WHEN ADDING NEXT-GENERATION AML/CFT, COMPLIANCE OFFICERS SHOULD CONSIDER THOSE DETAILS TO BE RESTRICTED

Sign on commo equipment,  4th infantry Division, Vietnam

Before I attended law school, I served a tour with an armored cavalry unit in the First Infantry Division, during the conflict in Vietnam in the 1960s. Communications security during a time of war is critical, lest your enemy learn your plans, and devise an appropriate response in advance, which can cost your side dearly.

On our military radios, most of us had a small sticker, which read Charlie is Listening, located where it could not be missed by whoever was operating that device. Charlie was of course Victor Charlie, the military alphabet designated for the Viet Cong, the VC, our adversaries, whose guerrilla warfare tactics we might today call asymmetric warfare.

The point of this article is to inform you that, when you acquire that next-generation AML platform, do NOT rush out a detailed press release bragging about it, because money launderers read PR websites too. 

They also have the latest technology, because their budgets are far larger than yours at the bank, and they are often ahead of what is commercially available, as are their clients. When I was engaged in laundering narcotics profits for American, Canadian and European traffickers, I knew that they had been using email back before it was generally in regular use. They also were the first to use personal computers to store data about their operations, and went paperless years before that was a common. event. 

Don't give your opponents any useful information about what software and AI platforms you are using to catch them. Let them think you are still running that old legacy system, so that they don't change what they have been doing in the past, do you can catch therm in the act.

If your provider must publish details of your acquisition of a program employing artificial intelligence, as I trust you will be buying in 2023, if you do not already have such a system, have the company's press release show you as a prominent international bank with a global reach, and not identify you by name. Remember that many money launderers are former bank lawyers and accountants; they know how compliance operates. Just don't give up anything confidential about how you are conducting your anti-money laundering and counter-terrorist financing operations, lest they act accordingly.

Remember, money launderers might adapt, and overcome obstacles you have placed in their way, if they knowing what you are doing. Don't make it easy on them.

Captured VC  radio; note red sticker at bottom

                                    enlarged; "Charlie is Listening." One of our stickers on enemy equipment.