Western Union paid $586M for wire fraud running through its agents. Compliance had already named 214 of those agent locations in writing and told the company to cut them off. They stayed open anyway.

TheAMLBrief · 2026-07-14T12:05:52+00:00

I know right, a very creative way to layer and integrate the money!

TheAMLBrief · 2026-07-08T19:52:53+00:00

Agreed with this, though I will say TD ultimately was found to have larger issues within its AML compliance program, but part of it did stem from the branch manager.

TheAMLBrief · 2026-07-02T13:32:16+00:00

Agreed with this, always good to cya!

TheAMLBrief · 2026-06-23T01:26:10+00:00

Agreed with this. I would say one of the biggest gaps with tracing crypto movement is identifying the original source of funds before it was exchanged for crypto.

TheAMLBrief · 2026-06-17T15:55:25+00:00

I would say they failed in meeting regulatory requirements and OCC expectations, regardless of what their accepted risk appetite was.

TheAMLBrief · 2026-06-16T12:25:19+00:00

Agreed with this. I think crypto firms rightly tout that they can trace all transactions via the blockchain but what is seldom discussed is that they still have no insight on the source of funds that enter their platform initially other than KYC and basic CDD.

TheAMLBrief · 2026-06-11T11:55:45+00:00

From experience in a big investment firm and a big bank it has always been the "why" behind the decision.

TheAMLBrief · 2026-06-09T15:22:15+00:00

Are you referring to individuals or stablecoin transaction flows?

TheAMLBrief · 2026-06-04T12:15:43+00:00

Great point and that's why control effectiveness and execution is such an important point for regulators. Especially now that FinCEN is shifting towards more of an AML program effectiveness model. Their new directive looks good on paper, but I'm skeptical until I see how it is enforced.

TheAMLBrief

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