U.S. Corporate Transparency Act: Why Banks Are Wary of This New Law and You Should Be Too


TCAE is excited to invite Ross Delston, Attorney and Expert Witness, to share his insights on the U.S. Corporate Transparency Act. In this session, Ross will cover basics of the Corporate Transparency Act, discuss access to the new registry, and why criminals the world over are gleeful about the new law.

The main areas of discussion will be what happens when you offer in scope and out of scope services and the issues of explaining that to clients, and then some of the areas where safeguarding and reconciliation caused issues.

Learning outcome

  • Who are the five types of financial institutions that have access to the registry?
  • How can those FIs get access and what are the preconditions to that access?
  • What types of companies are required to report their ownership and which do not?
  • Why ownership information in the new registry is treated like PII – personally identifiable information – and why the implications are far-reaching in terms of penalties?


Ross Delston | CAMS, Attorney + Expert Witness

Ross Delston is an independent American attorney, expert witness, and former U.S. banking regulator (FDIC) who has specialized in AML/CFT issues for over 20 years. Ross has participated in the monitorships of AIG and BNP Paribas, and has been a consultant to the IMF on AML/CFT and banking matters since 1997. On behalf of the IMF, he has participated in nine AML/CFT assessments of offshore financial centers, including Jersey, Bermuda, and St. Vincent. Ross has also been an expert witness on AML issues in 15 cases, including on behalf of plaintiffs in Joint Liquidators of Stanford International Bank. v. Toronto-Dominion Bank, a Canadian civil action growing out of one of the largest Ponzi schemes in recent history.

Ross has drafted trade finance policies and procedures to address TBML risks for a multinational bank and conducted training on the new procedures. He has also co-authored two law review articles on TBML: “Strengthening Our Security: A New International Standard on TBML is Needed Now” (2012) and “Reaching Beyond Banks: How to Target TBML and Terrorist Financing Outside the Financial Sector” (2009). Ross started his career as an attorney at the U.S. Export-Import Bank where he drafted and negotiated trade finance deals.

Ross has been quoted on AML/CFT and banking issues in the New York Times, Washington Post, Wall Street Journal, New Yorker, the American Banker, Bloomberg, ICIJ, OCCRP, the Times of London, the Nikkei (Japan) and the Hindu Business Line (India). He has lectured and conducted training on AML/CFT and TBML topics at the U.S. Financial Crimes Enforcement Network (FinCEN); the People’s Bank of China (central bank) twice; the Reserve Bank of India’s Staff College in Chennai; for U.S. bank examiners at the 2016 FFIEC Advanced BSA/AML Specialists Conference; and at conferences and seminars throughout the world.


Abdullah Alawi | Financial Crime Investigator 

Abdullah has 20 years of experience in banking treasury, diplomacy, investment advisory, and financial crime investigations. He worked for multiple private and public institutions in the Middle East and Canada. He enjoys the world of financial crime investigations, and loves to help others in their learning journeys. Abdullah holds a PGD in Financial Strategy, MSc. in Banking and Finance, BSc. In Economics, and is Certified Anti-Money Laundering Specialist (CAMS), and Certified Financial Crime Specialist (CFCS).