Friday, December 8, 2023



In any large compliance department at an international bank, you generally have staff with a wide variety of experience. There are, in senior positions, compliance officers with a decade or more on the job, meaning those individuals who have often held a number of compliance and risk management positions in the financial sector, and therefore have been exposed to many of the wide variety of imaginative techniques employed by laundrymen in their ongoing quest to deceive compliance frontline personnel, and move the proceeds of their clients' crimes through the global financial structure.

There are also a large number of more junior staff, who although they may have taken the necessary classes, and have passed the required academic or vocational examinations, and have the right to append the obligatory initials after their names and titles, really don't have that hands-on experience, in the field, that makes an effective compliance officer. The result is that when a really unusual, opaque technique crosses their computer screen, they fail to identify it as financial crime, and give it a passing grade, allowing it to not only to penetrate and exploit their bank that one time, but to assure a money launderer somewhere that he or she can use that trick time and again, with a reasonable expectation that it will not be identified and interdicted.

Frankly, you cannot get information on many of the advanced tradecraft tricks, because they are either rarely used, are old wine in new bottles, or new iterations, meaning permutations of existing techniques, or have appeared only in obscure references within pleadings (not published decisions) in Federal Court in New York or Miami. They are not, by any means, available to the compliance industry; only known to those of use whose business it is to ferret the out, collect them, and disseminate them, either through publication, or in virtual or real-life presentations.

It is vitally important that those who are newer to the compliance culture not only learn these advanced methods, they need to see their application, in fact patterns that might appear in a typical compliance workday. We encourage training officers to insure that their frontline people, especially those with limited experience on the job, not only know those tricks of the laundrymens' trade, but can consistently extract them from of a crowd of transactions; Knowledge is power, when it come to the compliance profession.

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