Tuesday, August 29, 2023


While money launderers come from a wide variety of occupations and professions, most are errant attorneys, accountants, current or former bankers, or corporate or financial service types. Who they are is not as important as what they are as a measurement of effectiveness in that dark business.Can they wash, dry & fold (place, layer and integrate) a criminal clients' illicit profits with ease, and without exposing either themselves or their clients to law enforcement, government regulators, or bank compliance officers? That is the litmus test of their ability.

In measuring those individuals, I like to use a military equivalent to simplify the metric: many are Company Grade, and a much smaller group are Field Grade. For those who don't have prior service to guide them, Company Grade are the Lieutenants and Captains. They have a modicum of  training and experience and are frontline participants in the game, the movement of funds through the financial  structure, in order to conceal their criminal origin, and clean it along the way to a specific goal, whether that be legitimate investment, or simply concealing it for future client access.

The second group, which is much smaller, are the Field Grade money launderers. The military equivalent are Majors and Colonels. They have already had extensive hands-on experience "in the field," as active players in the movement of illicit capital, and they have been eminently successful in this criminal endeavour. Graduating from day-to-day money movement tasks, they now generally supervise their subordinates and "staff" in significant volume of dirty cash, while retaining their version of Command and Control over the entire operation.

Whose is it that you encounter when you catch someone laundering money into, or through, your bank or non-bank financial institution ? It is the Company Grade money launderer, either when he makes a fundamental error, or you are just good enough to spot his moves. As a compliance officer with training and experience, looking for the red flags of money laundering, or specific tradecraft, you identify his operation in real-time and out him, as the gatekeeper you were designed to be.

Sometimes, however, this is not the complete story. Your young money launderer may just happen to be the tip of the iceberg; he may be only an underling, in support of a far more experienced laundryman, one who has had many years to not only perfect his craft, but to evade and elude detection through experience and the money laundering experience of street smarts. 

Field Grade money launderers, which are few in number, and who may have decades of success behind them, are the kingpins of their illicit profession. In truth and in fact, they may be behind the curtain here, directing others from a position, both physical and leal, of utter safety. Those individual are the hardest to identify, let alone interdict in process. They may confine themselves to sanctuaries where they defy extradition, due to corruption and political connections, or by sheer power. You my even have identified them, only to find you are unable to find evidence linking them to criminal activity.

Therefore, the next time you unover what appears to be a sophisticated money laundering operation, but cannot understand how the players have identified could have created such an advanced method, look under the covers for another hand in the equation, someone directing the participants and players, like puppets on a stage. You may just have seen evidence of a rare breed, their supervisor. Catch that man if you can, or at least identify him for the rest of us to watch for. 

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