Thursday, March 16, 2023


If you as a compliance officer have had the opportunity to interact directly with high net worth clients who are seeking to open account relationships with your bank, you know that many of them, due in large part to their success, and human nature, are incredibly arrogant, and at times difficult to deal with, when you seek to perform enhanced due diligence, They often demonstrate impatience with the delays that your inquiries often require, and they tend to push new accounts staff to pressure you to quickly complete your tasks, which adds to job stress.

Financial criminals are no different than their legitimate, wealthy counterparts. They are used to demanding and often getting, expedited service from money launderers, and the financial service professionals who assist them. I know this from personal experience; criminal clients often equate success in illicit enterprises with wisdom, which is a dangerous thing.

One group of my former clients insisted upon transferring a large portion of their criminal proceeds from accounts in a perfectly opaque Caribbean tax haven/offshore financial center, to certain banks in Switzerland known for their respect for client privacy, among other things. I objected, and declined to assist, based upon a number of factors which are best not detailed here in a public forum, as they constitute Tradecraft.

Nevertheless, and without any financial training or experience, they elected to proceed, even going so far as to conceal the transactions from me.This proved to be a fatal error, for not only did they themselves fall victim to Swiss financial professionals, whom they relied upon to their substantial loss, their actions exposed them to both European and American law enforcement attention, which further compounded their losses when their funds were targeted, seized and became subject to the first ever joint Swiss-American significant forfeiture proceeding;They lost millions of dollars.

The clients' arrogance ended up being their downfall; they went against my prudent "professional advice;" their arrogance led to fatal mistakes. This occurs more often than you would think. Criminals, flush with cash, impatient for results, do things which,if caught by alert compliance officers who, reading data which contains only a single red flag, the clients' error in judgment, tumble to an illicit enterprise.

Finding that sole inconsistency, in sea of what appears to be a legitimate operation, is now simplified by the availability of next generation platforms and systems powered by artificial intelligence, which can extract it from unstructured data previously neither accessible nor known to exist. AI allows compliance to literally turn the tables on financial criminals who make that single unforced error. Always be on alert to harvest that one,lonely item that will ultimately lead you to uncover something which was hidden in plain view. Happy hunting.

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