"FIRST, LET'S KILL ALL THE [CORPORATE SERVICE PROVIDERS.]" SHAKESPEARE, HENRY VI

If you read the outstanding article by retired DEA Special Agent Robert Mazur, you know that the only way to truly deter large-scale money laundering in America's financial institutions is to hold the specific bankers responsible for multi-million dollar violations personally liable. He argues that, unless and until this happens, banks will accept the risk of major civil fines and penalties, as part of the cost of doing business. Only when a conviction and prison term becomes a real possibility will frontline bankers increase their AML efficiency, and stop facilitating money laundering in the pursuit of profit.

Of course, that may be politically impossible in the United States, given the power of the banking lobby, and pressure to avoid massive employee flight from the financial sector, after arrests on a large scale occur. In that event, perhaps there are other players in the chess game of money laundering whom law enforcement can take out of the equation, to reduce the ability of laundrymen to operate successfully. Let's talk about one today.

I am referring to that legal loophole, and effective obscenity, known as shell companies, those offshore, opaque and assetless entities that pervade our financial system. The individuals who provide those shells are generally non-professionals in faraway jurisdictions, where they can safely flout onshore law enforcement and effective compliance. Target the dodgy corporate services provider with the American legal weapons of conspiracy and racketeering, to literally put them and their "profession" out of business. Charge them as co-conspirators in every narcotics, arms trafficking, fraud, and major white collar crime, so that all the providers that fail to conduct enhanced due diligence on their clients, who later are indicted, fall along with them.

In 1994, at the annual conference of Money Laundering Alert, I proposed radical steps to shut down the offshore financial centers by isolating them for trade, communications and finance. While that may be impossible now, due to globalization, law enforcement can make the occupation of a specific type of financial service provider, corporate entity suppliers, so dangerous that its specialists will exit the business poste haste. Let's make that dodgy profession an endangered species; Arrest the bums.