Thursday, March 17, 2022

WHERE WILL RUSSIAN SANCTIONS EVADERS/MONEY LAUNDERERS GO NOW ? SCANDINAVIA, PERHAPS.

 

Please allow me to don my old money launderer's blazer, put my thinking cap on, and figure out where the smart Russian money managers are most likely apt to test the waters, for the successful evasion of the newly-enacted global sanctions against their country, which will require clever money movement, in an unlikely place, far from the usual routes and jurisdictions, but potentially effective for their goals.

You see, money launderers are only limited by their imaginations. They brainstorm, scheme, research, and plot, often staying up night and weekends, just to match wits with the international banking community, to come up with a cash pipeline never tried before, and apply it to an industry or profession not known to be targeted by financial crime, and that most bankers would not consider to be high-risk.

For those readers who scoff at the use of Norway's financial system by foreign money launderers, let me take you back to a specific scheme created by a an artful team of Iraqi bankers, seeking to move and clean over $100m in US Dollars, diverted from the billions the American military shipped to Iraq for post-war reconstruction. I understand they successfully employed a major Norwegian bank for that task, because an American law enforcement agent who received details about the operation didn't believe it could be done through that financial institution, in that country. 

I think I will follow the breadcrumbs laid down quite convincingly by my friend, Andreas Hobbelin, and choose Scandinavia, in general, and Norway in particular. The country's complex web of interlocking transnational corporations, extremely complex by design, include a number of Russian beneficial owners, and constitute a maze that only compliance officers with attention to detail can unravel. The corporate structures are ripe for exploitation by career money launderers working for Russian interests abroad. That is, if they were not already doing it, before the invasion of the Ukraine.

Let me humbly suggest that compliance officers at Scandinavian financial institutions, especially those whose clients engage in international trade, advise their frontline staff to be especially sensitive to, and promptly report, any transactions that might possibly be Russian sanctions evasion through money laundering; things are seldom what they seem.


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