I was once tasked to teach the directors of a major Dominican Republic bank about money laundering methods. The bank had been a repeated victim of sophisticated laundrymen successfully depositing narco-profits, and there were well-founded fears of regulatory action. Rather than get up in front of them and detail the most dangerous and esoteric techniques, I chose a much more hands-on approach.
We put the bank's directors in a small room, and gave them a dozen fact patterns, such as the bank's compliance officers might experience daily, and report to them. They had only five short minutes to confer and decide upon a course of action. Some were new account profiles, but most were specific transactions. We pressured them, such as occurs in real life situations.
At the end of the exercise, I used each example to demonstrate specific techniques, and what was it about them that gave away the particular scheme. Much like the casebook method taught in law school, the program was designed to explain in practical terms how one identifies money laundering tricks of the trade. I put the directors on the spot to jointly brainstorm, and draw conclusions from facts; it works.
Therefore, it is humbly suggested that, rather than bore compliance officers with a monotonous lecture, which they will not remember use this hand-on method, so that when they actually see money laundering, they can identify, and hopefully, report it to senior staff in real-time.
We put the bank's directors in a small room, and gave them a dozen fact patterns, such as the bank's compliance officers might experience daily, and report to them. They had only five short minutes to confer and decide upon a course of action. Some were new account profiles, but most were specific transactions. We pressured them, such as occurs in real life situations.
At the end of the exercise, I used each example to demonstrate specific techniques, and what was it about them that gave away the particular scheme. Much like the casebook method taught in law school, the program was designed to explain in practical terms how one identifies money laundering tricks of the trade. I put the directors on the spot to jointly brainstorm, and draw conclusions from facts; it works.
Therefore, it is humbly suggested that, rather than bore compliance officers with a monotonous lecture, which they will not remember use this hand-on method, so that when they actually see money laundering, they can identify, and hopefully, report it to senior staff in real-time.
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