TEST THE EFFECTIVENESS OF MONEY LAUNDERING TRADECRAFT INSTRUCTION THROUGH NON-NONSENSE EVALUATION

We trust that you have already read our recent article detailing the absolute necessity of teaching advanced money laundering tradecraft to frontline compliance officers, and of employing a technique designed to effectively imprint this important knowledge upon them. See What's the Best Method to Teach Compliance Officers Money Laundering Techniques (June 25, 2023). That is step one in the process; to insure that you have successfully imparted the money laundering techniques to your attendees, it is critical that you complete the program with a unique form of testing.

I was once tasked, by a former senior member of the American law enforcement community with finding out whether the senior officers of a foreign financial institution could, on demand, and in a real-time pressure environment that simulated realistic conditions, correctly identify specific financial crime/money laundering activity, such as they might expect to experience in their bank. Add to the mix the fact that the bank was located in a high-risk country that was both a transit center for narcotics smuggling, as well as for money laundering, often complicated by corruption.

My method was definitely a baptism of fire for the officers; they were given a number of case studies which had specific solutions hidden in the fact patterns, and assigned only a few precious minutes in which to not only identify the technique in progress in the bank, but create a real-time response and solution to protect it. They were bombarded with one after another in sequence; no sooner had they solved one problem, another was offered up forthwith, and the clock started on the next set of facts.

The officers were allowed to work as a team, and to verbally brainstorm about potential typologies, and then challenged to come up with a recommendation, literally on the fly. Yes, in this case, the group came through with flying colors, because they had been thoroughly trained in the past, under the supervision of the individual who brought me in to test their mettle. 

After you have trained your people, hopefully using both the casebook/case study technique & delivering the content through the Socratic Method, it is time to test their retention, as wella s your own effectiveness. Put them through a post-lecture tradecraft identification endurance contest, preferably on a day after they have absorbed your material, to confirm that they not only absorbed the content, they will instantly recognize it, even under trying conditions. Any errors in their conclusions are to be corrected, and the techniques they missed covered once more; show them where they missed the mark, and use positive reinforcement to make the training a positive experience.

It is hoped that, through this method, you can improve the knowledge base of your frontline staff, and stimulate them to look at every group of transactions that they are monitoring in a new light, from an analytical perspective, and not just pass over something that they should catch.