Friday, July 28, 2023


Before I went to law school, I enlisted in the US Army, and spent a substantial amount of my military service with the First Infantry Division in Vietnam in 1969-1970, mostly in the field searching for an elusive enemy who was extremely experienced in what we now refer to as asymmetric warfare. This involves the artful use of deceptive tactics whose civilian equivalents are disinformation and misinformation, the techniques of fooling your adversaries to achieve success.

Years later, I would employ some of the methods and techniques I observed while engaged against hostile forces as an attorney-turned money launderer, acting as a sort of financial Viet Cong,  constantly changing up and modifying my criminal activities, always seeking to spread confusion among my opponents, both in the financial, as well as law enforcement, worlds. Over a period of more than a decade, I honed my craft, to escape and evade detection and capture, and if some of my clients had paid attention to my instruction, I might very well still be engaged in that dark profession, had I succeeded in staying alive in a dangerous life where financial errors have dire consequences.

Some of those techniques that I used then are in common use today, because frankly, they are not generally recognized as disinformation and misinformation. For example:

1. USING CORPORATION NAMES THAT ARE SIMILAR TO THOSE OF ESTABLISHED ENTITIES. Bankers, especially compliance officers, often erroneously believe that these deceptively similar names are somehow part of a major Fortune 500 company. i once used "Continental" in a name, and DC lawyers wanted to know whether it was owned by Continental Grain.

2. FORMING COMPANIES IN OFFSHORE FINANCIAL CENTERS, WHERE BENEFICIAL OWNERSHIP CANNOT BE TRACED, BUT USING THEM DOMESTICALLY, WITHOUT DISCLOSING THE JURISDICTION OF FORMATION. Many compliance officers mistakenly assume that a local bank client, with a brick-and-mortar location ( e.g. office) is domestic. It isn't necessarily so.

3.FORMING COMPANIES WITH THE SAME EXACT NAME IN A NUMBER OF JURISDICTIONS. Another cute trick to fool wire transfer department; having previously passed a company's international wires, one coming in at the close of the day, which is stated must be sent forthwith, ends up going to an entity with the same exact name, but elsewhere.

4. OPENING AND CLOSING A CORPORATION, AND ITS ACCOUNTS, WITHIN A CALENDAR YEAR, AHEAD OF ANY REPORTING REQUIREMENTS WITH THE SECRETARY OF STATE. Only the original frontmen from the day of formation are ever shown, and they may be attorneys, accountants or financial services company agents.

5. MAKING A VERY SMALL CHANGE IN A RECOGNIZABLE CORPORATE NAME TO DISGUISE YOUR FRONT COMPANY. Sometimes, just modifying a name with a single letter, or a suffix, confuses compliance officers, some of whom may even consider it  simply a typographical error, and correct it in their records.  

We will discuss the use of Psyops ( Psychological Operations) by laundrymen, in a subsequent article.

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