WHAT DO YOU DO WHEN YOUR COMPLIANCE JOBS ARE ENDED BY A RAID, AND A MURDER?

It appears that there are a number of readers who were unhappy with being left hanging by my recollection yesterday, about how I became a compliance officer, notwithstanding that I was a former money launderer. Well, how left that role is far more curious than the manner in which I ended up in it.

I was working at my desk one day performing enhanced due diligence checks on a number of investors that had been named by the firm as potential high-risks, meaning that they came from countries with high levels of corruption, narcotics trafficking, and/or financial crime, when I heard a commanding voice right behind me say, " Sir, step away from your computer." I quickly turned around to see an armed, uniformed law enforcement officer standing directly behind me. The good news was that he was not holding a firearm on me, but the impact on me, of his bold statement that day, made from behind, I cannot minimize. I know what it's like to be arrested, remember.

I remember thinking, "WTF? I had paid my debt to society with almost two years of incarceration, and could not for the life of me think of why I was being targeted again. Thus was several years after my release, and I had religiously stayed on the straight and narrow path since then.What could possibly be the reason why I had an officer behind me, commanding me to shut down my work station and stand up?

To add to my confusion, I vaguely recognized the officer; wasn't he from US Customs, and hadn't he been involved in the original Caribbean money laundering investigation that ended up in Irish accountant Sean Michael Murphy's Roadtown BVI office back in the early 1980s, and uncovered the money laundering operation in the British Overseas Territory of Anguilla? This was beginning to look like a bad dream come to life.

But wait! As I looked to my right, down the hall, at the work stations of some of my coworkers, I noticed that all of them also had law enforcement standing behind them as well, barking orders. It wasn't just me, it was everybody. A wave of relief washed over me at that moment, because I had feared some old unfinished business had come back to haunt me, and spoil not only my day, but my next decade. 

We were all herded into the conference room, and a man in a business suit stepped up to the podium to speak. I recognized him as a former US Attorney for the Southern District of Florida; What's going on? He explained that he had been appointed as trustee of the company where I was working, and it was ceasing all operation forthwith; bottom line, we were all fired. Some of us would be rehired, but solely for winding down operations, and we were not to count on being brought on for any significant period of time. 

It turned out that four of the senior officers of the company had a closely-guarded secret. They were operating a sophisticated Ponzi scheme, inside a billion dollar investment firm. The owner would ultimately be sentenced to twenty years in Federal Prison, and the company's primary investment tool would be held by the Eleventh Circuit Court of Appeals to be a security, and subject to registration with the SEC, which had not been done.

I was out of a job, but was quickly hired by one of the firm's most successful salesmen, a man whose annual commissions exceeded a million dollars each year, as his personal compliance officer to screen his personal clients, which he had taken with him. I was immediately back as a compliance officer, working remotely, as he lived up in Fort Lauderdale by-the Sea, and I was in Miami.

Unfortunately, it was not to be, for my new boss had previously made a habit of taking certain Asian ladies from our old office with him on overseas trips, when we were with the firm, and somehow, his fiancé had figured out what was going on from a strange email that she had seen. The young lady had my boss purchase a large handgun for her, claiming that she was afraid for her safety, when he left her alone on those trips, and she used it on him one night, alleging to the police that he had attacked her. Eventually, she was charged and convicted, but that violent event abruptly ended my compliance career for the time being. Next stop: financial crime consultant.