Saturday, December 30, 2023


From my perspective, having been, in turn, a bank attorney, career money launderer working in the tax havens, compliance officer assisting law enforcement and later the private sector, Financial Crime Consultant for World-Check, author, journalist and lecturer on money laundering, and senior consultant on advanced money laundering techniques, compliance directors face a daunting task ahead in 2024, if they truly want to lead effective compliance departments.

I see two mandatory requirements that most compliance departments are presently deficient in, and which must be addressed:

1. Updating all AML/CFT software platforms, to take advantage of the latest advances in programs, especially AI-empowered systems, that became publicly available in 2023. Damn those budgetary restrictions placed by bank management who are focused on delivering excess profits to shareholders. Those massive civil fines and penalties imposed by regulators, and getting a reputation among money launderers that your banks is an easy target, can add up to disaster on 2024. The laundrymen are aware of the new programs, too, and you had best acquire them to interdict their tricks in real-time, or face the consequences thereof.

2. The huge amount of new, and generally undertrained, frontline compliance staff, who are not up to speed in recognizing advanced money laundering tradecraft, is a wakeup call for your directors to immediately conduct advanced training now, to teach your people how laundrymen are deceiving them, through the use of advanced tradecraft. Do not skimp on training, and insure that your staff learn the techniques that are not taught in industry lectures and conferences, from those who have been there and done that.

Pay now or pay much more later, when the true costs of neglecting the acquisition of the latest AML platforms, and of conducting advanced training hit you where you are most vulnerable; in the realm of negative publicity when those shortcomings manifest themselves in compliance malpractice.

Kenneth Rijock,

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