Tuesday, July 11, 2023



Last night, an earthquake, registering 6.6 on the Richter Scale, occurred more than 200 miles north of Antigua & Barbuda. Although no damage or Tsunami issues were observed, compliance officers would be well advised to remember that smart money launderers often use natural disasters as a smokescreen to shield their movement of the proceeds of crime. Remember, the East Caribbean contains offshore financial centers with a long and sordid history of accepting the proceeds of narcotics crime and fraud, and corrupt bankers that ask no questions still hold senior positions there.

Laundrymen generally, but not always, disguise any criminal funds transfers made in the aftermath of a natural disaster by showing them as payments from charitable organizations, NGOs or nonprofits. Compliance officers observing such post-event transfers into the region should carefully vett the sender, which is often using the name of a known charity, but with a minute change in the exact name, to give the impression that it is an established entity. Of course, it is a but well-executed deception, using a name very slightly different, even down to the use of a non-Latin/Roman alphabet letter or letters very similar to the real thing. 

The the United States, we have observed post-hurricane movement of illicit profits by experienced money launderers, because they know that, in the chaos of a natural disaster, compliance officers are often seconded to tasks other than their primary responsibilities, leaving a vulnerability, and even those that are still on their assignments, the public policy of rushing aid to the victims of natural events may cause them to approve and pass transactions that they might otherwise take a hard look at.


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