points in suspicious activity reports ( SARs ) are structuring transactions , and those are important to LE . Perhaps if banks and others file a quick SAR versus extensive narratives , LE could get this information quickly . So , let ’ s focus on the important areas where you need descriptions and narratives and let ’ s automate some of the other reports . This will usher in more innovation for the industry .
AT : What recommendations would you give to AFC professionals on how to combat financial crime more effectively ?
JB : Be curious and pay attention to current events because that often dictates potential laws and regulations and what the regulators or LE believe is important . There are many ways to stay on top of things domestically and internationally . Make sure people internally ( where you work ), understand what you ’ re doing because everybody has a role . So , if I ’ m an AML professional , I ’ m not going to work in a silo ; I ’ m going to explain to the frontline staff why we ’ re doing what we do . Business lines need to understand that strong compliance equals strong business and it ’ s not a negative . Many people in the business line think of compliance as simply a cost center , but it ’ s a cost-saving center . Be curious , pay attention and get out of your silos .
AT : How can FIs best incorporate artificial intelligence ( AI ) to combat financial crime ?
JB : First , you must get smart people to understand the mission . We have AI experts . I ’ m certainly not one , but I think that you need to understand that while AI can be used in a useful way , it can also be harmful . I would like to see ( and I ’ m sure this is already happening ) the government put together a group of experts , both on the LE side and the technology side , who will figure out how to continue to get good information . A concern that I have heard in the industry is how do we allow institutions to experiment with AI without criticizing them for regulatory problems during that process ? I ’ ve talked with many bankers who have said that they are happy to change their technology , but while they do it , they want the possibility of not being criticized by regulating agencies if they miss something . To implement new technology , you need to be able to make mistakes . Perhaps some pilot programs are the best way to do this .
AT : Having achieved a successful career , what would you like to accomplish in the next five years ?
JB : I ’ ve been fortunate to be teaching a class at George Mason University Schar School of Public Policy on money laundering , terrorism and corruption for the past five years . That ’ s eye-opening because graduate students are interested in this space . They produced a great deal of quality content , which we ’ ve been able to post on our websites and LinkedIn . I want to continue teaching and encourage the next generation to be involved in the AML industry .
Another career milestone that I will continue with as long as I keep working is the AML Partnership Forum , which we created in the past two years and are doing again in March 2024 . We patterned the Forum after the West Coast AML Forum , which has been going strong for 30 years . The Forum gets LE personnel , private sector professionals and regulators together in a closed-door setting . There ’ s no press or exhibit hall and it ’ s designed to be an exchange of information . Attendance is capped at 180-200 participants to guarantee excellent dialogue and exchange of ideas . That ’ s what we ’ ve been able to do here in D . C . and I want to keep doing that for as long as I can . We made it a self-sustaining 501 ( c )( 3 ) organization . It ’ s run by private sector people , the Department of Homeland Security , the Internal Revenue Services- Criminal Investigation and the Federal Bureau of Investigation , so it is a perfect public-private partnership event .
In addition , I ’ ve now done around 500 or 600 podcasts over the past five or six years . I ’ ve visited and interviewed investigative journalists , regulators , people in AI , financial technology ( fintech ), the sanctions space and other experts ― and it ’ s all connected to national security and financial crimes . So , I would like to continue interviewing interesting individuals .
AT : What is the most important lesson you learned while working in the AFC industry ?
JB : Everybody ’ s committed . It ’ s a three-legged stool : LE , the private sector and the regulators . Nobody is doing things they don ’ t believe in , which is important to know and refreshing . I ’ m as cynical as the next person , but then you look at what the community has been able to accomplish .
This is now a career path ― it didn ’ t used to be ― which is excellent . My daughter Rachele is in this space and I couldn ’ t be prouder . I want to see the next generation after her get involved . All in all , what we do matters . What you do matters . Hopefully , what I do matters . The biggest thing I ’ ve learned : This isn ’ t a “ check-the-box ” industry or community . This is an industry that gets things done .
Interviewed by : Karla Monterrosa- Yancey , CAMS , editor-in-chief , ACAMS , editor @ acams . org , ACAMS Today | December 2023 – February 2024 49