IN MONEY LAUNDERING, ALWAYS CONSIDER THE LAW OF UNINTENDED CONSEQUENCES

I note that, for the purposes of stimulating tourism, nonstop flights between the Continental United States and the Faroe Islands are about to begin this month, from New York Stewart International Airport (SWF) to Vagar Airport in the Faroes (FAE). If you weren't paying attention in Geography class, the Faroe Islands lie just north of Scotland, and west of Norway, in the North Atlantic. It is a self-governing territory under the external sovereignty of the Kingdom of Denmark, which is similar to the arrangement of certain British Overseas Territories in the Caribbean. They have one of the longest functioning Parliaments in the world. Are you beginning to get the picture yet?

The Faroes are outside, and not a part of the European Union; even their Danish nationals residing there are not considered to be bound by any EU treaties. The territory is also not bound by EU sanctions against Russia, and in fact continues to trade with Russia since the invasion of Ukraine. It is outside the Schengen Zone, but in fact there are no border checks on those traveling between it and the Schengen countries. Additionally, it is part of the Nordic Passport Union, meaning no travel documents whatsoever are required to enter Scandinavian countries. Perhaps now you understand the potential attraction for laundrymen and other of the Usual Suspects.

Remember, money launderers play a dangerous game of chess with the world's law enforcement agencies. To avoid discovery and arrest, they think several steps ahead of their adversaries. This means they find new Targets of Opportunity to operate in or from, in the commission of money laundering and financial crime, long before such new jurisdictions become known to law enforcement and regulatory agencies.

American citizens can now travel nonstop to the Faroe Islands, visa-free, and stay up to 90 days. There is no American Embassy or consulate. If you have read between the lines, seamless travel from the Faroes into Europe is not only possible, but could most likely be accomplished without leaving a paper trail.You see, the idea is not to move and clean criminal proceeds in the Faroe Islands, but to use the jurisdiction as an intermediary stop where the territory's relationship with the countries of Scandinavia can be exploited, as a part of an international money laundering operation. Indeed,  flights from New York to the Faroe Islands could have unintended consequences not considered by the territory's government. 

I am sure that a number of enterprising transnational money launderers, who have had long and satisfactory experience in the Caribbean, and elsewhere, and who always are doing research into new "opportunities,"have already seen the Atlantic Airways press releases about the commencement, on August 22, of flights to the Faroe Islands. Like I once did, they stay up nights and over weekends, just to ferret out such new potential places to operate from, in, or through. We can only hope that Europol, as well as financial crime investigators, and bankers, in Norway and Sweden are reading this article, and will govern themselves accordingly. Money Laundering chess is a game for both sides.