Enforcement Trends, Gaming, Crypto — and More

I am very pleased to co-chair again the Practicing Law Institute’s 2024 Anti-Money Laundering Conference on May 23, 2024, starting at 9 a.m. in New York City (the event also will be virtual). 

I am also really fortunate to be working with my fabulous co-chair Elizabeth (Liz) Boison, a partner at Hogan Lovells.

We have another fantastic line-up of experienced and knowledgeable panelists:

• Alma M. Angotti, Guidehouse, Partner, Financial Crime, Fraud, and Investigative Services
• Michael Grady, U.S. Department of Justice, MLARS, Chief, Bank Integrity Unit
• Carole House, Terranet Ventures, Inc., Executive in Residence
• Kevin Mosley, U.S. Department of Justice, MLARS, Deputy Chief, Bank Integrity Unit
• Ron Schmidt, Internal Revenue Service, BSA Group Manager
• Christopher Soriano, Penn National Gaming, VP, Chief Compliance Officer

The conference will tackle critical issues in BSA/AML/OFAC compliance and money laundering enforcement.  The three panels will be:

1.         Recent Trends in Money Laundering and Enforcement

The Department of Justice continues to bring major money laundering indictments and civil forfeiture actions.  The panel will discuss:

• Enforcement actions against individuals: key cases and emerging trends.
• Enforcement actions against organizations: key cases and emerging trends.
• The implications for U.S. financial institutions and their AML programs, including risks and the red flags for potentially problematic customers and business lines.

2.         The Gaming Industry: Unique AML Challenges and Emerging Issues

The unique services and products offered by the gaming industry present unique AML issues and risks. Further, the dramatic growth in online wagering has created particular challenges, as the volume of transactions and customers increase and bad actors develop more advanced and complicated measures to circumvent existing AML controls.

Topics discussed by the panel will include:

• What does it mean in today’s environment for a casino to have an effective, risk-based BSA/AML program? 
• The IRS examines gaming institutions for BSA/AML compliance. What do examiners want to see, and how should institutions prepare? 
• Online gaming presents emerging AML and money laundering risks. What controls are appropriate, and how should the relationships between casinos and online gaming providers best be managed? 
• How could the current BSA/AML regulatory and enforcement regime be improved in regards to the gaming industry? 

3.         Anti-Money Laundering: Blockchain, Cryptocurrency, and Digital Assets

One of blockchain’s most compelling and adopted use cases is to make the cross-border movement of money faster, cheaper, and decentralized. The panel will discuss:

• The (near) future of crypto: what is the likely regulatory, law enforcement, and case law landscape going forward?
• What do regulators expect a recipient to know about the source of digital asset funds? (Travel rule, mixers/tumblers, hosted vs. unhosted wallets and FinCEN’s special measures requiring reporting on mixers);
• Transaction tracing and investigations of illicit crypto schemes: illicit funds, hacking, ransomware, and more. What are financial institutions’ responsibilities to monitor and trace crypto transactions, identify wrongdoers, and, potentially re-screen transactions once new attributions have been made?

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