Last week, an interviewer asked me whether it was really possible to eradicate money laundering. We will never stop the most innovative money launderers from practising their dark craft, but you can virtually banish money laundering from the bank where you work. Unfortunately, banks do not assemble the necessary human resource tools to get the job done.
Here is my formula for unqualified anti-money laundering success. You compliance "Flying Squad" team must include at least one individual with these qualifications :
(1) A former or retired law enforcement detective or investigator who formerly specialised in white collar crime. Federal or national experience is preferred. You may already have such a person, if you have a Financial Intelligence Officer on board.
(2) A former money launderer or white collar career criminal, now working on the correct side of the street in AML.
(3) A businessman formerly employed at a large public company, who has an acceptable level of AML/CFT experience and education.
Why these three ? The ex-law enforcement agent has investigative skills, and experience, that you in compliance frankly lack. The former criminal's skills speak from themselves. He is best suited to identify criminal activities. The former businessman can bring his experience in working in the private, non-financial sector to bear, as he knows what it is like to work in the types of firms that are your typical bank clients.
This team would take all the Suspicious Activity Reports, bank officer queries, and information received by bank staff that appears to be inconsistent with the customer's trade or business, and provide real-time identification, and interdiction, of active money laundering at your bank. You need to be proactive if you are serious about money laundering suppression; think about it.