ACAMS Today had the opportunity to speak with John J. Byrne, CAMS, president of Condor Consulting LLC, former ACAMS executive vice president and senior advisor to the ACAMS advisory board, to discuss anti-human trafficking (HT) projects he is currently working on and how HT has evolved in the anti-money laundering (AML) field.
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, 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 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 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. In addition, Byrne received the ACAMS Lifetime Service Award in September 2017.
ACAMS Today: In what ways can the reporting and detection of HT be improved?
John J. Byrne: We first have to acknowledge the tremendous support of the financial sector for their efforts in detecting and reporting HT. Unfortunately, some in Congress are unaware of how proactive the private sector is now. As for improvements, the community working on human trafficking has been strongly advocating more reporting on labor trafficking so that should be added to the work of the financial sector.
AT: Last month, you spoke to Sara Crowe and David Medina of Polaris to discuss human trafficking on the ACAMS Today AML Now podcast. What did you learn about HT from them that you previously did not know?
JB: Again to my previous point, they made a compelling case that victims of forced labor in domestic work, farming and nail salons are being harmed in even greater numbers than victims of sex trafficking.
AT: How can beneficial ownership information assist in preventing HT?
JB: Anytime there is increased transparency in learning who actually owns a business, there is improved risk assessment.
AT: How have efforts to combat HT changed throughout your time in the AML industry?
JB: When several ACAMS members came to us in 2011 and recommended that financial institutions wanted to work with their law enforcement counterparts to develop “typologies” and “red flags” for broader AML community distribution, we jumped at the opportunity. The result of those working groups was new data and trends for institutions to create and I am sure the increase in suspicious activity reports on suspected human trafficking was a direct result. It was also comforting to see the private-public partnership that resulted from this project and the excellent leadership of the Department of Homeland Security in anti-HT.
AT: What other projects are you working on to help in the fight against HT?
JB: Building from the previous project I mentioned, we have had several meetings with Polaris and a number of AML leaders from financial institutions are creating an updated list of typologies and indicators of HT for a new report from Polaris. You should expect to see that in spring 2018.
AT: Do you have any other advice you would like to share with us?
JB: Whenever a banker complains about regulatory burden, explain how AML can save lives in areas such as human trafficking. That is not a burden.