Saturday, March 28, 2020


If you are a fan of heist movies, you probably have seen the 1970 film Kelly's Heroes, a story about a group of soldiers in the US Army in 1944 in France who go AWOL to rob a shutered bank behind the German lines that is storing millions of dollars in gold ingots. Based upon a true story, it illustrates the old maxim "The best time to rob a bank is in the middle of a war."

Maney launderers working for international narcotics cartels are most likely working overtime this month, as they are fully aware that compliance officers at international banks in North America and in the European Union have their hands full with the stay-at-home orders from Government, personal fear about catching the Coronavirus, or their families catching it, and performing their duties at the bank. There have been requests to defer, for ninety days, any and all compliance with the Bank Secrecy Act, and all other AML/CFT regulations and obligations.

In short, individuals who are working in the financial community, who are preoccupied with mortal danger, as well as the practical difficulties they now encounter in operating a compliance division at anywhere near an effective level, are under siege, and money launderers, who are always looking for vulnerabilities and systemic weaknesses, are most certainly driving a financial truck, loaded with the proceeds of crime, right through the bank's front, and back, doors.

Look for online transfers of funds, payments that ordinarily would be quickly spotted as inconsistent with a trade or business, payments for phantom deliveries of goods that are most likely trade-based money laundering, and similar transfers that an alert, and physically present, compliance officer might interdict, if he or she was on duty. Money launderers thrive amidst chaos; expect them to be hard at work in the current emergency situation, plying their dark trade, and in your bank.

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