Saturday, June 4, 2022


Is there a bloody Solution, Pooh ?

I am amazed that the world's compliance officers, charged with being the AML/CFT gatekeepers, persist in being reactive, instead of proactive, which has a much higher probability of success in real-time interdiction of money laundering. They fail to understand that laundryman are engaged in dark, though dynamic, occupation that does not turn off when the business day ends. They are out to beat the banks and the global law enforcement community, and they are eminently succeeding.

Having spent a decade in that opaque, but intellectually challenging profession, in my youth, I know that money launderers, who are only limited by their imagination, are always several chess move ahead of compliance officers, and the law enforcement agents assigned to stop them. They are always moving forward, invading areas of legitimate commerce, moving illicit capital, and going forward to yet other strategies and tactics. long before their footprints are discovered. Their tradecraft continues to evolve, leaving their adversaries behind.

Sometimes I feel like a member of a beleaguered professional football team, way down in the standings, destined to fail each and every season, but still pushing against the tide. Is there a solution ? Perhaps it takes a new perspective, solving the problem, not after the fact, but before it occurs. There's the rub.

Remember the film Minority Report  ? In a dark future, individuals who advanced technology calculated had a propensity for crime, were detained before they could commit that crime. Could a software program actually predict that an individual was extremely likely to engage in money laundering in the near future, employing available open source data ? No, I don't mean "Thought Crime" from 1984, but real public data, from which a true threat level can be extrapolated. Short of that feat, anti-money laundering and countering terrorist financing will continue to fail, time after time. Who can reach back, into the period BEFORE the money laundering is conducted, and stop the crime before it occurs ?


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