This is a transcript of the podcast LSEG’s Anna Rosenberg contemplates the regulatory road ahead, which features her in conversation with GRIP’s US Content Manager Julie DiMauro.
[INTRO]
Julie DiMauro: Greetings everyone, and welcome to a Global Relay Intelligence and Practice, or GRIP, podcast. I am Julie DiMauro, the US Content Manager for GRIP, talking to you from New York City.
GRIP is a service that features a daily website of articles on a variety of compliance and regulatory topics, plus podcasts and other deep dives into compliance trends and best practices.
You can find the service at grip.globalrelay.com, and we hope you’ll connect with GRIP on LinkedIn. I’m so pleased to announce that today’s podcast session features Anna Rosenberg, Senior Manager for Government Relations at London Stock Exchange Group in New York. I’m going to ask Anna to please introduce herself and describe her background before we kick off the program.
Over to you, Anna.
Anna Rosenberg: Thanks, Julie, and thanks again for having me on the podcast. It’s certainly an exciting and perhaps unprecedented time in US politics, so I am excited to dive into that. I work for the London Stock Exchange Group’s Government Relations team, and I primarily work on policy issues related to our risk intelligence business.
This part of our business really focuses on AML, KYC compliance. Because of that, I handle data privacy, AML, KYC policy issues, and I also handle digital assets throughout LSEG. I guess what does that mean? It sounds like maybe not a lot of lobbyists have frequented this podcast, but I meet with federal policymakers and regulators and really try to advance LSEG policy priorities. And then also, I help our company see around the corner on legislation or regulation that may be coming down the pike.
Maybe just a little bit of background about myself. Before LSEG, I worked at FTI Consulting in their public affairs practice, and while I was there, I helped set up their FinTech and digital assets practice. I worked at TransUnion on their government relations team, and then I also did some public sector work, both for the Commodity Futures Trading Commission, which is a derivatives regulator, and then also for the US House of Representatives on their financial services committee.
So overall, my career has really been centered around financial services and public policy and the intersection of the two. So again, really looking forward to the discussion and hopefully maybe demystify some of the things that are going on for the viewers.
Julie DiMauro: Terrific. Anna, thank you. Let’s dig in. Before we even get into the real weeds of things, can you set the scene for us in the financial service sector, the perspective that you might have in terms of the regulatory and legislative developments that you’re tracking right now?
Anna Rosenberg: Yeah, absolutely. Obviously, President Trump has hit the ground running to deliver some of his campaign promises early in his second term. I think there have been a lot of actions, at least from my perspective, that have been predictable, just given the general theme around America First and deregulation that we keep hearing about, and then other actions that definitely have even caught me by surprise. I’m in the weeds on these things, so that should say a lot. I think if we went through all of his executive orders and what they mean, we’re going to be here until tomorrow.
So I think I’m just going to keep this answer relatively high level and maybe thematic. What I will say is there is this really interesting dynamic at play where we have a Republican trifecta, but there are very tight margins in both the Senate and the House. I mention this because in the Senate, you need 60 votes to pass all major legislation. There are caveats to this, but most legislation that I think your viewers care about, things like data privacy, big anti-money laundering reforms, digital assets, things like that, they still require bipartisan consensus because they’re going to need to reach across the aisle and find seven Democrats to vote for it in the Senate.
I think purely from a legislative perspective, unless there is a major crisis, it’s going to be really hard to pass legislation, maybe with the exception of crypto, which we’re going to talk about, I know, later. But tight margins will also mean that Trump is really going to stretch his executive authority, which we’ve already seen, and then really heavily rely on the regulators to ensure he’s making progress on some of his policy priorities, which by the way, it’s not necessarily uncommon whenever there’s a new administration.
I think we’re seeing two themes emerge. Deregulation and the approach President Trump is taking on financial crime, but through the prism of America First.
I know I’ve already mentioned deregulation in America First before, but there’s this interconnectedness between the two, particularly as we are focusing on things like financial crime. I know we’re going to get into specifics a bit later, but I do think that Trump is certainly going to be bolder on his deregulatory agenda than he was his first term. I also think certainly he’s going to be less bold than his predecessor on enforcement action, or at least I think enforcement action is going to be really targeted and really strategic.
On the deregulatory front, we’ve already seen moves towards deregulation. He’s fired and he’s replaced heads of regulatory agencies. Again, this is common, but he’s also reversed or threatened to reverse or halted or really taken the teeth out, so to speak, on existing regulation, and really regardless of statutory authority. It’s not like I think all of Trump’s goal is going to just purely be, “Let’s roll back Biden era regulations and call it a day.” I do think we’re going to see some big proactive pushes, yes, of course, on things like digital assets and AI, but also things that are a little bit more nuanced.
One example here is something like de-banking. This has really emerged actually as a big priority for the administration. Perhaps for folks who are not super in the weeds on what this is, this is an idea that people’s politics or line of work, it’s being weaponized by banks. The banks are closing down bank accounts and they’re being shut down, or people are not receiving bank loans.
That’s an area that’s emerged. We’re seeing legislation going through the Senate Banking Committee right now that’s focusing on de-banking. Another proactive area that I think we’re going to see a big push on is around tackling traditional forms of fraud. Things like government fraud, romance scams, things like that. I think DOGE is already starting their work there. I know we’re going to talk about it later, but I do think a shift, maybe less on crypto fraud and more on traditional forms of fraud.
I guess just to close, I think there’s certainly going to be a massive shift from President Biden. We’re already seeing this and this is expected. Like I mentioned before, while we may see less success going through, from a legislative perspective going through Congress, I really think the action is going to be on the agency level. Those compliance folks that are tuning in, I would really make sure to stay plugged in there.
Julie DiMauro: Anna, that was very helpful. In addition to stopping what his administration has seen, and Republicans in general have interpreted as regulation through enforcement, you bring up the deregulatory agenda. There also is this expansive concept of executive power going on.
Anna Rosenberg: Yeah. Yeah, absolutely.
Julie DiMauro: That is playing out in terms of the firings and going after law firms. There’s just a lot of that. To your point about needing bipartisan support in Congress, what’s interesting is a lot is winding up in the judiciary and Republican judges are not necessarily siding with him.
Anna Rosenberg: Right. We’re seeing that, even the news this week. Exactly.
Julie DiMauro: Now, let’s dig into a few of these topic areas. There’s a lot of enthusiasm around the near future of digital assets. What can we expect from the administrative agencies and from this Congress?
Anna Rosenberg: Yeah, that’s certainly a hot topic. Just over two months into President Trump’s new term, we’re already witnessing a shift of how federal regulators are approaching the crypto industry. The SEC has already dropped some of their high-profile lawsuits against companies like Coinbase. We’re really seeing them loosening the grip on other major firms, so companies like Robinhood and Gemini, which have been all over the news.
To your point, I do think digital assets is an area where we’re going to see both a proactive legislative push in Congress to set these clear, light touch rules of the road for the crypto market. Then simultaneously, we’re going to see regulators again focus on deregulation and scaling back progress that was made during the Biden administration. Not to mention, like you said, Chairman Gensler, he was notorious for his regulation-by-enforcement approach. I think at least that aspect is certainly going to change. We’re going to see a lot less of that.
I know I keep saying deregulation, America First, but this is an area, crypto at least, is an area that I think is definitely motivated by both. President Trump wants to ensure that he keeps innovation in the US by providing these guard rails or clear rules of the road, but he doesn’t want to do so to necessarily overburden businesses.
We have seen some pretty big steps in the administration and Congress just to make sure that they’re delivering on that campaign promise. Within the first week, we saw President Trump issue an executive order basically with the intent to support growth in the US in the crypto industry, which really signals again this intention that Trump wants to ensure that crypto stays in the US. At some point, he’s even said in one of his speeches, he wants US to be the crypto capital of the planet. That just goes to show the overwhelming amount of support there is from the administration.
On the regulatory side of things, we saw the SEC announced a crypto task force. The mission of this is very clear. It’s to create rules of the road for the crypto industry. On the legislative side of things, we saw a stablecoin bill advanced through the Senate Banking Committee, which basically regulates US stable coin issuers at a federal level. We saw Trump issue an executive order also to establish an official government cryptocurrency reserve in the US. The idea here is this fund is going to be stocked with coins that are basically forfeited to the federal government as part of criminal or civil proceedings.
We’ve already seen legislative proposals that are meant to help implement this executive order.
I don’t mean to regurgitate what I’m sure listeners are hearing on the news, but just to say there is a huge push and honestly, a bipartisan push to move some of these proposals forward. I think just speaking to folks in the industry, I think we are seeing this new sense of optimism that’s sweeping through the crypto world. In terms of what I expect coming down the pike in Congress, there’s a stablecoin bill that’s advancing through the Senate right now. I know there were concerns from the Democrats basically worried about lack of consumer protections and maybe the anti-money-laundering safeguards didn’t go far enough. But to be honest, if I was a betting person, this is one I think may actually get enacted into law this Congress. There were even a few Democrats on the Senate making committee that voted for it.
Funny enough, I’m actually less concerned about Democrats not voting for it than more curious of how the Senate is going to reconcile their approach towards stablecoin with what the House is trying to achieve as well. If there were any hurdles, I actually think it would be more from that perspective.
And then up next, we’re going to see probably an introduction of a comprehensive market structure bill move. And really what this means is it just defines when a crypto is a security, when it’s a commodity, really with the intent of clarifying the roles of the SEC and the CFTC. What I’m watching here is I think it’s going to be interesting to see whether FIT21, which you may know, but this was that market structure bill that advanced out of the House last Congress.
I’m going to be curious to see whether or not that’s going to be the framework for which members of Congress work off, or are they just going to start from scratch? Because there’s definitely different political calculus now. Again, it needs to be bipartisan. So it’s going to be interesting to see how far Republicans go to throw in some provisions in there to ensure that their colleagues on the other side of the aisle stay on board. But yeah, I think that’s something that I also feel relatively confident that we can get accomplished this year. But definitely stablecoins, 60% market structure bill is how I would weigh its chances – what my opinion is.
And I think what is a little bit less clear on the digital asset side is how Congress and regulators are going to approach tokenization of traditional or what they call real world assets and whether … are they going to try to tack that on to the larger market structure bill? Is that going to be a separate effort? Because we’re seeing kind of trad-fi really kind of explore this area.
And I’m sure they could also benefit from some kind of rules of the road in that space as well. And then maybe to tie this back into this financial prime general conversation, what I’m tracking is, where does AML fit into all of this? What will AML look like to ensure that markets are working as intended, but they’re also protecting consumers? Are they kind of going to carry over existing Bank Secrecy Act obligations that financial institutions need to comply with for just consistency purposes?
We saw this kind of in the stablecoin bill. Or is this going to be something completely different? I know that was a lot, but it’s a very active space and one that I certainly am very excited about just purely from seeing Congress be able to find kind of bipartisan consensus and push something forward that is kind of a big priority for the administration.
Julie DiMauro: Absolutely. And what I think has been very interesting is general acceptance and enthusiasm from the public. I mean, the spot bitcoin and ether ETFs did well. There’s just been a lot of enthusiasm. And there’s some promise to the technology that underlies digital assets to using blockchain in innovative ways that maybe will be enhanced with this new approach.
Anna Rosenberg: Yeah, absolutely.
Julie DiMauro: Terrific. Now, I want to talk about the DOJ. And we’ve been talking about financial crime and weaving that through. So I want to pick up on that. One of the first actions was to direct an enforcement shift for the Foreign Corrupt Practices Act, the FCPA. We saw President Trump issue an executive order. Basically halting enforcement altogether. Can you talk about this and what are some of the potential ramifications if the FCPA enforcement activity and direction were to truly change and go away?
Anna Rosenberg: Yeah. So maybe a little bit more color and maybe background of kind of where we currently are with FCPA, just in case listeners aren’t too familiar. So in February, Trump signed this executive order that basically directs the DOJ to pause enforcement of the FCPA. And for those who are not familiar with the FCPA, this is basically a law that prohibits companies and individuals from kind of offering or paying bribes to obtain or retain, I guess, business. And part of the reason that Trump is focused in this area, again, ties back to kind of this America First theme.
Trump believes that US companies are, you know, are harmed by the FCPA kind of over enforcement because, you know, they’re prohibited from engaging and what he views as kind of common practices among international kind of competitors. And, you know, in his speech, he really basically says, you know, in his opinion, you know, immediately, as soon as folks go abroad to do business, an investigation immediately opens, which creates this unequal playing field.
Not to debunk that, but what I think is interesting is like I saw a stat somewhere that says FCPA enforcement has actually historically been focused on foreign companies and not vice versa. So again, like do with that information, as you will. But it is interesting, right? Like this is like has become a big priority for the administration. But anyways, you know, the pause is intended only until kind of new enforcement guidelines are published.
So again, you know, just to reiterate, this is a temporary pause, right? This is no way eliminates FCPA enforcement across the board. What I find interesting is that the executive order was issued after the DOJ issued a memo that basically outlines their enforcement priorities for the FCPA. And one of these kind of enforcement priorities is that, you know, the DOJ is going to kind of shift their enforcement priority to focus more on kind of foreign bribery investigations that have ties specifically to drug cartels and transnational criminal organizations and kind of shift away from more kind of traditional FCPA enforcement.
So if I were to guess, you know, I think this DOJ memo is going to serve really as kind of a blueprint for what these new upcoming enforcement guidelines are going to look like. I think for folks who are concerned about FCPA and kind of the direction of travel there, I would direct you to take a look at it’s called like the DOJ “Total Elimination” memo that Pam Bondi released last month, because again, that’s going to give you kind of a clear indication in terms of where the guidelines are going to fall.
You asked about ramifications. My response to you is maybe don’t immediately panic. Right. And I say this for a few reasons. First, you know, as I said before, neither the executive order or this kind of memo, you know, change any substantive DOJ expectations with regard to FCPA. I think rather the order is kind of, the order really is just to review these existing guidance enforcement and then, you know, decide whether or not they need to kind of shift where they’re going to prioritize.
Secondly, you know, FCPA is also simply enforced by the SEC. And to date, the SEC has not announced any modifications to their FCPA enforcement program. Now, look, this is not to say that forthcoming guidance is not on its way, right? Like we’re waiting for Paul Atkins to be confirmed, which I think is going to be relatively soon. And maybe he has plans for how he wants to approach this. But as of right now, the SEC has been totally quiet on this.
And then the third one is, you know, and this is in my opinion is the biggest one, is that the statute of limitations for FCPA violations is five years for violations of the anti-bribery provision. So this will definitely outlast the current administration and, you know, any FCPA violations occurring over the next four years, they could be subject to enforcement under kind of the new administration. And then the last thing I’ll say, and also kind of an important one is, you know, there are other global kind of anti-bribery laws and regulations. So global companies are still going to be on the hook for complying with the, you know, with the other ones.
So, look, I’m not saying this as a way to like discount the the potential implications of kind of the rollback or the changes of FCPA enforcement. I think, you know, where what could be kind of problematic is like some companies may now have kind of a higher risk tolerance and hope they don’t get caught, particularly in this kind of wait and see no enforcement period. But, you know, what I am saying is like, perhaps just to calm some nerves, like I don’t anticipate this being a total like wild west with zero guardrails, at least in my opinion. But again, I think once we see that kind of DOJ memo come out, we’re going to kind of get a clear kind of picture of what’s going to come down the pike.
Julie DiMauro: And in terms of, you know, the wild west and companies kind of throwing their rulebooks out the window. I mean, there is the aspect that, having policies and procedures around not having bribery occur through your vendors and your supply chain networks, and your employees, is just good business, and protects your reputation, and that protecting your books and records is actually just plain honest-to-goodness business – and business that your stakeholders expect from you.
Anna Rosenberg: Absolutely. Again, I think it’s going to be strategic. I think it’s going to be targeted, I think, from his America First kind of, you know, viewpoint, it’s going to be very easy to predict maybe where he’s going to what he’s going to prioritize first, both from like a company perspective, but also from an industry perspective and a kind of geographical perspective. But, you know, I certainly think, you know, maybe folks right now are hoping, you know, that, you know, again, they could have this kind of higher risk tolerance just kind of while we’re in this wait-and-see period.
Julie DiMauro: Absolutely. Thank you so much for that. Now, what’s the latest with the Corporate Transparency Act and beneficial ownership reporting? It seems like it’s on again and off again, depending on the day of the week. It did have a lot of bipartisan support. And actually, I will say that, you know, the current Secretary of State, Marco Rubio, had a major role in offering this. So where are we with the CTA?
Anna Rosenberg: The CTA is a trigger for me. It’s something I’ve been working on a lot. And it’s very fair to call it on again and off again. Right. If I were a small business, I would be very flustered just trying to keep up with what the current status is of the CTA. As of right now, the CTA is back and reporting requirements are back in effect, but with a new deadline.
However, the Treasury Department kind of announced that it’s not going to enforce penalties or fines against any US citizens or kind of domestic reporting companies, even after kind of this forthcoming rule change takes effect. Right. And in fact, Treasury is actually releasing a proposed rule around the details of foreign entity reporting. And it’s going to be interesting to see if there are kind of any exemptions or is it going to be all across the board – you know, only foreign entities have to report, not domestic.
Again, back to the first theme. Right. So and then on top of all of that, you know, we are still seeing, you know, court cases that are pending that basically contest the CTA. One thing that I found interesting is Trump’s DOJ defended the CTA in court, even though the administration was outspoken about their views on CTA more broadly, you know, how they think it’s a total botch from like a privacy perspective, but also from like a small business-compliance perspective as well.
So, you know, to me, at least the DOJ continuing to kind of defend the CTA really indicates that the CTA is here to stay. But again, obviously with a very different lens or, you know, a very different focus. And then, you know, to even further complicate all this on the congressional side of things, you know, we have this really interesting dynamic where Republicans and kind of both chambers are introducing legislation that’s intended to fully repeal the CTA. Likely that is not going to see the light of day. They’re not going to be able to get the 60 votes in the Senate. So there’s a little a lot of dynamics at play. I think the industry is going to have a chance to comment. So, yeah, that’s the state. That’s where we currently are.
Julie DiMauro: You’ve mentioned privacy in your remarks earlier. Is this going to be the year Congress will pass comprehensive data privacy at the federal level instead of the hodgepodge of state rules that we have now?
Anna Rosenberg: Yeah, it’s interesting that kind of the question around data privacy is kind of directly after the CTA question, because I think it’s very hard to talk about one without talking about the other. But to be honest, every time somebody asked me this question, I giggle because you would think, you know, here is an issue that it definitely has bipartisan support. It quite literally impacts every single American. You would think Congress would be able to kind of muscle through some of these issues around preemption and right of right of action, which have really been the two kind of sticking points that have prevented significant kind of momentum moving forward. But here we are over a decade later with no federal kind of comprehensive privacy.
You know, I think I was feeling somewhat confident about the introduction last Congress of the American Privacy Rights Act, or it was called APRA, because at least in my opinion, you know, I think it did a decent job of kind of balancing the Democrat and Republican wish list, right, especially in areas of preemption, right of right of action. But, you know, ultimately, you know, this one did not see the light of day. It barely moved. So, you know, I do think we’re still going to see kind of momentum and interest around this topic. But something might pass the finish line.
But, you know, the House Energy and Commerce Committee, they put together a working group and they, you know, release a request for information to the industry. And I think comments are maybe due in April or, you know, in the next several weeks. But I think, you know, the big question that I have at least is like, are they going to fully start over or are they kind of going to use this APRA as kind of as the framework?
You know, I assume they’re keen to kind of start over just because, you know, the different kind of dynamics in the House and Senate and, you know, certainly different like political calculus. But, you know, to be not sound so pessimistic, you know, I do think that they’re trying to get it right. I think it’s a very difficult balance. Right. Obviously, you want to balance the consumer protections and ensure consumers feel empowered over their own personal data. But they also want to make sure that businesses are not hamstrung, you know, from doing kind of critical business practices, things like fraud prevention, extending credit, for example. So I get it. And it’s a different difficult place. And, you know, there’s certainly states that have got it right. There are certain states that at least on the Republican side of the House have gone wrong. And it’s like, where does preemption play into all of this Right?.
And, you know, to your point about states, like certainly the federal government is feeling pressure now that states have really paved the way here I can kind of touch on that a little bit later. But again, back to your question, do I think they’re going to get something done this year? I just don’t know how they’re going to solve for these like main sticking points. And, you know, remember, data privacy will need 60 votes in the Senate. So seven Democrats are going to have to, you know, join and, you know, offer their support. I don’t think it’s impossible, but I do think there’s going to be some concessions that both sides of the whip, both sides of the aisle are going to have to be willing to make. And it’s going to be interesting, you know, are Republicans willing to be doing some horse trading there? Where I do think there is going to be focus and perhaps more kind of quick win, so to speak, is this idea of foreign adversaries having access to Americans’ data.
You know, last year we saw a very significant bill that was enacted into law, which basically prohibits data brokers from transferring both folks’ amount of data of American sensitive data to foreign adversaries. And then we also saw the DOJ finalize a rule basically intending to do something similar. We have not seen Trump or there have been no indications that Trump is going to roll or rescind that final rollback or rescind that final rule. But, you know, it’s definitely no secret that these initiatives are primarily focused on data transfers to China. And, you know, while, yes, there have been skepticism from certain people about whether these initiatives are working as they are actually going to bring their intended benefits, I certainly think kind of there is this, you know, there’s this theme that has emerged, which is, you know, national security as a basis for regulating data flows. Then again, we might see some things being done in that area.
And then I think maybe to just touch on CFPB, because I think this is, you know, certainly has made headlines recently, whether or not CFPB gets dismantled is a totally different conversation. But, you know, under the Biden administration, the CFPB was really focused on reining in data brokers. They introduced a data broker rule, which basically seeks to regulate, you know, data broker practices. This is one that is absolutely, in my opinion, not going to be taken up by the Trump administration.
I know that’s a relief to, you know, a lot of the industry. So it’s going to be interesting to see kind of if and what kind of proactive measures that CFPB is going to take to kind of, you know, whether it’s on data brokers or data privacy kind of more broadly. And then very last thing I’ll say, because you touched on kind of the state patchwork, is that’s just only going to continue to grow. Right. In fact, I was reading an article that now states are actually starting to revisit their comprehensive privacy bills that have been enacted and are going to try to strengthen them. So good luck to compliance teams.
Julie DiMauro: I mean, California is often referred to as the fifth biggest economy in the world. That fluctuates a little bit. But they have a very comprehensive strategy around privacy. That regime is quite robust. So like you said, growing list of states always, always adding to their privacy legislation. But I also see, you know, I see businesses pushing back. It affects a lot of businesses in terms of their data flows and the monitoring that they would need to suddenly be involved with. Or it also involves the monitoring that they’re already doing and puts more constraints around how much information they can collect or not collect. And, you know, there is the idea of customers and employees and their right of access to that information. Right? Many moving parts to it.
Anna Rosenberg: It’s a lot. And, you know, a Republican administration, you know, a lot of their focus also is to make sure there’s less compliance burden on small businesses. Right. And so it’s tough for small businesses trying to kind of comply with all of these. And so I hope that is a big kind of reason why we’re going to see kind of hopefully more push this Congress.
Julie DiMauro: Absolutely. Terrific. Now, I want to talk about the effort from Senator Steve Daines from Montana, Republican and Chris Van Hollen from Maryland, a Democrat who introduced a bipartisan bill last year to expand access to FinCEN’s registry – FinCEN being a part of the US Treasury. Can you talk about that bill and what the prospects are for maybe advancement of this year.
Anna Rosenberg: So maybe a bit of context, right. CTA was enacted in 2021 and FinCEN has subsequently finalized rules both on the reporting side of things, but then also the access. Right.
Like who has access to FinCEN’s BOI registry and, you know, access to the registry was very limited within kind of within CTA and only financial institutions to a certain degree and some law and government enforcement agencies were granted access to the registry. And one of the reasons this is something that I’m tracking very closely is because, you know, screening vendors, like I mentioned, you know, we have this kind of AML compliance product. Right. So screening vendors such as ourselves and all of our peers, we were not granted access apart from a very narrow provision, which was included in the access final rule that basically says, you know, hey, financial institutions, you can outsource, but on a case-by-case basis on a staccato basis.
And also, you know, these vendors can’t use any of this information, any downstream products. So keep in mind also, like the language that’s in the access final rule, there’s no accreditation process. Anybody can be technically this vendor for the financial institutions and access the sensitive data. And I’ll come back to that. You know, why it’s important. So, you know, why is this an issue? Right. Many of our clients are financial institutions. Many of them are regional community banks. And some of these smaller banks, like banks, typically have smaller compliance teams. And so they’ve historically outsourced to companies like LSEG in the first place.
We also have many global banks, right? They need to vet ownership structures that that span dozens of countries and languages and regulatory regimes. And so this is kind of where we where we come into play here. Right? We provide financial institutions with this kind of enhanced view of an illicit actor, which, by the way, at least for us from LSEG perspective, this is all sourced from open public sources. So, for example, you know, we have things like explicit sanctions, implicit sanctions data, watch lists, law enforcement lists. Right.
We aggregate all this information. We offer it to financials and others to help them stay in compliance with various AML KYC ranks. And beneficial ownership is obviously a very important piece to a complex financial crime puzzle. Right. You know, without BOI, it’s very difficult for a financial institution to really truly measure kind of their risk exposure. And of course, BOI’s effectiveness is even more enhanced when it’s supplemented with these other types of data that I just mentioned, explicit, implicit sanctions and so on.
And so over the last two years, you know, my number one priority is, you know, I’ve been educating policymakers on some of these unintended consequences that could arise from these limited access requirements, both from a compliance burden perspective for the financial institutions, but also really from a national security perspective. And ultimately, where we landed is last Congress, there was a bipartisan bill, like you just mentioned, Senator Daines and Van Hollen, which basically allows screening vendors to apply for a license to get accredited and to access this registry on an ongoing basis on behalf of only financial institutions. But we would only have access to foreign entity data, which actually falls in line with what the Treasury is trying to do from a rulemaking perspective. And these companies would have to reapply every two years. This was the last Congress.
A lot of folks think the registry should be totally dismantled. Some folks think that the registry should be fully public. It’s a really tough balancing act. If any of your listeners hear about this issue and they want to get involved, please reach out to me and I’m happy to connect and we can talk further about this.
Julie DiMauro: Thank you for that background. I do want to talk about something that is in the news quite a bit and everybody seems to have an opinion about. And a lot of what they’re doing is winding up in the courts right now. So, DOGE. Elon Musk’s government efficiency initiative called DOGE has certainly been in the headlines. Do you anticipate its findings to meaningfully effectuate change from a policy perspective?
Anna Rosenberg: So, you know, obviously, purpose of DOGE is kind of eliminate fraud, waste, abuse in the government. Right. We all know this. And at least Trump and Musk claim that they have found a lot of it. You know, I imagine there is a second step here. Right. OK, they found all this fraud. What are they going to do about it? And what are they going to do to make sure this doesn’t happen again? So, yes, I do think DOGE findings could impact policy. Particularly in areas such as fraud prevention. Right. So things like digital identity, for example, or identity verification obligations.
I think there’s going to be a heightened focus on how we can leverage some of this technology just to make sure that this does not happen again. And what I hope at least is some of these learnings around fraud prevention also get carried over to the private sector. There’s fraud happening also probably equally as much in the private sector. But, you know, speaking of the private sector, you know, they do have, we do have, very innovative ways to mitigate fraud.
So, again, like digital identity or, you know, identity verification system, for example, I think it’s going to be interesting to see kind of the focus on those two. You know, outside of policy, right, I generally think there’s going to be this push to modernize government systems. And this could include procuring things like identity verification systems or even kind of advancing, again, like digital asset solutions.
The government also knows there’s this additional complicating factor of bad actors using AI and it, you know, they’re becoming even more kind of intelligent, right? These bad actors and they’re making their operations more seamless. And the government, of course, recognizes this. So I think, you know, there certainly needs to be changes from a technological perspective just to make sure that we’re staying up with the times we’re getting ahead of these bad actors, at least from what they’re saying. I think that is what the purpose of DOGE is.
Julie DiMauro: So, broadly speaking, your role as a government relations professional, what’s keeping you up at night right now and what are the other one or two policy actions that you and the firm that LSEG is most interested in seeing at least some greater guidance, if not definitive action on?
Anna Rosenberg: Let me start with your first question around kind of what keeps me up at night. And I’m going to answer this purely from a financial regulation perspective. I think for me, you know, I obviously I understand, you know, Trump’s reasoning for deregulation, right? I understand he wants to ensure innovation stays in the US.
I understand that, you know, businesses feel totally overburdened and overwhelmed. But we just have to make sure national security is not being compromised and people not being held accountable from an enforcement perspective. You know, there is a very delicate balance here.
Things like CTA, whether you like CTA or you think CTA is awful, I think most folks agree with the general spirit of what the CTA is trying to achieve. FCPA is another example, right? And maybe to tie this issue or tie this to an issue that really hits home for a lot of Americans and certainly something that Congress is really trying to grapple with is around fentanyl. Right? There is obviously a direct correlation between more transparency around things like beneficial owners and trying to combat drug trafficking.
So I just hope, you know, the right balance will be struck. You know, one that protects Americans privacy. It alleviates, you know, some of these compliance burdens from a reporting perspective, but it also ensures that we have still continue to have safeguards in place that combat some of these types of crimes. I think in terms of what I am tracking is the possible passage of Senator Daines and Senator Van Hollen’s bill.
But also, you know, again, I would say digital assets. I think we’re at a point where, you know, companies are really actually supportive of light touch regulation. They’re tired of this regulation-by-enforcement approach. So I’m curious about what develops in the space and how regulators are going to approach enforcement more broadly. Are they just going to turn away or are they going to still make sure that they’re going after some of these, you know, kind of really egregious cases?
Julie DiMauro: You know, this is an exciting time to be a government relations professional.
Anna Rosenberg: I have never been busier.
Julie DiMauro: I can imagine. Now, you’ve been so kind as to focus on compliance professionals and a lot of your remarks. How can compliance professionals best navigate this uncertainty and constantly changing regulatory and legal environment, but still make the case to executive leadership they need certain resources to keep the ship upright?
Anna Rosenberg: Yeah, I mean, my advice, the first thing is I would say, do not panic, but also do not loosen, you know, the reins. Right. I know there’s a lot of headlines around proposals that lawmakers are introducing. I think just remember, there is kind of this last check in place, which is that 60-vote threshold in the Senate for most legislation. And, you know, like I said, you know, we are going to see a lot of action from the regulators. So, you know, I would just make sure, you know, continue doing what you’re doing, continue developing strong relationships with regulators and their staff. You know, one thing that people in DC like to say is “personnel is policy.” I think that’s absolutely true. Make sure you’re keeping track of the movements and the kind of the appointments or, you know, of key staff.
I don’t necessarily think the Trump administration is going to try to play kind of a gotcha game with industry, at least maybe not to the same degree as the Biden administration. But, you know, I don’t think they’re going to totally look the other way either. Right. I think there is it’s pretty clear which kind of types of companies and what type of financial crime the administration is going to focus on or is going to put kind of like a microscopic lens over. But, you know, again, I don’t think enforcement is necessarily going to go away. And I do think the administration is going to go after strong cases. So, you know, and also like not to mention, state attorney generals usually step in to fill any void.
So I guess just to summarize, I think compliance leaders should be prepared to kind of urge their business leadership team to remain committed to, you know, building and maintaining very robust compliance programs. And, you know, do not, you know, take your hands off of the reins, regardless.
Julie DiMauro: Makes a lot of sense. And Anna, I want to turn things to you. Tell us about your role at London Stock Exchange, how it’s evolved and about the more helpful pieces of advice you’ve received in your careers. It could benefit others as they develop professionally and in the compliance arena.
Anna Rosenberg: So in terms of, I think, how my role is evolving, you know, I would say, it’s constantly evolving.
You know, there are at least from an advocacy perspective, right? Like there are certain issues that we’ve decided we want to be more proactive on. Just given kind of where the administration stands and some of these issues, there are issues that we’ve kind of put on the back burner just because they’re not necessarily a priority for the administration. But, you know, I think that’s the most exciting part of the job is, you know, always kind of having to adapt based on what the regulatory environment is.
And also like from a relationship building perspective, like making sure that, you know, we’re keeping these relationships fresh and we kind of know where all the key players are and where they sit. In terms of advice, I would say two things. One, you know, embrace lifelong learning. The world is constantly evolving. The legislative landscape, for example, at least in my line of work, is certainly always evolving. So, you know, stay curious and open to kind of learning something new, even if it’s outside of your comfort zone or even if four years down the road in a new administration, it may be a non-issue, for example.
And then I think secondly, and one, I think that honestly, I should have even said this first, is one that really helped me throughout my career greatly is building a strong network, right? Must drop the courage, go to that networking event, be proactive at, you know, developing relationships. You never know who you’re going to meet. That person that you are so lazy to go to that coffee networking, that person might be your mentor or your future boss or whatever. So as cheesy as it is, I would just say, you know, just continue to say yes.
Julie DiMauro: Great advice. Absolutely. You can find mentors, sponsors, friends and other opportunities that way. Absolutely.
Anna, thank you so much for sharing these incredibly useful insights with us today. And for being on this GRIP podcast program.
I want to thank our listeners for tuning in as ever. Please explore our articles and other podcasts at grip.globalrelay.com. And please tell your colleagues about us.
We’ll see you back here for another podcast session real soon.
