The ACAMS Connection is a bi-weekly e-newsletter exclusive to ACAMS members. It provides members with a snapshot of anti-money laundering (AML) current events, the latest trends in financial crime and updates on what is new to the ACAMS community. The ACAMS Connection is the trusted source by ACAMS members for staying on top of industry best practices. Click here to subscribe to the ACAMS Connection newsletter.  

Recently Featured

Casinos: Responding to New and Evolving Money Laundering Risks

Throughout history, people have engaged in games of chance for entertainment or financial gain. Games of chance are, at their core, based on mathematics and probability. A roll of the dice or spin of the wheel, in conjunction with a set of rules, makes it possible to predict and calculate the likelihood of all possible outcomes.


The Importance of Collaboration in CSE Investigation

Child sexual exploitation (CSE), child sexual abuse materials (CSAM) and child sex trafficking (CST) are serious crimes that adversely impact children being coerced or manipulated into engaging in sexual activity for financial gain. The ACAMS Today Back-to-the-Basics article, “Beyond The Headlines—A Real Look at Trends in CSAM and CST,”1 introduces and delves deeper into this topic and provides a classification for these heinous crimes.


What Are the Sunday Scaries?

“Set peace of mind as your highest goal and organize your entire life around it.” Brian Tracy1 The term “Sunday Scaries,” sometimes referred to as the Sunday Blues, is believed to have been coined in or around 2009. There is some debate regarding who created the term. Some say it was a person who would eventually become a TikTok influencer.


Previously Featured

Casinos: Responding to New and Evolving Money Laundering Risks

Throughout history, people have engaged in games of chance for entertainment or financial gain. Games of chance are, at their core, based on mathematics and probability. A roll of the dice or spin of the wheel, in conjunction with a set of rules, makes it possible to predict and calculate the likelihood of all possible outcomes.


The Importance of Collaboration in CSE Investigation

Child sexual exploitation (CSE), child sexual abuse materials (CSAM) and child sex trafficking (CST) are serious crimes that adversely impact children being coerced or manipulated into engaging in sexual activity for financial gain. The ACAMS Today Back-to-the-Basics article, “Beyond The Headlines—A Real Look at Trends in CSAM and CST,”1 introduces and delves deeper into this topic and provides a classification for these heinous crimes.


What Are the Sunday Scaries?

“Set peace of mind as your highest goal and organize your entire life around it.” Brian Tracy1 The term “Sunday Scaries,” sometimes referred to as the Sunday Blues, is believed to have been coined in or around 2009. There is some debate regarding who created the term. Some say it was a person who would eventually become a TikTok influencer.


Lessons Custodians Can Learn From Traditional Correspondent Banking

Custodians, which are financial institutions that provide the safekeeping and servicing of investor assets including stocks, bonds and other assets, are exposed to some serious money laundering and financial crime risks. The Financial Crimes Enforcement Network’s (FinCEN) unprecedented enforcement action against a trust and custody firm is a perfect example of that risk and the possible consequences.


Four Questions: A Look at the State of Ransomware, Sanctions and Other Global Issues

Sam Cousins is a senior associate at ACAMS, where his work includes supporting public-private partnerships and strengthening ACAMS’ thought leadership pillar through the development of content on sanctions and risk, particularly the Sanctions Masterclass program and Global Monthly Update. Cousins’ work also focuses on countering ransomware financing, which includes enhancing industry awareness of the anti-financial crime risks associated with ransomware attacks and supporting the mitigation of those risks through policies,


Making the World Safe for DeFi, With Seoyoung Kim

In this “Financial Crime Matters” episode, Kieran Beer talks with Seoyoung Kim about the promise and possible perils of decentralized finance. Kim is associate professor of Finance and department chair at Santa Clara University. 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.


Ask the AFC Guru: Sanjeev Menon—Staffing Solutions

Anti-financial crime (AFC) guru Sanjeev Menon, managing director of Madison Davis’s Legal and Compliance Practice Area, specializes in executive recruitment and provides staffing and workforce solutions to compliance and anti-financial crime (AFC) clients. Menon, who is an ASA Certified Staffing Professional and holds a Society for Human Resource Management-Certified Professional designation, is here to answer your top AFC staffing questions.


Fines for AML Compliance Failures

Fines to banks for anti-money laundering (AML) compliance flaws can occur due to various reasons. AML regulations are put in place to prevent financial institutions (FIs) from being used for illicit activities such as money laundering and terrorist financing. When banks fail to meet the requirements and demonstrate flaws in their AML compliance, regulatory authorities may impose fines as a form of punishment.


Doris Birmingham: Evolving with BSA

Doris Birmingham is the administrative officer, senior Bank Secrecy Act (BSA) analyst at American National Bank of Texas (ANBTX). Previously, Birmingham was a senior auditor with direct reports and specialized in retail/consumer banking and compliance audits, including BSA, the Sarbanes Oxley Act (SOX), the Privacy Act and the USA PATRIOT Act. She has a proven ability to communicate and build strong relationships throughout the banking network,


Beyond the Headlines—Sextortion

Editor’s note: This article is the second of a three-part series on child sexual abuse material (CSAM) and child sex trafficking (CST). The first part is available here. ***Disclaimer/trigger warning: This article discusses sexual offenses committed against children. Reader discretion is advised. What is sextortion? Sextortion is a form of online extortion that involves the threat of distributing intimate or sexually explicit images or videos of a victim unless they comply with the demands of the blackmailer.


Incorporating FinCEN’s National Priorities Into Risk Assessments

The article titled “FinCEN’s AML and Terrorist Financing Priorities: An Introduction,” featured in the June-August 2022 edition of ACAMS Today, shared general thoughts, basic definitions and practical examples on each of the national anti-money laundering (AML) and counter-terrorist financing (CTF) priorities

The article titled “FinCEN’s AML and Terrorist Financing Priorities: An Introduction,” featured in the June-August 2022 edition of ACAMS Today,


Parsing the Challenges of Fighting Financial Crime, With Rick Small, Dan Soto and John Byrne

In this episode of “Financial Crime Matters,” Kieran Beer talks with Rick Small, director Financial Crimes Program at Truist, Dan Soto, chief compliance officer at Ally Financial and John Byrne, executive vice president at AML RightSource about what has been achieved in the past 40 years in the fight against financial crime and what challenges lay ahead.


Managing Risk and Compliance in a Volatile World

An unprecedented confluence of crises has transformed the financial crime and risk landscape, turning the screws on the compliance efforts of financial institutions (FIs). Circumstances such as the ongoing Russia-Ukraine conflict, resulting spikes in geopolitical tensions between the West and Russia and China, in addition to a teetering U.S. economy plagued by stubborn inflation, have presented unforeseen challenges to leaders that call for the fortification of compliance controls and crime prevention strategies.


AI in KYC for Community Banks

Know your customer (KYC) is a familiar topic for all banks, regardless of size. Traditionally for community banks, this was one of the easier blanks to fill in. Being local generally meant a community banker knew their customer personally or at least through easily verifiable means. There is a comfort level to an understanding with relative ease of the expected activity and background of new customers onboarded at a community bank in a traditional setting.


Four Questions: Understanding Sanctions Imposed Against Russia

Russia’s invasion of Ukraine and the subsequent sanctions that the U.S., European Union (EU) and other countries imposed against Russia in the wake of this act of aggression have been the focus of worldwide media attention since February 2022.


FinCEN’s Drug Trafficking Organization Activity Policies

The article titled “FinCEN’s AML and Terrorist Financing Priorities: An Introduction,”1 featured in the June-August ‘22 edition of ACAMS Today, shared general thoughts, basic definitions and practical examples on each of the Financial Crimes Enforcement Network’s (FinCEN) national anti-money laundering (AML) priorities. This article, the ninth of the series, will discuss drug trafficking organization (DTO) activity in greater detail.


Your First 30 Days as an AML Compliance Officer

With the rising threat of money laundering and terrorist financing, regulators are more vigilant in preventing financial crimes. To assist the authorities in curbing these crimes, the anti-money laundering (AML) regulations mandate financial institutions, virtual assets service providers (VASPs), and certain nonfinancial businesses and professions to implement an AML/counter-terrorist financing (CTF) framework.


Preparing for Europe’s AMLA and Fighting Financial Crime, with Dutch Central Banker Willem Schudel

In this episode of "Financial Crime Matters," Kieran Beer talks with Willem Schudel, head of department, Financial Crime Supervision (anti-money laundering and terrorist financing) at the Central Bank of the Netherlands, live from The Assembly Europe, ACAMS’ annual conference, held this year in Dublin.


The Potential Perils of Online Gaming

Online video games have become a popular pastime for people of all ages. However, with the evolution of the gaming industry, exposure to financial crimes is rapidly increasing. The rise of virtual economies and the increasing value of in-game items and currencies have made it more appealing for criminals to use microtransactions and loot boxes in video games to launder money.


The Devastating Effects of Fentanyl Trafficking

Fentanyl is a powerful synthetic opioid drug used for analgesic (pain relief) and anesthetic purposes in both human and veterinary medicine, in addition to treating patients with severe or chronic pain. Launched in 1963 by Janssen Pharmaceuticals, founded by Belgian Dr. Paul Janssen, fentanyl is the most widely used anesthetic in the world.


Jonathan Schnatz on the IRS-CI and Countering Sanctions Evasion

“What we’re really seeing is the use of professional enablers, both by oligarchs to continue to hide their assets, and also in the export controls sanctions cases where they’re using shell corporations to hide the true shipment of goods.” In the latest episode of the “Sanctions Space” podcast, Justine Walker is joined by Jonathan Schnatz, special agent and senior analyst at the U.S.


Revolutionizing AFC Through ChatGPT

Integrating ChatGPT into current anti-money laundering (AML) techniques is a novelty and a controversial issue. ChatGPT was created by OpenAI in 2020 and it is a powerful artificial intelligence (AI) model that uses natural language processing to understand and generate human-like responses. ChatGPT may have the potential to revolutionize AML techniques by automating and predicting the detection of suspicious financial activities, thus reducing the risk of financial crimes.


Creating the Next Wave for Fighting Financial Crime, With FINTRAC’s Sarah Paquet

In this episode of “Financial Crime Matters”—a live recording from the ACAMS Assembly in Hollywood, Florida—Kieran Beer talks with Sarah Paquet, director and CEO of the Financial Transaction Reports Analysis Centre (FINTRAC). Paquet discusses FINTRAC’s new role handling sanctions intelligence, managing the revolution in financial technology and the ongoing commitment of the financial intelligence unit (FIU) to expand and further internationalize Canada’s anti-financial crime public-private partnerships.


Maha Khan: Find the Influencer and Change Will Happen

ACAMS Today sat down with Maha Khan, Financial Sector lead with the Finance Against Slavery and Trafficking (FAST) initiative, a project based at United Nations University Centre for Policy Research (UNU-CPR), during the ACAMS 2023 Hollywood Assembly, to discuss the newly updated Fighting Modern Slavery and Human Trafficking (FMS and HT) social impact certificate and its importance.


FinCEN’s Transnational Criminal Organization Activity Policies

The article titled “FinCEN’s AML and Terrorist Financing Priorities: An Introduction,” featured in ACAMS Today, shared general thoughts, basic definitions, and practical examples on each of the national anti-money laundering (AML) priorities. This article, the seventh of the series, will discuss transnational criminal organization (TCO) activity in greater detail.


Have Sanctions Against Russia Prompted Commodity Laundering?

Sanctions can be effective if they are proportional to the strength of their enforcement and the unity of global efforts. EU sanctions against Russia, its oil and natural gas industry, are not an exception to this rule. Whilst many suggest that sanctions have worked as planned, the surfacing data reveals that much more collective work is needed.


Matt Zweig on the Dynamics of U.S. Congressional Sanctions Policy

"I always like to describe Congress as writing in pen, and the administration as writing in pencil.” In the latest episode of the “Sanctions Space” podcast, Justine Walker is joined by Matt Zweig, Senior Director of Policy at FDD Action.


FinCEN’s Fraud Policies

The article titled “FinCEN’s AML and Terrorist Financing Priorities: An Introduction,” featured in the ACAMS Today 12th Law Enforcement Edition, shared general thoughts, basic definitions, and practical examples on each of the national anti-money laundering (AML) priorities. This article, the sixth of the series, will discuss fraud in greater detail.


Financial Crime Prevention in Small Companies

“Who watches the watchmen?” Often, in a very small company, there is only one person who serves as both the back office and compliance person. And as the person in the hot seat, you know that good systems are critical to prevent deliberate and inadvertent financial crime.


Unpacking Fintech, Regtech and Suptech

The term financial technology (fintech) is many times used interchangeably when referring to regulatory technology (regtech) and supervisory technology (suptech). However, these technological solutions should not be lumped together. Let us unpack the distinct differences. What is Fintech? Fintech includes the provision of financial services using technology. Initially, banks were using technology to support their systems.


Information Sharing: Why Community Banks Should Participate

Section 314 of the USA PATRIOT Act, which was passed back in 2001, is a vital portion of the legislation. Anyone who had been in the anti-money laundering/Bank Secrecy Act (AML/BSA) space prior to 2001 understands how significant this change was to the industry. Section 314 specifically centered around the ability of financial institutions (FIs) and law enforcement (LE) to share information.


The Rising Demand for AML Specialists

The global COVID-19 pandemic had widespread consequences. International lockdowns and subsequent work-from-home mandates created an unprecedented increase in financial crime, leading to a rising demand for anti-money laundering (AML) specialists. This has been primarily driven by continuous changes in technology, where security measures may not have been as stringent as they should have been.


Re-thinking the ‘War on Dirty Money,’ with Tristram Hicks

In this episode of “Financial Crime Matters,” Kieran Beer talks with Tristram Hicks, co-author with Nicholas Gilmour of “The War on Dirty Money,” an examination of the promise and shortcomings of the current costly global effort to combat financial crime.


Digital AML Transformation in Times of War

After almost a decade of military and political conflict, in February 2022, Russian troops invaded Ukraine through its eastern border in what the Kremlin officially denominated a “special military operation.” Among the immediate results were a massive and ever-growing humanitarian crisis (with more than eight million Ukrainian leaving the country, the biggest refugee crisis in Europe since World War II).


Why FIs Should Consider Banking Marijuana Dispensaries

Former Financial Crime Enforcement Network (FinCEN) Director Kenneth Blanco once said, “Banks must be thinking about their crypto exposure. If banks are not thinking about these issues, it will be apparent when examiners visit.” This advice from the former FinCEN director can also be applied to marijuana banking; financial institutions (FIs) cannot ignore the marijuana industry and expect not to be exposed to the risk associated with the industry.


Toms Platacis on the Frontline of Sanctions Implementation

“Unfortunately, I must say that you don’t have to be a criminal mastermind to come up with a sanctions evasion or circumvention scheme… most of the time, they’re not very sophisticated.” In the latest episode of the “Sanctions Space” podcast, Justine Walker is joined by Toms Platacis, acting head of Latvia’s Financial Intelligence Unit.


Insider Fraud and Employee Monitoring: Learn from Others’ Mistakes

When thinking of employees who have reached managerial roles or work in loss prevention, the last attribute that comes to mind is untrustworthy. However, that is exactly what they were in 2022 at Amazon. These roles naturally convey trust, which can lead to unquestioned agreement and unearned respect.


Keeping Up with the Financial Action Task Force and Beyond, with David Lewis

In this episode of “Financial Crime Matters,” Kieran Beer talks with David Lewis, executive secretary of the Financial Action Task Force (FATF) from 2015 to 2022, about the FATF’s recent plenary that gray listed South Africa and Nigeria, formally suspended Russia from membership, and criticized governments throughout the world for lax oversight of cryptocurrency businesses.


The Big Impacts of Small, In-House BMAs: A Case Study in the Fight Against Corruption

Faced with the challenges imposed by COVID-19 and global economic downturns, what will differentiate strong businesses from weak ones going forward will be their ability to think ahead, adapt and innovate. Fighting corruption and other financial crimes continues to be a huge operational burden and a major pain point for many governments and private institutions, particularly when it comes to investigating and adjudicating underlying criminal activity.


The Great Divide: Getting Convergence Right This Time

As the world becomes increasingly interconnected and digital, so too has the threat of financial crime. Traditionally, siloed methods of combating financial crime, such as anti-money laundering (AML) and fraud detection, must adapt to the changing landscape and find ways to effectively mitigate the risks posed by increasingly sophisticated cybercriminals.


Trade Finance Risk and Controls

Trade finance is described as the provision of finance and services by financial institutions (FIs) for the movement of goods and services between two points, either within a country or across borders. There are multiple methods by which an FI can participate in the financing of product movement. The type of trade finance transaction and the role the FI plays in the transaction is the starting point for determining the risk of the transaction to the FI.


The BSA Tractor

You may have read it in magazines or seen the news or videos of some altruistic country sending modern tractors to aid farmers in developing nations. It seems surprising when they return later to find all the tractors in disrepair, with some now even being pulled by teams of horses. Some reactions blame the farmers for either ignorance or ungratefulness.


FinCEN’s Cybercrime and Cybersecurity Policies

The article titled “FinCEN’s AML and Terrorist Financing Priorities: An Introduction,” featured in the ACAMS Today 12th Law Enforcement Edition, shared general thoughts, basic definitions and practical examples on each of the national anti-money laundering (AML) priorities. This article, the fourth of the series, will discuss cybercrime and relevant cybersecurity and virtual currency considerations in greater detail.


How Britain Became Butler to the World’s Financial Criminals, with Oliver Bullough

In this episode of “Financial Crime Matters,” Kieran Beer talks with Oliver Bullough, award-winning reporter for The Guardian, about his latest book, Butler to the World: How Britain Became the Servant of Tycoons, Tax Dodgers, Kleptocrats and Criminals.


Dissecting the Mafia: Sicily’s Cosa Nostra

For the past 100 years, the mafia’s brutal and lawless presence has influenced everything from pop culture to history, extending beyond Italy’s borders to impact crime around the world. The word mafia is used as an informal term for four major groups: Calabria’s ‘Ndrangheta, Campania’s Camorra, Puglia’s Sacra Corona Unita and the most influential of the groups, Sicily’s Cosa Nostra, or the Sicilian Mafia.


Fighting the Online Exploitation of Children, With Jonathan Dupont and Tiffany Polyak

In this episode of “Financial Crime Matters,” Kieran Beer talks with Jonathan Dupont, a financial intelligence investigator for Western Union, and Tiffany Polyak, anti-financial crime (AFC) associate at ACAMS, about the growth in online sexual exploitation of children and the related rise in child sexual abuse materials on the internet.


Human Trafficking: Detection and Investigations

The first part of this series, “Human Trafficking: Persona-based Typologies and Methodology,” re-emphasized the scale of the human trafficking (HT) problem and the key investigation challenges to tackle, including the need to reconsider the current HT detection and investigation approach.


Justyna Gudzowska and Dan Tannebaum on Looking Ahead to 2023

“As we look at Ukraine, as we look at these unprecedented sanctions, we really have to close the loopholes that are created by the Wagner Group’s presence in many countries around the world, in particular in Africa.” The “Sanctions Space” podcast is back! Justine Walker is joined by Dan Tannebaum, Atlantic Council, and Justyna Gudzowska, The Sentry.


Dozens of Whistleblowers Have Contacted FinCEN Since December: Sources

More than 50 people have secretly flagged anti-money laundering deficiencies and sanctions evasion to U.S. officials in the month since Congress bolstered a fledgling, federal whistleblower program, two sources with direct knowledge of the matter told ACAMS moneylaundering.com. Click here to read the full article.


The Nexus Between Ransomware, Cryptocurrency and Money Laundering

In May 2021, American motorists across the states of Virginia, Georgia and North Carolina panicked as they scrambled to fill their vehicles at gas stations. The run for fuel was a result of a cyberattack on the Colonial Pipeline, which was forced to shut down its supplies of diesel, petrol and jet. Colonial Pipeline’s operations were disrupted by a ransomware attack perpetrated by Darkside―a criminal gang that demanded a ransom of 75 bitcoin ($4.3 million).


Machine Learning: A Game-Changer in the Fight Against Money Laundering

Financial crime, including money laundering, is an illicit growing industry, and criminals are getting increasingly sophisticated. Financial institutions (FIs) are deeply involved in combating this. In North America alone, they spent a little less than $50 billion on compliance in 2021.


The Importance of Regular Independent AML Audits

The legal and regulatory landscape of the anti-money laundering/counter-terrorist financing (AML/CTF) sector is in constant flux and necessitates a dedicated function to assess the level of compliance and the effectiveness of obliged entities’ policies, procedures, measures and controls regularly.


The Nexus Between Terrorism and Human Trafficking

Editor’s note: This article is the first part of a two-part series on human trafficking and terrorist organizations. Human trafficking (HT) constitutes a serious human rights violation and is one of the most profitable criminal enterprises, attracting both small local groups and international networks.


Effective Compliance Programs Have One Thing in Common

According to the Financial Action Task Force (FATF), financial institutions (FIs) should be required to implement programs against money laundering and terrorist financing. The program should support the development of prevention and mitigation measures that are commensurate to the financial crime risk faced.


Beneficial Owners and Sanctions Against Russia: Compliance in 2023

The ball has dropped, the fireworks have faded, and the new year has arrived with new anti-money laundering rules, sanctions and other compliance-related responsibilities on the near horizon for the global financial services industry. Moneylaundering.com reporters Koos Couvée, Gabriel Vedrenne, Fred Williams and Benjamin Hardy asked regulators, investigators, attorneys, consultants and other sources to share their opinions on what the next 12 months hold in store for anti-financial crime professionals.


Sanctions, Shell Companies and Superyachts: Compliance in 2022

If years were disgruntled spouses, 2022 threw everything at us but the kitchen sink, starting with political turmoil in Britain, a criminal referral against a former U.S. president, uprisings in Iran, a standoff between superpowers near Taiwan and a decoupling of the global economy. Click here to read the full article.


Matt Richardson: Preventing Human Trafficking and Online Exploitation

ACAMS Today spoke with Matt Richardson about anti-human trafficking (HT) efforts and the future of HT, his participation in “Dark Highway” (an HT documentary that is being televised in Canada and the U.S.) and the different methods for maximizing online safety. Richardson is director of Intelligence and Investigations with the Anti-Human Trafficking Intelligence Initiative (ATII).


Human Trafficking: Persona-based Typologies and Methodology

Human trafficking (HT) has been widely researched and discussed in different forums and from different perspectives. Most recently, ACAMS Today’s brilliant three-part series, “Understanding Human Trafficking,” clarified key HT concepts, definitions and business models that are useful for every anti-financial crime (AFC) professional to understand.