In this episode of FIBA on Risk and Compliance Excellence (The F.O.R.C.E.), David Schwartz, President & CEO of FIBA, leads a compelling conversation on the global crisis of human trafficking and the critical role financial institutions can play in addressing it.

Joining him are two powerful voices:

• Rani Hong, survivor of child labor trafficking, global advocate, and co-founder of Social Detective, a new AI-driven platform designed to detect trafficking and fraud.
• John Tobon, former Assistant Director for Homeland Security Investigations and expert in financial crimes, who brings decades of frontline law enforcement experience.

Together, they examine the human and financial dimensions of trafficking—one of the fastest-growing criminal enterprises worldwide.

Key Topics Include:

• Beyond the headlines: Why forced labor represents the majority of trafficking cases—often hidden from public view.
• The financial footprint of crime: How illicit proceeds move through global financial systems, and the urgent need for vigilance by banks.
• Technology as a tool: How Social Detective uses AI to identify suspicious transactions, patterns, and red flags in real time.
• Challenges in enforcement: From secrecy and control by traffickers to limited prosecutorial support, and how collaboration can close the gap.
• Role of financial institutions: Why “every payment tells a story” and how banks can help prevent exploitation by strengthening KYC, breaking down silos, and acting on red flags.
• Looking ahead: How major global events like the World Cup and Olympics heighten risks, and why businesses and individuals alike must stay alert.

In this episode, David Schwartz, President & CEO of FIBA, leads a timely discussion on the rise of “fair access” laws and their implications for banks, regulators, and consumers. He is joined by Marina Olman-Pal, Shareholder at Greenberg Traurig, and Carl Fornaris, Partner at Winston & Strawn LLP, both leaders in financial regulatory law.

Together, they unpack the legislative trend fueled by political polarization, state activism, and public pressure—including recent developments in Florida, the Agriculture Bill, and proposed federal legislation.

Key Topics Include:

• What Florida’s fair access laws really mean—and why they’ve become a national reference point
• Complaint mechanisms and OFR’s investigative process: What banks need to document and disclose
• Why regulators are advising banks to tread carefully with ESG language in policies
• The risk of litigation in the absence of regulatory clarity
• Federal vs. state tensions: Can federal preemption apply?
• The growing importance of lobbying, legal review, and internal governance

Podcast Recap:

• Florida leads the country in enforcing fair access statutes, requiring financial institutions to justify service denials
• New legislation includes complaint processes, private rights of action, and increased transparency obligations
• Federal efforts (like the Fair Access to Banking Act) remain in bill form, but could override state laws if passed
• Banks must reassess their customer policies, document risk decisions clearly, and prepare for legal exposure
• The industry is urged to engage in advocacy and compliance planning—not just wait and see

Stay tuned for more regulatory insights in upcoming episodes.

In this episode of FIBA on Risk and Compliance Excellence (The F.O.R.C.E.), we explore the U.S. Department of Justice’s surprising pivot in cryptocurrency enforcement—and what it means for financial institutions, digital asset companies, and regulators.

Hosted by David Schwartz, President and CEO of FIBA, this episode features Richard Weber, Partner at Winston & Strawn LLP and former Chief of IRS Criminal Investigation, as they unpack the DOJ’s decision to disband its National Cryptocurrency Enforcement Team and narrow its focus to criminal abuse of digital assets.

Key Topics Include:

• What the DOJ’s memo really says—and why its language has left even legal experts unsure
• Why prosecutions tied to fraud, terrorism financing, and organized crime remain active
• The enduring risk for institutions despite “less enforcement” messaging
• How state regulators are stepping up as federal agencies scale back
• Why companies must prioritize compliance regardless of shifting political winds
• The vital role of public-private partnerships in reducing regulatory confusion

Podcast Recap:

• DOJ will no longer pursue enforcement that mimics regulation, but fraud and criminal misuse of crypto remain key targets
• The disbanding of the DOJ crypto task force may signal deprioritization—but not decriminalization
• State regulators like NY DFS and CA AG continue active enforcement
• Financial institutions must maintain strong AML/BSA frameworks, as risks persist even if crypto isn’t named
• Reducing compliance based on temporary policy shifts exposes firms to long-term legal and reputational risk
• Open dialogue between regulators, law enforcement, and the private sector is critical to address ongoing uncertainty in digital asset oversight

🎧 Thank you for joining us!

Stay tuned for more insights in upcoming episodes.