Tuesday, November 28, 2023


Compliance officers at international banks are presently working during a period marked by increased risks posed by the double-barreled threat of Russia sanctions due to Ukraine, and a new terrorist financing focus due to the Israel/Hamas war, and this is not the time for newly-minted frontline staff to get on-the-job experience. Banks need seasoned compliance directors to guide their staff during this high-risk period, individuals who will deliver practical training programs, to equip their people to deal with these emerging threats, while still exposing them to the money laundering tradecraft that they need to know to identify advanced and unusual techniques employed by laundrymen.

Since you can't give your staff twenty years of hands-on compliance experience, adequate training, supervised by people who have been there since 9/11, and can pass on their decades of actual tactical exposure, has become mandatory. Neither academics nor former regulatory officers can give your staff the benefit of the perspective of experienced compliance officers, who should be conducting your training sessions, using not only the needed content, but illustrating the information with their own actual examples from cases they handled.

Any compliance directors whose 2024 training budgets are not sufficient to bring in outside talent should draft their most experienced frontline staff to conduct that training. I humbly suggest that they may wish to employ the twenty Money Laundering Tradecraft articles that I have published on my blog this year, to give their people a broad-based background in the techniques that they are most likely to encounter in their daily workload, If you are not aware of those articles, email me at miamicompliance@gmail.com  and I will supply you with a detailed list of the topics I have covered. Use your best people to teach your new ones the tricks of our trade, ladies and gentlemen. These are difficult times for any compliance department; you need to meet these challenges head on; use your most experienced people to do that.  

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