Friday, March 24, 2023


I was once asked to give a presentation before a compliance association at one of Europe's tax havens/offshore financial centers. The evening before, I flew in from Heathrow; not expecting that anyone would be meeting me in the Arrivals Hall, I went directly to my hotel via taxi, and began preparing for the lecture.

The telephone then rang; it was the lead organizer. Apparently, they had gone to the airport to meet me, and to drop me at the hotel, not knowing that I knew the city from my prior life as a laundryman. They were surprised to learn that I had actually arrived because they had closely watched the arriving passengers from the flight, and not seen me. They wanted to know how on earth I had managed to slip by them.

As you can see,old habits die hard; I had instinctively positioned myself in the midst of a group of locals returning home when I disembarked from the aircraft, and my greeting committee totally missed me in the airport. Once the group was in the baggage claim area, I detached myself from the throng, and slipped out the door, unnoticed by anyone. Of course, I only had hand luggage. We call this hiding in plain sight. Being elusive was a survival skill in my previous occupation, and it has become second nature.

This is how money launderers operate; there might be but one amidst a group of completely legitimate transactions, where a bored compliance officer, looking at transactions at the end of a busy week, and thinking of what he or she is planning for that evening, quickly passes over one solitary entry among many, and not giving it a second thought, misses it completely. It's all about deception, misdirection and mischief.

Start thinking like a money launderer, to catch yours; what would I do to beat my compliance program today, if I was the opponent? Know your enemy, ladies & gentlemen; what specific methods would most likely succeed, given your strengths and weaknesses? Learn the laundrymans' tradecraft and look hard for the telltale indicia of each method; Happy hunting.

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