WHEN WILL THE DOJ START GOING AFTER AMERICAN BANKS WHO FAIL TO EFFECTIVELY TRAIN THEIR COMPLIANCE OFFICERS?

Ask any compliance officer how international product diversion money laundering works, or the criminal use of Life Settlements, and you get a bloody blank stare. It's because financial institutions never invest the time to hold closed-door training sessions, where their frontline compliance officers actually learn the nuts and bolts of advanced and esoteric money laundering techniques, what the brits call Tradecraft. Given the strong language contained in the massive British American Tobacco case, and the news that US compliance officers who approved over 300 transactions that ultimately benefited North Korea, because they didn't understand what was happening, you can expect that heads will roll, and it will not be pretty.

And it's not just the banks themselves; how many useless hours do compliance officers spend annually at industry conferences and events, where the content they receive is neither helpful nor current? Far too many, in my humble opinion. There simply are no private lectures, restricted to active duty compliance staff, where cases demonstrating the evolving methods of laundrymen are not only explained, but analyzed, and investigative solutions detailed, given the availability of Artificial Intelligence platform countermeasures, for attendees.

I'm sorry, but appending a long train of initials after your name, to demonstrate your AML/CFT competency to the world just doesn't cut it for this old former money launderer, if you cannot diagram for your frontline staff each and every advanced money laundering technique in present use, and identify it solely from raw data presented to you. There is a knowledge deficiency in the industry, and it my take a major casualty among America's banks before they wake up and smell the coffee. Read the BAT Criminal Information, and govern yourselves accordingly.