Monday, February 11, 2013


We have all seen the press releases; former FinCEN, OFAC, Treasury, DOJ and other senior government figures accepting well-paid positions, as global anti-money laundering heads at major US banks. where they oversee the entire AML/CFT efforts in those institutions. These are, by far, extremely qualified individuals, with extensive experience. The question remains, are they reforming American AML, now that they are in command ?

We still see obscenely deficient AML/CFT programmes, which receive repeated regulatory slaps on the wrists, and eventual sanctions, but since the compliance operations at many banks remain inefficient, unimaginative, and largely ineffective, the fines & penalties continue ad infinitum.
Furthermore, some narrow-minded bank directors regard the fines as the cost of doing business, and continue to hamper compliance at their banks, for the sole purpose of profit. The net result: the money launderers, financial criminals and terrorist financiers are winning, my friends.

I would like to see these ex-government leaders, now sitting in their comfortable commanders' chairs, make meaningful reforms in-house, by creating new and effective compliance departments, through proper training, mentoring, conference attendance, and salaries commensurate with their assigned responsibilities. Money launderers are now operating at a level far above the knowledge base of the average compliance officer; Let's level the playing field, please, gentlemen. Upgrade compliance to a meaningful level.

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