WHY IS NOBODY TEACHING TRADECRAFT TO FRONTLINE COMPLIANCE OFFICERS ANYMORE ?

I continue to see that younger compliance officers, indeed even some compliance directors, do not have a working knowledge of the more esoteric and arcane techniques which experienced money launderers use on a daily basis. It's been a generation since the USA Patriot Act was passed, and I fear that the knowledge base that post-9/11 compliance officers, who did not have to be motivated to broaden their horizons through the study of relevant Federal decisions, so that when they saw an unusual pattern, they would recognize it as one that appeared in a major case in the past.

While money launderers are constantly fine-tuning their techniques, meaning they are ever so slightly changing some of the elements, to fool law enforcement, the advanced techniques remain as effective as they were in 2001. Learn them, and pass on your knowledge to your more junior staff, and insure that, every six months, you make an effort to catch up on all the new techniques that law enforcement has exposed, or which appear in Federal Court decisions.

If you cannot explain, and recite from memory, at least thirty money laundering methods, you are not fully trained in the AML/CFT field. They don't reach those techniques in the seminars; catch up with the money launderers' tricks, or have one go right over your head tomorrow. and two years later, a law enforcement agent will explain it to you when you must comply with a subpoena for your customer's records, after his arrest, having used your bank with impunity.