Members of the international anti-financial crime (AFC) community congregated in Florida last week to discuss the latest developments in the AFC space during the ACAMS Assembly Hollywood, which took place from April 28-30 in Hollywood, Florida.
The conference’s informative sessions addressed an array of trending AFC topics, including artificial intelligence (AI), sanctions, regulatory changes, fraud and scams, cryptocurrency, terrorist financing, peer-to-peer payments, fentanyl and other narcotics trafficking, suspicious activity reporting, and sex and labor trafficking. The Assembly also offered attendees opportunities to meet and network during a variety of breakfasts, breaks, luncheons and receptions.
Foremost in attendees’ thoughts were concerns about U.S. regulatory uncertainty due to the beginning of the new administration, as marked by the announced non-enforcement of the Corporate Transparency Act earlier this year. Other top-of-mind issues for Assembly attendees included the continuing rise of global fraud, sanctions-related concerns such as the possibility of additional sanctions targeting Russia and Iran, the ongoing fentanyl crisis and the increasing role AI is playing in the fight against financial crime.
ACAMS CEO address
The first day of the Assembly Hollywood program kicked off with welcome remarks from Neil Sternthal, CEO of ACAMS. “You’re joined by 1,500 fellow [AFC] professionals from across the community: regulators, law enforcement, the private sector, professional advisors and solutions providers,” Sternthal said. “We all have a common goal: to protect the financial system, national security and individuals from the threat of illicit financial activity. What we do has never mattered more than right now.”
“This is a period of tremendous change and uncertainty for the United States and for the global community,” Sternthal continued. “But as CEO of ACAMS, I consider it both our honor and our responsibility to provide this community with a safe and trusted space to convene as well as to share insights and ideas with one another. By being here, surrounded by your peers and your leaders in the community, I hope you learn, connect and feel energized. I hope you leave the Assembly knowing how much ACAMS is here to support each and every one of you.”
Sternthal then named a few examples of offerings ACAMS provides to support AFC professionals in their career development, such as the Certified Anti-Fraud Specialist (CAFS) certification, which was launched last November; expanded delivery of ACAMS content including daily articles and regulatory updates, monthly AFC Regulatory Watch webinars, the “Sanctions Space” and “Financial Crime Matters” podcasts; AFC Toolkits on cartels and fentanyl trafficking; and the second annual Global Anti-Financial Crime Threats Report, which was published in February. In addition, ACAMS launched a new scholarship program—the CAFS Scholarship—at the Assembly Hollywood. The new scholarship focuses on AFC professionals who have taken a break from their careers.
Insights From Day One
Following Sternthal’s introduction to the Assembly, Tigran Gambaryan, head of Financial Crime Compliance at Binance, was featured during the opening keynote address, titled “Inside the Storm: What Compliance Must Learn from My Story.” During the presentation and Q&A session that followed, which was moderated by Kieran Beer, chief analyst and director of editorial content at ACAMS, Gambaryan discussed his harrowing experience of being unjustly detained in Nigeria for eight months in 2024.
During his time in captivity, Gambaryan was imprisoned alongside terrorists and fell ill with both malaria and pneumonia. Describing his state of mind at the time, Gambaryan said, “While this is happening, you’re living one day at a time. But what’s really driving you to keep going … it is family, it is your loved ones…. Maybe I didn’t have enough time to be depressed, but I guess I probably should have been.” He added that he was also focused on “getting out and seeing my family again, just knowing that this can’t be it.”
Despite his grave situation, he did have a someone on the inside who helped him—a fellow inmate Gambaryan describes as “the supercop of Nigeria” who was facing his own legal issues. “He kind of became my ‘Red’ from Shawshank Redemption, where he was able to help me secure a phone…. Most of the people in this facility could get some visitations from family, friends or attorneys. I was there completely by myself. A phone was the only way for me to communicate with anybody.” Having a phone in his possession made it possible to maintain contact with his wife and children, who were his reason for enduring such distressing conditions.
Later, during the special presentation “Immediate Sanctions Priorities for the New Administration,” Michael Cass-Antony of the U. S. State Department noted that financial institutions’ (FIs) departments should work together because a siloed approach introduces gaps that can be exploited by sanctions evaders. During the session, which was moderated by Dr. Justine Walker, head of Global Sanctions and Risk at ACAMS, Cass-Antony also thanked the AFC professionals in the audience for their sanctions efforts, adding that the State Department will continue to rely on AFC professionals’ diligence and will even “ask more of you.”
In the session “What Can a Compliance Officer Do that AI Can’t?” that afternoon, Kathleen Finn Bell of BMO Financial Group answered the question posed in the session’s title by saying, “I think the key thing is decisioning. We’re the moral conscience of any AI we are using. We’re aware of where we’re using it and making the decisions, especially when the decisions are difficult when they require recent information. Information that’s specific to our roles, to our institutions and to our situations.”
Another session that afternoon, “Building on a Foundation of Fraud: Payroll Tax Evasion in the Construction Industry,” provided a case study of the criminal case the United States v. Katz. The case involved a check-cashing company in Oregon that cashed more than 19,000 payroll checks through sham companies between 2014 and 2017, hiding a total of $177 million in wages and resulting in an estimated tax revenue loss of $44 million. Audience members learned that the architect of the scheme, David Katz, was found guilty of the crime last year and was sentenced to 48 months in prison earlier this year.
Insights From Day Two
At the keynote presentation on Tuesday, senior writer Andy Greenberg of WIRED and author of the book Tracers in the Dark, discussed his experiences investigating cryptocurrency and dark web platforms such as Silk Road and the subsequent sites that followed it. During his presentation, Greenberg noted his realization in 2020 that crypto was anything but untraceable, despite what many criminals believed. Greenberg observed that not many privacy tools make criminal transactions truly untraceable. “The most they offer criminals is more time,” he said.
In the session “AI Alignment: The Emerging Consensus on Risks and Benefits of AI in Financial Services,” panelists discussed the use of AI to better fight financial crime. Andrew Bingenheimer of U.S. Bank observed, “As we think as a community not wanting to enable nefarious activity to run through your various institutions, I think it takes a strong partnership collaboration between your technology partners, your vendor partners and obviously, your AML partners.”
Bingenheimer also emphasized the importance of AFC professionals becoming acquainted with AI and technology by using it. “The first step is demystifying the technology. While this emerging technology is complicated sometimes to execute on, it’s actually not that hard to understand in terms of what it’s doing and how it works.” He went on to suggest that activities like hackathons within organizations could help with the demystification of technology. “Personally, the one thing that is sort of an infinite loop is [using] the technology to learn the technology,” he said. “It’s just leaning into the curiosity.” Craig Timm of ACAMS, who moderated the session agreed adding, “You have to just jump in. You can start small. We’ve got plenty of resources available like webinars … to get in and start to use it. Just start to use it.”
In the following session “The ACAMS Great Debate: Should Criteria for “High Risk” Institutions and Customers Be Reassessed?,” Sam Raymond, of counsel at Gibson Dunn, and Clay Roberts of Western Union discussed whether FIs should determine a customer’s risk by industry type or by the customer’s activity. Raymond noted, “If I learned anything when I was in government, is that criminals talk to each other. There is a perception about certain industries, whether we like it or not, as being perceived as this industry is easier to launder money…. And as long as that's happening, I think unfortunately that means you're going to have more law enforcement resources or compliance resources focused on certain types of industries, whether that's fair or not.”
Meanwhile, Roberts emphasized the importance of monitoring activity, explaining that current high-risk categories are based on who you are, but monitoring activity is equally important when determining activity that can lead to a suspicious activity report filing.
During a deep dive session that afternoon on combating export controls evasion, panelists discussed how sanctioned entities such as Russia frequently employ intricate networks to circumvent export controls and acquire dual-use goods—items that can be used for both civilian and military applications. Session attendees learned how to identify dual-use goods, recognize geographic areas of concern and leverage import records in the fight against export controls evasion. One of the session’s panelists, Frank Calestino of Bank of America, noted, “Whether you are a small bank or a big bank, you have a treasure trove of data.” He added that it is important to contextualize data, and a dedicated compliance officer would be key in finding the needle in the haystack.
Key takeaways from the session included that FIs “now bear significantly greater responsibility in managing export control risks than in the past. Understanding and adapting to this evolving landscape is critical.” In addition, “government agencies emphasize a balanced, practical approach—encouraging institutions to assess risks based on their capabilities, prioritize key threat areas and address them methodically.”
Insights From Day Three
At the “Sanctions, Geopolitics and the Impact on Global Compliance Programs” session on the final morning of the Assembly Hollywood, attendees were asked how engaged the were in geopolitical scenario-planning. A surprising 45% of the audience answered “not engaged,” while only 7% responded “extensively engaged.”
During the session, Elaine Dezenski of the Foundation for Defense of Democracies noted, “I just want to emphasize the point that we are going through a massive … seismic shift in global trade orientation…. There’s really no way out of it. There’s no place to put your head in the sand. There are some winners potentially in all of this…. India is potentially a replacement market for certain parts of what the Chinese manufacturing base does, [although] not all of it.”
At the closing session of the 2025 ACAMS Assembly Hollywood, “ACAMS MLDC Presents the Latest Developments in AML/AFC,” panelists covered a range of late-breaking topics in the AFC space. Ana Davila, head of Risk Assessment and Intelligence at Stripe, shared insight on the EU’s Markets in Crypto-Assets Regulation, highlighting it as a good starting basis due to the clarity in defining different crypto, but noted it was too soon to determine if the regulation will work in the long term.
During the session, Rick Small, executive vice president at Truist Financial Corp., offered attendees his take on one of the hot topics at this year’s Assembly Hollywood: the prevalence of fraud. When asked whether we were losing the battle against frauds and scams, Small observed, “’Losing’ is a relative term, but they’re not decreasing. We are seeing a significant amount of fraud…. [Whether] it’s Zelle or Venmo or PayPal, you’re seeing … more disclaimers up front than even last year. ‘Are you sure you know who you are sending to?’ ‘This is cash.’ ‘Make sure.’”
Key Takeaways
Based on comments from the show floor, several issues were of particular relevance to attendees of this year’s Assembly Hollywood. Top-of-mind concerns for participants this year included: the challenges of small- and medium-sized FIs in selecting the right AI system to implement; staying informed on the various regulatory changes; uncertainty among AFC professionals regarding the impacts of the new administration; keeping up-to-date with and aware of new fraud schemes; the continuing scourge of drug trafficking—fentanyl in particular; and the current uncertain geopolitical landscape throughout the world.
Reported by the ACAMS Today Editorial Staff
Karla Monterrosa-Yancey, CAMS, editor-in-chief, kmonterrosa@acams.org
Ben Bahner, CAMS, editor, bbahner@acams.org
Monica Mendez, CAMS, consultant
Ana Acuna, web producer, aacuna@acams.org
