference has just ended and 1,500 AML p [...]

EVERYBODY'S BEEN BURNED*

Byrne — Fri, 14 Sep 2012 01:00:00 +0100

But the three "prongs" of AML can all work together

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In 1967, the Byrds were not contemplating the three parts of the AML community (law enforcement, regulators, and the financial sector) when David Crosby opined that we all have had obstacles and have all been burned at some point. As many readers prepare for the ABA/ABA Money Laundering Enforcement Conference (which I am proud to have c [...]

TIME IS (NOT) ON MY SIDE*

Byrne — Thu, 23 Aug 2012 01:00:00 +0100

Not even the Rolling Stones would wait to reach out

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Whenever Mick Jagger and the boys (ok, the very old men) sing this 1965 classic, I am always struck by how the last thing we have on our side is Time.

Windows of opportunity close so rapidly today, whether it is in politics and the need to respond to another policy position devoid of fac [...]

RESPONDING YET AGAIN TO A MAJOR REPORT

Byrne — Fri, 03 Aug 2012 01:00:00 +0100

"The things you think are useless, I can't understand"*

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I have certainly tried to explain to the AML community the importance of gauging the success of your compliance programs by reviewing enforcement actions, guidance, and typologies.

This is not by simply [...]

�ALL IN ALL, ANOTHER BRICK IN THE WALL?'*

Byrne — Fri, 13 Jul 2012 01:00:00 +0100
CDD: Another obligation without a trade?

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The AML community (government and the regulated) constantly emphasizes both outreach and communication. It is safe to say that no one believes that efficient and effective regulation can occur unless we hear one another, understand challenges, and are willing to compromise. (Compromise is not surrender.) However, do we truly practice [...]

�THE SPACE BETWEEN'*: 14 AML/BSA THOUGHTS TO CONSIDER

Byrne — Fri, 22 Jun 2012 01:00:00 +0100
What's Wrong Or Right �or "Nobody's Right If Everybody's Wrong" **

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As we approach Independence Day and our collective commemoration of the freedom and liberty we are so fortunate to have in the U.S., it is also important that we acknowledge the many challenges we face. Recognizing challenges and being candid is a luxury we have as Americans and to quote Dave Matthews, there is a "space between" what's wrong or rig [...]

THE TIMES THEY ARE A-CHANGIN'

Byrne — Tue, 22 May 2012 01:00:00 +0100
An open letter to the next FinCEN Director

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As you all know by now, there will be a new Director of the Financial Crimes Enforcement Network (FinCEN) in the near future.

�

Having been fortunate to have worked with all of the directors since the very beginning in 1990, I want to take this opportunity to offer suggestions for the next occupant of this important post. While some of what I [...]

TAKE IT EASY*

Byrne — Tue, 08 May 2012 01:00:00 +0100

Once again, overreaction by Congress harms AML communication opportunities

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It never ceases to amaze me how often elected officials quickly overreact to an issue without considering the consequences. In fact, many may argue that they never seem to act quickly when necessary.

(Note: While one clear exception may be the USA Patriot Act as a prompt response to 9/11, swift and decisi [...]

JUST NEVER SHOW THE FEAR THAT'S IN YOUR EYES

Byrne — Fri, 20 Apr 2012 01:00:00 +0100

Staying on top of key issues

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This week we lost two music icons, Dick Clark and Levon Helm, and that always makes me consider how relevant music is to everyday life--even something as arcane as our industry--AML and financial crime.

The first, Dick Clark, was a constant in offering television audiences in the 50s-80s a snapshot of what was popular and what was moving up in popularity. In a strange way, AML conferenc [...]

WHERE DO WE GO FROM HERE?*

Byrne — Mon, 09 Apr 2012 01:00:00 +0100

Learning from the Citibank order

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I don't typically do a blog so soon after the last one, but the Comptroller of the Currency's April 5 Citibank order made me think that a quick snapshot of themes may be appropriate.

I will leave to others the burden of producing a detailed analysis of what can only be seen as a major ac [...]

OFFICIALS WARN BANKERS OF THREATS UNDER THE RADAR

Byrne — Fri, 30 Mar 2012 01:00:00 +0100

I.G.Y.: "A just machine to make big decisions?" No, as always, up to us

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Every time I return from a conference, I am struck by the mixed emotions and strategies of the participants. Some clearly attend to learn from the panelists, share information and best practices with peers, and leave with a commitment to improve whatever situation they left when they arrived at [...]