WITH TWO WARS IN PROGRESS, DECEMBER IS THE TIME TO PLAN YOUR 2024 AML/CFT TRAINING PROGRAM FOR FRONTLINE COMPLIANCE STAFF

The future, specifically 2024, will be here shortly; amid the ongoing sanctions evasion issues involving Russia, you now have increased terrorist financing exposure, due to the armed conflict initiated by HAMAS., which has definitely resulted in increased law enforcement and regulatory attention in North America. In short, December is the time you need to map out how you are going to increase your AML/CFT training during Spring '24, not only to have an expended, and effective program to potentially mitigate any fines and civil penalties that might be levied upon your bank, but to increase your chances of interdicting sanctions evasion and terrorist financing in real-time, to avoid same.

1. Russian and Iranian Sanction Evasion identification is sure to get increased attention in 2024, and you owe it to your frontline staff to present a remedial program, as and if necessary, reminding them of the wide variety of ways that imaginative money launderers, now wearing sanctions evader hats, are moving dual-purpose technology, and artfully cleaning and transmitting payments for goods and services that they have provided countries in the developing world.

2. You need to detail the obscure and esoteric money laundering methods that laundrymen have been employing to provide financial support to specially designated terrorist organizations, especially in the Middle East. North American compliance officers should expect greatly increased law enforcement scrutiny of payments to Lebanon, Turkey and other Middle Eastern jurisdictions. You training should focus upon both tradecraft and high-risk countries in the region.

Advanced training in these subjects is the only way to insure that your staff can recognize threats in progress. Plan out your Spring training regimen, and document each and every step you are taking to prepare them, to reduce the risk that they will miss, or ignore, hidden dangers, and if they do, that the consequences will be reduced to manageable levels.