WHO MIGHT BE THE ONES QUALIFIED TO TEACH YOUR COMPLIANCE OFFICERS MONEY LAUNDERING TRADECRAFT?

 

Now that we have established that most frontline compliance officers do not recognize advanced money laundering methods and techniques, because they have never been effectively instructed in what to look for, it may be time to figure out who is qualified to teach them. Obviously, the AML/CFT industry, which presents pricey seminars and conferences that generally don't scratch the surface about tradecraft, is unqualified regarding this critical topic, and the certificate programs out there, as well as those that offer a university degree in compliance, are also failing in this regard.

So where does a compliance director who is serious about closing the knowledge gap regarding his or her staff's understanding of advanced and esoteric money laundering methods and strategies? I regret that I can offer very few effective choices:

(1) Former Assistant United States Attorneys, but only those who acquired relevant experience in prosecuting a large number of money laundering and financial crime cases, during their careers. You will have to screen them carefully, to find those few individuals who really know the subject. The problem is, they are now light-paid criminal defense lawyers, and since many bank executives, sick and tired over wat they feel are excessive compliance budgets, will probably balk at paying these former AUSAs their going rate, you may not be allowed to hire them.

(2) Retired Federal law enforcement agents: Provided you can find one who has serious relevant experience, this could be your best choice. Some will claim to be competent, but you will need to determine whether they focused on money laundering cases to confirm their knowledge base. They are out there, you just need to find them. Many work in law consulting and investigative firms, and may not be receptive to teaching, but others will be interested.

(3) Former money launderers; Unfortunately, you can count us on the fingers of one hand; only two qualified in North America, because once convicted, sentenced and completing their incarceration, they  generally want to get as far away from the field as possible. Some fear retribution from clients,against whom they testified, or who were never charged, and are concerned about being identified. Nevertheless, those few of us who are out there are available, though many banks don't choose to hire us. They prefer to send their staff to meaningless seminars.

(4) Law school instructors and professors: many of these individuals have prosecutorial experience, state as well as federal, in bringing money laundering cases, and choose to teach, which makes them good candidates for imparting the knowledge your compliance officers require to be effective. You might want to explore this group especially on a virtual classroom basis.

As you can see, the number of qualified individuals is extremely short, you may not be able to convince your superiors to engage them, and they not be interested in the job, which can be tedious at times, and not what they are used to doing, at this point in their professional lives. Nevertheless, if you continue to fail to train your staff in money laundering tradecraft, they will continue to fail to identify laundrymen using advanced or unusual techniques in your bank, which is your loss as supervisor and leader.