Sunday, August 27, 2023


When I speak at conferences and seminars about the decade I spent as a career money launderer, attendees often come up to me after my presentation and bluntly ask me why I ever got involved in such a dark, and indeed suicidal, activity. As a respected bank lawyer, Vietnam veteran living in Miami, with its superb weather and everything else that the city offers, how did this happen? Most money launderers get caught sooner or later, usually because their "clients" get jammed up with an indictment, and the only way they can mitigate their eventual sentence is to render what is known as Substantial Assistance, both in the arrest of others, and in the Government's recovery of the proceeds of crime.

I am a first generation American, from a family that arrived in the US a century ago from the Ukraine. Being blessed not only with a liberal arts education, but also the professional benefits of law school, how did I stray, ending up in the company of narcotics traffickers, some of whom were definitely dangerous to be around? 

I left graduate school to enlist in the Army during the height of the war, even though I could have received a medical deferment. My patriotic position was that with the privileges of citizenship also come responsibilities. While there, I extended my tour, which is how I ended up on the back of an armored personnel carrier, crossing the border, in Nixon's ill-fated invasion of Cambodia, when we attempted to wipe out the North Vietnamese Army's sanctuaries there. it was my welcome to the Ho chi Minh Trail.

I used to think that it was become of PTSD, Post-Traumatic Stress Disorder, and it is true that I was exposed to serious during my more than 400 days in Vietnam, where the enemy was doing its best to end my life, and of those I served with. Many Vietnam veterans, many of whom have been diagnosed with PTSD, later engaged in criminal activity after their discharge, and served time in prison for their crimes. was the war the presumptive cause?

Alternatively, I thought that living in a dangerous, life-threatening situation had made me an addict to that kind of life; since I encountered a number of Vietnam vets engaged in international narcotics smuggling, I believed that the theory had merit. I know that I personally chafed at being confined to a law office all those early years. Did a life of safety bore me? 

Now, however, I have something medical to consider as the cause for my aberrant behavior: Last year, the Veterans Administration started administering the newly-passed PACT Act, which  deals with Vietvets who were exposed to Agent Orange, a defoliant sprayed from the air into the jungles of Vietnam, to deny cover to the NVA and Viet Cong. My tour was in the area most affected, and I have filed a claim, as I have a condition and symptoms presumptively linked to that toxin. Fortunately, I do not have terminal cancer as the result, because like many veterans so exposed I would already have passed away, as have a large number of them. I am able to deal with my Agent Orange exposure, thanks to advances in medical science.

Here's my dilemma: Agent Orange also has neurological consequences: many of those exposed now have conditions that include Parkinson's Disease and ALS, also known as Lou Gehrig's Disease. I don't know if I have been affected in any way, but neurological damage can affect one's behavior. Did I commit money laundering because I had a diminished capacity? I cannot say, but it is just one more mystery I cannot answer, as only an autopsy of my brain will supply an answer, and medicine has not reached the point where Agent Orange has been determined to cause normal people to engage in crime.  

So, I have no answer for you; I have spent decades trying to atone for those sins, by teaching law enforcement, the intelligence community, and the private sector how to catch money launderers, performed EDD and identified financial criminals, and exposing money tradecraft to two generations of compliance officers. Hopefully, I will one day know why I acted the way I did, but in the meanwhile, I offer my unique experience and perspective as a financial crime consultant. Find the bad guys, ladies and gentlemen.      

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