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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.

An edited transcript of their responses follows.

On France’s priorities for 2023:

Thomas de Ricolfis, director, Anti-Financial Crimes Sub-directorate, national police, France: Our focus will be on collector networks [those who collect cash to be laundered]. This is not new, but we will refocus on this topic: Cryptocurrencies, obviously, as they are growing. And there will be a focus on low-level corruption.

In France, we are far from what the Encrochat and Sky ECC investigations revealed about the level of criminal infiltration in Belgium or the Netherlands, but it is an area of concern for us too.

It is very likely that the Russian-Ukrainian war will continue to have a big impact on AML professionals. We will also keep a close eye on the European economic recovery plan, and, like many other European countries, we will also be particularly vigilant on the unwinding of the economic support measures put in place following the pandemic.

At the national level, we are rather ahead of the future AML standards discussed at the EU level, whether in terms of cash payment limits or supervision of VASPs [virtual asset service providers].

The most important adjustments that could take place concern data exchanges within the EU. There are ongoing discussions on a common bank account file, on the standardization of the transmission of banking information.

For us, the developments should mainly concern the exchange of information in order to have interoperable databases, and these are important areas of progress for us. The hardest part is the exchange of information. Knowing who has a bank account is important.

On developments in Germany:

Birgit Rodolphe, chief executive director of resolution and prevention of money laundering, Federal Financial Supervisory Authority [BaFin], Germany: In my view, the legal framework concerning cryptocurrency businesses as well as supervision of such players will increase, and companies will need to adapt to that. I also think we will see a development in the use of algorithms in transaction monitoring. The requirements regarding KYC on customers and ultimate beneficial owners will become stricter. Separately, the coming European harmonization of rules will mean that we will all need to adapt to the future supervisory architecture.

The risks identified in Germany’s national risk assessment and in BaFin’s own risk assessment feed into our annual supervisory priorities for combating money laundering. We will continue to focus on our medium-term priorities, particularly on self-audits and imposing penalties where appropriate.

In terms of examinations, we will continue focusing on high-risk areas in the non-banking financial sector in the coming year while also continuing to monitor banks closely. We perform regular risk profiling for the institutions under our supervision. Accordingly, we plan our supervisory actions and onsite inspections for the coming year on a risk-based basis.

A new Federal Authority for Combating Financial Crime will meanwhile bundle relevant agencies under one roof, which is an important step in the right direction.

On Switzerland’s priorities:

Michael Manz, head of Switzerland’s delegation to the Financial Action Task Force: Swiss priorities for 2023 include the drafting of a bill on transparency and identification of beneficial owners of legal entities and various other legislative projects that should improve the effectiveness of the anti-money laundering, combating-the-financing-of-terrorism regime.

The aim of the bill is to strengthen the prevention and prosecution of financial crime and thus the integrity and reputation of the Swiss financial center and economy. In particular, this project aims to introduce a central register for the identification of beneficial owners, as well as new obligations to update information about them, based on risks. This register will be accessible to the competent authorities, but not to the general public.

Separately, it has been more than three years since FATF extended its standards to cryptocurrency, but implementation in most countries is still insufficient. It will be important to make progress here.

On cryptocurrency and the travel rule:

Steven Christie, senior vice president for compliance at Binance: The travel rule and how it’s being implemented in different parts of the world will be a challenge.

There’s a disconnect, in many instances, between the policies that countries are implementing, and the realities of the technology. That creates an obvious friction, one that is very difficult to navigate around, and that’s something that industry is going to continue to struggle with unless or until the policies come into alignment with the practical realities.

The regulation was designed, really, with SWIFT [the Society for Worldwide Financial Telecommunication] in mind, which is a highly centralized, permission-based network. That does not necessarily reflect the realities of being in a completely distributed or decentralized, permissionless network.

How companies manage to mitigate risks, including contagions from different business lines, the transparency of their operations—those things will be a primary focus for regulators that will impact compliance. Overall, 2023 will probably be a little bit tougher given the high-profile issues we’ve recently seen in the industry. The scrutiny level will increase and the margin for error is going to reduce, but I think it’s a welcome challenge.

It’s really going to be about ensuring that you have the proper build out of all the other, non-marquee item aspects of a compliance program: your controls, governance, committee oversight, and the right internal communication and reporting processes.

On sanctions:

Daniel Tannebaum, partner and global head of anti-financial crime at Oliver Wyman, a global consulting firm in New York: Looking ahead, one challenge in 2023 will be figuring out OFAC’s [the Office of Foreign Assets Control’s] first-of-its-kind price cap on Russia-sourced, maritime crude oil shipments, which is likely to be followed by caps on refined products early in 2023.

The new year will also determine whether the imposition of blacklists will be followed up by effective enforcement. With all the sanctions that have been put out into the ether in 2022, it is now incumbent on governments to ensure that companies are following the letter of the law, and if they are not, making sure there are penalties to pay, especially if these firms were going out of their way to violate the restrictions.

Susannah Cogman, partner, Herbert Smith Freehills law firm, London: People sometimes find OFSI’s [the U.K. Office of Financial Sanctions Implementation’s] choices for enforcement a bit curious, and it will be interesting to see what matters they pursue in respect of sanctions against Russia. This will be quite important for how the agency is perceived, and whether the messages OFSI has been sending about strict liability hold value. I don’t know that we will, but it would be great to see some examples of egregious conduct subjected to significant enforcement, rather than honest, good-faith mistakes subjected. The other area where it would be positive to see enforcement is sanctions circumvention—criminal prosecution of those who help others evade—which would strengthen the regime and drive better compliance.

A lot of clients are concerned about the potential of China invading Taiwan, whether such a scenario would lead to a raft of sanctions like those against Russia, and how it would all play out.

On FinCEN and the Anti-Money Laundering Act:

Gregg Rozansky, senior vice president and senior associate counsel, Bank Policy Institute: There was a lot of focus last year on AMLA [the Anti-Money Laundering Act] and keeping a close eye on what FinCEN is planning to do in terms of implementing the requirements. In all honesty, there is still some uncertainty, but some of this will be resolved in 2023.

For example, FinCEN has identified—as it was required to do under the law—priorities for AML and CTF [counterterrorist financing] objectives of the government, and those ultimately will need to be incorporated into the risk-based AML program requirements.

Historically, the risk assessments were based on things like geography or the position someone may have, but financial institutions will now need to think about this in different dimensions, different ways.

Regarding beneficial ownership, there’s still a lot of questions around access to FinCEN’s database and the extent to which institutions can rely on it. Banks clearly are hoping that they will have access and that FinCEN will be verifying the accuracy of the information in the database.

There’s also implementation of new whistleblower protections under AMLA, which will give employees within financial institutions protections—and also financial incentives—to raise BSA [Bank Secrecy Act] and AML issues.

AnnaLou Tirol, former deputy director, FinCEN; now partner, O’Melveny law firm: One thing for 2023: I would like to see whether the whistleblower program truly expands. FinCEN had a whistleblower program previously that only applied to a very specific number of violations, but the AML Act covers any alleged violation of the BSA. This not only means a broader program in terms of violations, but also in terms of the number of individuals who could qualify as whistleblowers, such as a member of an audit team inside a financial institution.

Then, importantly, the retaliation protections that were in the AML Act were very broad. Financial institutions need to be tracking that very closely. They should be asking questions about what that means for their internal complaint process.

Also, keep an eye out for real estate. Real estate and beneficial ownership are cornerstones of the administration’s anti-corruption strategy. When you look at the finance side, those are the two major pieces of the anti-corruption effort—a ‘whole of government’ effort.

Jason Foye, senior director, AML investigations, Financial Industry Regulatory Authority: From the AML and fraud perspectives, we anticipate continued focus on Russia sanctions compliance and evasion tactics in 2023, as well other priority threats such as new account fraud, complex market manipulation and trading frauds, and Ponzi schemes.

However, having been in this space for the past 15 years, I also know that it is critical that we expect the unexpected in the sense of we don’t know what threats will emerge in 2023, but we know they will emerge and require our attention and resources.

One area we know will demand attention in 2023 is crypto assets.

FINRA is actively working on its oversight of firms and associated persons with direct or indirect touch points to crypto assets. FINRA’s Office of Financial Innovation has created a Blockchain Lab focused on the development of blockchain-related regulatory initiatives that can support our regulation of all asset classes.