Thursday, April 28, 2016


It's not just the bankers who have been having unannounced, huddled meetings, regarding the Panama papers disclosures; the money launderers, especially those who have ever engaged Mossack and Fonseca to form corporations for them, are also paying attention. Compliance officers can expect them to act upon it, in ways that could effect the banks where they act as gatekeepers.

On May 9, the ICIJ has announced that it will release, in a mass data dump, the balance of the documents, to the public. Look for cash movement, in the first week of May, if not sooner, orchestrated by money launderers who are spooked by the possibility that their clients' companies may be named.

The preferred method is to move illicit capital into an obscure jurisdiction, one that is not yet generally regarded as a tax haven, or offshore financial center. Then, the funds would be move into at least two, successive, newly formed, local companies, so as to effectively cut the paper trail, denying investigative reporters (or law enforcement agents) the name of successive companies employed in the pipeline.

Even money that is no longer held by a Mossack-formed Panama corporation, and residing in accounts, under other company names, may be transferred by money launderers, in an overabundance of caution. Watch for suspicious transfers of large amounts, even from long-time clients whose activity has been minimal for several months, or even years.

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