A fincrime compliance journey and message to honor the fighters, the first responders, the fallen and all those who still bear the physical and emotional scars from 9/11

The Skinny:

  • In this piece, ACFCS VP of Content, Brian Monroe talks about what the 20-year anniversary of 9/11 means to him, from working as a reporter at a newspaper in Melbourne, Fl., to later learning from and teaching and training the fincime compliance fighters of tomorrow.
  • The attacks also shaped his career, as the 2001 U.S.A. Patriot Act ended up fueling stronger anti-money laundering (AML) rules, just as it worked to better uncover the nuanced financial trails of terror groups, which in many cases have funding sources from legal means used for horrific ends. The bookend of this is the recently-passed Anti-Money Laundering Act – the most significant update in 20 years.
  • After the birth of his daughter, Elyse Renee Monroe, on April 22, 2021 – one day before his birthday – Monroe reflects on the pain of so many mothers, fathers, sons and daughters, siblings and relatives and the brotherhood and sisterhood of firefighters and first responders who made the ultimate sacrifice, shared grief still felt to this day.  

By Brian Monroe
bmonroe@acfcs.org
September 11, 2021 

In moments like this, even as a journalist with more than 20 years of experience and making my living as a weaver of words, I feel unable to express my sadness, my sorrow and the still raw emotions I feel on this solemn day.

A day that saw a country wounded, but revealed a spirit that would never be broken.

As I write this, sitting alone in my home with my four-month-old daughter cooing and giggling in her crib, I am crying. She is my first child and at 46, I consider her a blessing beyond all measure.

The attacks also shaped my career, as the 2001 U.S.A. Patriot Act ended up fueling stronger anti-money laundering (AML) rules, just as it worked to better uncover the nuanced financial trails of terror groups, which in many cases have funding sources from legal means used for horrific ends.

After the birth of my daughter, Elyse Renee Monroe, on April 22, 2021 – one day before my birthday – I also shudder at the pain and loss of so many mothers, fathers, sons and daughters, siblings and relatives and the brotherhood and sisterhood of firefighters and first responders who made the ultimate sacrifice, emotional pain still felt to this day.  

As I imagine that day, where terrorists used a twisted ideology to justify mass murder, my tears flow more, knowing I would be crushed past all understanding if someone took my beautiful smiling snuggler Elyse away from me. 

Having a daughter now myself, and wanting to protect her from anything that would steal her smile, even if just for a moment, that is unimaginable grief. 

I also further understand the pain of losing a mother and father.

My father, James, passed away more than a decade ago after a battle with lung cancer, but my amazing mother, Susan Margaret Monroe – a sweet, kind, caring person who sacrificed so much over the years for my brother and I – passed away in January of this year after heroically battling a host of medical issues.

Even with the challenges my mother had, she finally relented – my mom was legendarily stubborn – and let herself be checked in to a hospital, chiefly due to challenges of pain related to prior neck and back surgeries.

My mom had stabilized and was even medically cleared for a major back surgery, that, at 74, was supposed to finally allow her to live a pain-free retirement. So it was shocking to everyone she passed away just days later.

Less than a week after my mom had passed, I learned that my adorable, 10-year-old miniature schnauzer, Khloe, had terminal cancer. She was the smartest, most affectionate, loving, best dog in the whole wide world. 

Khloe was my wife’s first pet and formed a bond with our family that made us imagine how we ever lived without her. 

She filled a hole in our hearts we didn’t even know we had. Khloe knew the names of 20 or 30 of her toys and, for a treat, would even pick them up and put them away. 

She also loved children and I had already begun imagining her snuggling and playing with my daughter. 

We did everything we could to fight it and didn’t leave her alone, not even for a second. My wife and I rearranged everything so someone was at her side at all times. 

Khloe lived one more week after her diagnosis, and in that short time, barely wanting to eat, she still played with her toys, chased ducks in the back yard and howled when someone got home from work. An irrepressible spirit. 

As my brother and his family visited to help me grieve and get my mom’s affairs in order, Khloe passed away in my mom’s house, in me and my wife’s arms, loved until the very end.

So for me, this 9/11, potentially more so than any other, is more painful and poignant as I imagine the grief of the families on that terrible day who lost the ones who meant the most to them – as I still face a darkness and feeling of emptiness not being able to hear my mom’s voice or smell my puppy’s Dorito paws when she rolls on her back at the joy of life.   

Flurry of fear on the day of the attack: where would the next one come?

Two decades ago, I was a daily journalist in Melbourne, Fl., at a newspaper called Florida Today, part of the same chain as U.S.A Today.

When I arrived shortly after 9 a.m., the newsroom was buzzing with the energy of a hornet’s nest. I had never seen everyone so frenzied. Then I found out why and I couldn’t believe what I was hearing, and then what I was seeing.

The World Trade Center was on fire after a plane had hit it.

At first, editors and reporters were speculating, was it due to an accident and a plane that was out of control? 

Then the second plane hit and the worst fears of everyone – that no one wanted to speak aloud – came true: it was a deliberate terrorist attack.

Then more news trickled in of the attack on the Pentagon and another plane crashing in a field in Pennsylvania, that was reportedly headed to the White House or Capitol.

No one knew how many more attacks would come and from where. Was this a coordinated attack in other major cities, national landmarks, high-profile government and public sites or military installations?

Then, all of a sudden, the barking of editors, and rushing of reporters stopped. Everyone watched, in horror and stunned silence, the towers implode, crumble and collapse.

The hope that many could be saved – with the bravery and will of New York’s finest – faded as the news broadcasters switched from talking about the efforts to locate and evacuate civilians to the soul-crushing reality that the hundreds of firefighters, police and first responders fighting against impossible odds likely didn’t survive.

As editors tried to chart out the stories that needed to be covered – national and domestically in central Florida – my mind raced to what could be local targets of opportunity.

My first thought: what about Patrick Air Force Base? What about Kennedy Space Center, one of the nation’s top gateways to the stars?

My editor agreed with me and said go to Patrick to see how they were responding and if the base had any insight or intel they were willing to share on local vulnerabilities. I went with a photographer and the changes that would become commonplace for years were already in process.

The base, now called Patrick Space Force Base, is a United States Space Force installation located between Satellite Beach and Cocoa Beach, in Brevard County, Florida, on the picturesque A1A, surrounded by water on the East Coast.

Base staff had already started putting up blast barriers and started restricting traffic to prevent a possible car or truck bomb-based attack. Heavy equipment continued fortifying entrances, with the main gate starting to resemble a mini-fortress.

The soldiers on duty were tight-lipped, not wanting their attention to be distracted by a reporter.

But the PR person gave an update, noting that the base had switched to a heightened state of readiness and would remain so until they got a better sense of if the terror attacks were focused on New York and Washington – or any city was at risk.

I was finally able to get enough for my story and, even after all my deadlines had passed, I just couldn’t relax. Everyone was a potential enemy and anything odd or out of the ordinary could be a harbinger of an attack to come.

Follow the white rabbit or when is a truck not a truck, but a weapon?

Fear. Something that would grip many hearts that day – and for weeks and months to come – also made me wary.

I remember as I was leaving the newsroom, I saw a beat up white delivery truck with no company name on the side, seeming to amble up and down the street in front of the building.

I knew that terror attacks could come from bombs being held in large trucks. The truck almost seemed to be looking for groups of congregated people as it slowed near various restaurants and population centers around town.

Not knowing its final destination or intentions, I decided to follow it. The truck continued on its meandering, plodding path for another 30 minutes or so.

I tried to see if the driver looked out of the ordinary, from out of town perhaps, but couldn’t see the inside of the cab due to tinted windows. I was about to dial 9-11 as the truck finally turned away from the busy areas of the city of Melbourne and went toward the highway.

I finally stopped following it once it was out of my county and into the next. Like many others, that fear would persist with a sense that the core of security in our borders had been torn asunder.

The terror attacks on 9/11 were for many, in and out of New York, the darkest time in our nation’s history that shattered the perception we were safe here at home. But we did not, as a country, as warriors as a light of freedom, justice and the rule of law, give in to fear.

We found those who did this and hunted them, taking the fight to them and any who would give them shelter.

What I didn’t realize at the time is my career would later be directly affected by those attacks and the stronger fincrime compliance regulations that followed. 

From covering cops and courts locally to the laws to find and fight illicit finance

After working as a reporter at Florida Today for five years, until 2006 – covering a bevy of beats, from the city desk to cops and courts, city government to high-tech, defense and stocks and bonds – I was able to move back down to where I grew up, in Miami, in South Florida, and also to be closer to the girl I was dating who lived 2-1/2 hours away, taking a reporter position at ACAMS/Moneylaundering.com.

In those eight years, until 2014, I saw firsthand how anti-money laundering (AML) laws, and failures to follow them, led to banks – in some cases accidentally, in others more deliberately – laundering funds tied to organized criminal groups, corrupt oligarchs, sanctions evaders and terror financiers.

In some cases, those killed or wounded in terror attacks and their surviving relatives, sued large banking groups for their alleged support of terror attacks or sending funds from terror groups to the families of suicide bombers.

In that time, I saw a nascent field of AML become a multi-billion dollar sector, with technology companies creating advanced systems to detect aberrant transactions and alert human analysts, who themselves had to engage in deep and detailed training to understand the red flags of illicit groups across the spectrum of financial crime.

Since 2014, I have been lucky enough to work at #ACFCS and be able to work with law enforcement, terror warfighters, regulators and fincrime compliance professionals who are all allies in this shared mission, to counter illicit finance in all its forms, including terror groups and their shadowy backers.

Over the last two decades, the fincrime compliance sector has engaged in a historic, tectonic shift, spearheaded by global watchdog body, the Financial Action Task Force (FATF), to focus more on effectiveness, than technical compliance.

Think switching from getting credit for having laws on the books to the results of those laws arming law enforcement, with metrics of success tied to large, complex international cases investigated and top leaders prosecuted with hefty prison sentences and assets forfeited.

This year In the United States, for instance, the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) also shifted domestic fincrime compliance defenses to be more “effective” and create valuable intelligence for law enforcement through the Anti-Money Laundering Act (AMLA).

The AMLA is an expansive package of updates to break open beneficial ownership bastions, bolster public-private information sharing, usher in a new era of innovation and focus on effectiveness – with the threat of higher penalties for violations, and serial scofflaws.

To read ACFCS coverage of the AML Act, which Congress enacted into law in January after overriding a presidential veto, click here.  

To help entities subject to AML rules, FinCEN released a formal list of its national AML/CFT priorities, a collection of historic foils like organized criminal groups and other rising risks, like record ransomware attacks and crypto-fueled paydays.

The widely-watched and highly anticipated AML priorities are the first concrete update to implement the AML Act – the most significant upgrade to the country’s fincrime framework since the 2001 U.S.A. Patriot Act.

What does an ‘effective’ fincrime compliance program look like?

At the same time, as the U.S. shifts its fincrime fighting regimes to focus on effectiveness, one international group has finally detailed what that could and should actually mean in terms of concrete metrics.

In short, the Wolfsberg Group in a recent release detailed metrics of effectiveness including:

  • Are you compliant with local AML laws, cognizant of global standards?
  • Are you producing highly useful information to law enforcement, guided by national AML priorities?
  • Do you have a reasonable compliance program that reviews internal and external threats, gaps and vulnerabilities and adjusts based on rising or receding risks and law enforcement input?

For me, personally, this is one of the most exciting times to be in the field of fincrime compliance as the future has yet to be written.

All the old standards, such as “follow the rules and fear the regulators, and we will help you follow the rules,” have been uprooted.

The industry – as a whole – is catching up and validating the mission of ACFCS, a goal the association has championed since our inception.

And it is this: to teach, train and tackle financial crime in its totality, to support a convergent, holistic and enterprisewide approach to empower teams at all levels of the bank to think for themselves – in and out of dedicated compliance roles.

That philosophy buttresses efforts by technology titans using artificial intelligence, automation and machine learning to better capture, harness and wield data to better parse out potential instances of not just money laundering, but specific crimes, like human trafficking, cyber-enabled frauds and grand corruption. 

Strength and honor, tears and tenacity, tragedy, but ultimately, triumph

In all, even as the fincrime compliance sector matures, to hopefully better support federal investigators – and those gathering intelligence on terror networks – all players in this grand game remember to never lose sight of the goal: to never let another 9/11 happen again.

To all those who lost their lives on 9/11, I honor your sacrifice with my thanks, and my tears.

To your families, I salute your strength and resilience. To the first responders who gave everything, I salute your courage and to your brothers and sisters, I thank you for your tenacity, grit and determination.

To those who fought and died in Iraq, Afghanistan and other clandestine operations protecting our freedom, I thank you and I honor you for making the ultimate sacrifice.

Your efforts have not been in vain. You are the sword and the shield who have protected me, my daughter, my family, my friends, and that is a debt I can never truly repay.

The best I can do is try to lead a good life, being kind and trying to learn and share all that I can to arm the next generation of financial crime fighters with the knowledge and skills to better counter all the threat actors who seek to enrich their networks with tainted funding and, worst of all, those who seek to do us harm.

I also remember the day after 9/11. Where a country came together, putting political, racial, socio-economic and all other divisions aside. We were all Patriots that day. We found and flew our flags high, with pride.

We tried to help in any little way we could, giving blood, volunteering, looking to support and give to help our neighbors and show more kindness, compassion and empathy to each other – realizing that, whether we showed it or not, we were all hurting inside and fighting a hard battle.

To everyone in this fight, past, present and future, thank you for all that you do and thank you to all those who gave it all. On this day, we remember you. We honor you. We haven’t forgotten you. And we will never forget.