COMPLIANCE OFFICERS WHO HAVEN'T LEARNT MONEY LAUNDERING TRADECRAFT WILL NOT PREVAIL

 

The British alone have a word for it: TRADECRAFT, the actual nuts-and-bolts trade secrets in any profession, that are employed successfully in the field, and not known to the public. In the world of money laundering, it is tradecraft that beats compliance officers every time, whether it be a technique or tactic unfamiliar to legitimate bankers, an esoteric (known to only a privileged few) practise that nobody teaches at AML/CFT conferences and lectures, or a permutation of an existing technique that renders it invisible to conventional check-the-box compliance due diligence. Whatever it is, it invariably works.

Two years later, when your bank is visited by law enforcement, bearing a subpoena, you ruefully find out to your chagrin that a money launderer ran a technique right over your department, and you failed to identify it in real-time, and were unable to interdict the transfers as gatekeeper. This can have a negative effect not only on the compliance department but could result in ccivil penalties, and negative press, especially if criminal indictments result, and your bank in named as one of there funnels for the laundering. it can also cause you to lose face with senior management, which could have career implications, none of them good.

Therefore, start learning about obscure money techniques; learn to understand the money launderer's perspective, how he or she thinks and acts; how they disguise their operations, to hide in plain sight, and most importantly, how they are adept at innovation, modifying their techniques own the fly. If you need further details, ask yours truly or someone else who has actually done these things, not some professional AML lecturer, and start learning how to catch money launderers in the act.