Monday, December 11, 2023

NOTES FROM A CONVICTED MONEY LAUNDERER; EFFECTIVE COMPLIANCE STARTS WITH KNOWLEDGE OF THE BEST ADVANCED TECHNIQUES PLUS THE RED FLAGS OF EACH

If you read my article Advanced Money Laundering Techniques, as Taught by a Former Money Launderer

https://rijock.blogspot.com/2023/12/advanced-money-laundering-techniques-as.html

you know that I am currently laboring on a comprehensive virtual presentation, designed for compliance officers who do not have twenty years' of frontline experience, and who therefore have never been exposed to the advanced techniques and methods that laundrymen typically use to gain access to financial institutions without being recognized, identified and interdicted in real-time. I expect that it will be ready to present by January 2, 2024.

But there is an aspect of these advanced techniques that is just as important as the typologies themselves: The indicia, or Red Flags, of each method. Knowing how these tricks of the laundryman's toolkit are used are critical elements of effective compliance risk management, but there is an additional element of each technique that must also be part of your knowledge base: having a clear understanding of the Red Flags, or indicia, of each method, which will aid you in instantly identifying them as a particular type of tradecraft.

I have often found that compliance officers are aware of the textbook description of a specific advanced technique, but would not recognize it during transaction monitoring, because they are totally unaware of how it presents itself while in progress. What are the indicators that a specific method is being employed? 

This is, frankly, just as important as the technique itself, because money launderers are experts at presenting their transactions as legitimate through disinformation and misinformation, which to the untrained eye appear as normal. Applying the Red Flags of a specific technique, however, to a set of transactions often reveals that there something more under the table, a hidden agenda that deserves further inquiry. They are as important to know as the method itself, and must be taught alongside it during training.

One final note; For those who have requested a webinar, given the sensitivity of some of the content, and the risks of their ending up in the hands of financial criminals looking for "foolproof" techniques, My seminar must be limited to private presentations to financial institutions and financial service firms, where unauthorized recording can be prevented, and attendees identified. I well remember that, back in the 1990s, certain elements sought, unsuccessfully, to gain access to Money Laundering Alert's annual conferences. Fortunately, they were blocked. My presentation will be limited to the compliance community. miamicompliance@gmail.com

      

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