HOW A MONEY LAUNDERER BECAME A COMPLIANCE OFFICER

Someone asked me how I became a compliance officer, and I noticed that my autobiography, in the published version, doesn't over that portion of my life, and so to answer his question, I thought it best to pull out that section, which exists in my original handwritten manuscript, and which I am presently adapting to tell an uncensored version of my story. Here it is.

I was home one night, when I received a call from a banking lawyer that I had done a number of joint financial crime lectures with. He had an urgent problem; an overnight trip to Argentina had come up unexpectedly, and he had a previous commitment to teach a seminar on hedge fund money laundering early the next morning at a conference on Miami Beach. It is a subject of interest to me, and I agreed to fill in for him, and teach the class in his place.

After I finished, two people came up to see me; they were the CFO and director of compliance of a Florida company that sold investments in the insurance sector, and which was the largest of its kind in the world. They had a problem; one of their new clients was poised to invest $15m, and though he had been approved by the company's outside law firm, the smart owner wanted a second opinion. Would I conduct an enhanced due diligence investigation?

It sounded like a challenge, and I accepted after a meeting with the owner.The target of course passed a preliminary due diligence with flying colors, but I was tasked to pull out all the stops in an EDD, to rule out any possible chance that either the Source of Funds or Source of Wealth was an issue. Again, no red flags, but I was still concerned, because the client was a wealthy businessman from the Republic of Georgia.

One of the things I look at when conducting enhanced due diligence is what the target is doing when he for she is off duty, or outside their work, leisure or social worlds. What do they do they think we are not looking at them? This means photographs, images, which can capture them in unguarded, or incriminating fleeting moment. Perhaps sitting next to someone at a dinner that raises questions, or attending event where others not so acceptable are also seen. That's the beauty of photographs, especially those taken without the knowledge of the target.

I found a photograph online, taken at a distance, at the airport in Tbilisi (Tiflis in English) Georgia. The target was on the private aviation area, standing at the bottom of the stairs of an arriving business jet, for an obvious associate to appear. That person was one of Russia's powerful Oligarchs, one of his country's biggest robber barons. I eventually had my answer; the investor was a frontman for Russian organized crime, and I rejected the client, after which I accepted an offer to handle only high-risk affluent clients, and to come on board as a compliance officer. Even with my record, my ability to act as gatekeeper was needed to identify and interdict sophisticated transnational criminals trying to place investments.

A postcript; in the world of money laundering, I know that if you cannot get access to a financial services company through the front door, you always try the back door, or even the side door. The target later, I found out, cleverly placed the fifteen million dollars through the company's Bermuda subsidiary, which had its own separate compliance department, and which did not share information with the U.S. office. 

(I'd like to think I would still be there, but one day a bunch of uniformed Federal law enforcement agents showed up, but that's a story for another time.)