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ACAMS moneylaundering.com has packed our bags and said goodbye to sunny Florida at the close of The ACAMS Assembly Hollywood. In addition to all the usual stuff we jammed into our suitcases, we’ve brought back plenty of lessons and takeaways to share.

Tigran Gambaryan, head of compliance at Binance, kicked off the conference with an account of his eight-month captivity in Nigeria, where authorities detained and charged him with money laundering and tax evasion after he refused to pay a $150 million bribe.

After battling malaria and pneumonia, and with the help of the U.S. government, Gambaryan was released, but his story comes with a warning to anti-financial crime professionals working in jurisdictions “less regularly run than others.”

“You have to be cognizant of the fact that you are valuable,” Gambaryan said. “Be cognizant of the fact that just because you’re meeting with ‘the good guys,’ that you make sure they really do have the best intentions.”

Trump 2.0

Changes in regulation and enforcement were recurring topics at this year’s conference.

The Office of the Comptroller of the Currency’s deputy comptroller for compliance risk, Donna Murphy, briefly addressed the rollback of the Corporate Transparency Act during a roundtable discussion Monday morning.

“One thing I want to say about the CTA is that it’s really important for the bankers in the room to remember that in the U.S., banks are subject to the CDD [customer due diligence] beneficial ownership rule,” said Murphy. “That has not changed … The bank should just keep doing what you’ve been doing on beneficial ownership.”

The CDD rule requires banks to identify and verify anyone who owns or controls at least a 25 percent stake in U.S.-formed or -registered limited liability companies and certain other legal entities.

U.S. officials announced March 2 that they will not enforce the CTA against U.S. legal businesses, thus freeing LLCS, limited partnerships and other entities from their obligation to report the names, birthdates and other details of their owners or controllers to the Financial Crimes Enforcement Network, also known as FinCEN.

Regulators also said they have begun discarding the concept of “reputational risk” as a factor in supervision and enforcement by removing all references to the term in their training materials and guidance.

“So, if a bank decides not to bank a gun dealer, it’s not because they don’t like gun dealers, it’s because they require a lot of monitoring and compliance procedures and that relationship may not be very profitable,” Dan Stipano, partner with Davis Polk & Wardwell law firm in Washington, D.C., said during the conference’s closing panel Wednesday.

On Tuesday morning, Sam Raymond, of counsel with Gibson Dunn, and Clay Roberts, head of anti-money laundering compliance at Western Union, debated whether certain industries inherently qualify as “high risk,” or if AML personnel should focus solely on their “activities” in making such a determination.

“There’s a perception that certain industries are easier [for criminals to exploit],” said Raymond. “I’m not defending everything the current system is doing, but the reason that the system exists the way it does is in part because that’s how criminals are thinking.”

Roberts disagreed.

“I think it distracts us from really getting at the risk and where we need to go. Let’s not talk about types of institution, let’s talk about activity.”

Panelists Wednesday morning also speculated about which 15 unspecified rules the Treasury Department may scrap as promised by Treasury Secretary Scott Bessent last month.

“There are plenty of rules you could get rid of that are not going to really make much of a dent,” said Stipano. “If they start to go after the real core parts of the BSA … you could eviscerate the BSA [and] the U.S. would become the focal point for financial crime for the whole world.”

Emerging technologies

Despite regulatory assurances that everything is business as usual, “a lot has changed” with digital assets, C.J. Rinaldi, chief compliance officer at Kraken Digital Asset Exchange, said Tuesday morning.

“It’s a much more crypto and fintech friendly environment … I think this will eventually lead to regulatory clarity,” Rinaldi said, pointing to the Financial Innovation and Technology for the 21st Century Act, pending legislation known as “FIT21.”

The bill aims to define which agencies will oversee virtual assets and which regulations will apply to them.

Building an AML program while the relevant legislation still courses through Congress is akin to “building a plane while you’re flying it,” but creating a “sustainable and scalable” AML program will enable virtual asset service providers to adapt to new regulations as well as across jurisdictions, Kate Eyerman, global chief compliance officer at Blockchain.com, said Tuesday.

“At the end of the day, it’s important to remember that … compliance, regulators and lawmakers are looking at this from different angles, but with the same objective: How do we prevent our platform from being used for illicit purposes? And how do we protect our customers?”

Andy Greenberg, senior writer for Wired and author of “Tracers in the Dark,” said the takedown of the dark web marketplace AlphaBay in July 2017 marked the beginning of “open season” on online drug traffickers, human traffickers and money launderers.

After realizing the power of tracing transactions through the blockchain, investigators went “on a spree of one takedown after another,” Greenberg said in Tuesday’s keynote address. “It was too late for the subjects in these cases. They could not go back and erase the evidence … and investigators could go back in time and excavate that evidence.”

Trafficking

Chinese money laundering organizations, or CMLOs, continue to pose a threat by helping drug trafficking organizations move their money between countries almost instantly and at no cost.

“It’s really concerning for the United States when you have this unholy alliance between Chinese chemical companies and drug cartels,” Minh Nguyen, section chief of the Drug Enforcement Administration’s cyber division, said in a panel Tuesday afternoon. “What makes it truly unholy is the lack of law enforcement cooperation out of China.”

The White House under President Donald Trump has sought to tackle narcotics-related money laundering in part by requiring money services businesses in certain ZIP codes along the U.S. border with border to report cash transactions of more than $200.

Panelists on Monday afternoon said they expect the measure will soon face legal challenges.

“What are [criminals] going to do? They might drive to the next ZIP code over and just do [their illicit transaction] anyway,” said Rob DeCampos, chief compliance officer for Western Union.

Wednesday morning opened with a discussion on yet another looming challenge for compliance professionals: Monitoring for and reporting possible instances of forced labor, which is expected to surge in the runup to the 2026 World Cup soccer tournament in North America.

While financial institutions have tools to monitor transactions related to sex trafficking, detecting  forced labor presents an altogether different challenge.

“In our transaction monitoring world, we are trained to look at scenarios and rules and red flags that are very flat and based on transactions,” said Rafi Aliya Crockett, director of the financial intelligence unit at Polaris, a nonprofit focused on combating human trafficking. “In the labor trafficking world, there might not be a transaction at all.”

Economic warfare

As for sanctions policies, “the most surprising thing is how little has actually changed,” John Smith, former director of the Treasury Department’s Office of Foreign Assets Control said during a fireside chat on transatlantic sanctions and trade controls Monday afternoon.

“What is not surprising is that U.S. sanctions continue to go up all the time,” said Smith, now co-head of Morrison & Foerster’s national security practice. “OFAC, has been spared some of the changes we have seen in other parts of the administration over the last 100 days.”

The Trump administration will, however, escalate pressure on certain countries, particularly Iran, while also adding tariffs to its “national security and foreign policy toolbox,” Michael Cass-Anthony, the senior advisor and unit chief at the U.S. State Department, said, adding that banks will likely be on the hook for monitoring evasion.

“Increasingly, you will see guidance released on tariffs and what the responsibility for that is,” Cass-Anthony said.

Panelists in a special presentation on geopolitical sanctions programs Wednesday morning agreed that financial institutions should brace themselves for expanded use of restrictive tools as an economic and national security measure in the Trump administration.

“We are now in an economic hot war, but we’re going into this war without the equivalent of an economic Pentagon,” said Elaine Dezenski, former deputy and acting secretary for policy development at the Department of Homeland Security.

Kimberly Donovan, former acting associate director at FinCEN’s intelligence division, agreed.

“The industry is really on the front lines and has become the pointy end of the spear.”

And that’s a wrap.

See you in Paris.

Contact Chelsea Carrick at ccarrick@acams.org and Charlie Passut at cpassut@acams.org