REPORT: ADVANCED MONEY LAUNDERING TECHNIQUES ARE THE PRIMARY CONCERNS OF AML PROFESSIONALS

                             

If you happened to see the articles today about the survey entitled The State of Global Anti-Money Laundering Compliance Report 2023, you would have seen its conclusions about the biggest threat in the AML ecosystem: "It found that 46% of AML professionals are concerned about increasingly sophisticated money laundering techniques..." What this means is that advanced and evolving methods and tactics, as a principal component of money laundering activities, are neither being identified nor interdicted in real-time, and this continued migration, by laundrymen, to arcane and esoteric strategies that they refine and improve upon, is consistently beating your frontline compliance staff each and every business day. Also, AI won't usually catch evolving techniques that it hasn't seen before.

We have been focusing of late upon the mandatory nature of training in money laundering tradecraft, with regular retraining to match the evolving nature of the activity. Frontline compliance officers must not only learn about the advanced techniques in current use, they must also be aware of the more obscure and unusual ones, as well as have the mental flexibility to recognize traditional techniques that have been tweaked or modified, making them difficult to easily recognize, but which still retain certain indicia to be identified. Remember, in the world of the money launderer, the only limitations they have is their imagination; compliance officers must also be versatile and flexible in their perspective, so that they can  ferret out laundering activity when they see it, so matter how artfully it is disguised.

Take a good, hard look at your current training program? Who is teaching it? What experience do they have, and what don't they have, concerning the subject matter. Who is attending" How often are you offering it? Is it effective, given the parameters specified above?

In order to consistently catch money launderers in the act, compliance officers must have: (1) a thorough grounding in the advanced techniques, (2) a complete understanding of how laundrymen thnk, which makes them vulnerable to identification, and (3) continual updates on what money launderers are doing now, and tomorrow, in the legitimate financial marketplace, to keep up with the times. If your training program doesn't have these features, you have already lost the contest. Govern yourselves accordingly, compliance directors.