WHAT'S THE BEST METHOD TO TEACH COMPLIANCE OFFICERS MONEY LAUNDERING TECHNIQUES?

Assuming that you have secured an competent instructor, with at least a decade of frontline financial crime experience coming from one side of the law or the other, your next question is to decide what method will he or she employ to effectively teach money laundering tradecraft. The method is just as important as the content, because the goal is to imprint the specific techniques firmly into the attendees' minds, so that they can recognize each and every one in an instant, under the everyday pressures of completing their assignments on schedule.

The traditional structured lecture method, which is frankly dry, boring and causes the recipients to not only lose interest, but to begin to drift off into sleep, I cannot endorse. unfortunately, this is the typical lecture style used in compliance industry seminars and conferences. Even the narrative technique, which verges on story-telling, fails to adequately imprint the techniques to the extent where the compliance officer that we hope absorbed the material will quickly spot it under all circumstances and conditions.

My personal choice, and one which I know from experience is eminently effective, is the case study method, used since time immemorial to train lawyers, and reportedly pioneered at Harvard law School. where the professor works from casebooks, which contain notable cases. This technique has several unique features:

(1) Rather than give the student the answers, it forces them to perform an analysis, and to extract the issues from superfluous facts, so that they understand their significance. They learn what we call Issue Perception, which is a skill lawyers acquire by repeatedly reviewing cases,  exploring the fact patterns, and finding the answers within. Compliance officers need this skillset.

(2) The teacher generally does not supply any hints, but instead tries to draw out the solutions from the students themselves, employing the style of the Socratic method, but focusing upon challenging the students to extract the central issue. At the end of the sesion, the professor comments upon the student's conclusions, and adds in his wisdom, so that there is an understanding of the principle which he has been seeking to instill. 

(3) As a first-year law student in my youth, I was privileged to attend a Contracts class given by the law professor who was the model for Professor Kingsfield in the classic film The Paper Chase.  I know from personal experience how effective this sometimes strenuous, but stimulating, method is. That's how lawyers are made.

It is suggested that your lecturer prepare fact patterns in which all the typical, as well as advanced and obscure, money laundering techniques are hidden, so that the attendees can be challenged to extract them from each one, under time constraints, as they encounter in real life. Creating such a lesson requires extensive preparation, and which will not be possible unless the individual has a thorough understanding of the content. Choose your instructor candidate wisely, from his work history, and you will have an effective class.

For further information, you can reach me at: miamicompliance@gmail.com .