Strong statements, coming from several official quarters in the United States, including the President, regarding a military reply to events this week against American troops in the Middle East, has led most observers to believe that the reaction will involve Iranian naval assets that support Houthi operations, which minimizes the threat of precipitating a wider war. Such action, which will most likely include attacking Iranian warships and intelligence-gathering vessels in international waters, will raise significantly risk factors to global shipping,
Attacks by the United States Navy and Air Force against Iranian maritime assets, in the region, will cause immediate countermeasures, for risk management purposes, in the shipping industry. These reactions will be varied, making traditional TBML Red Flags, and even conventional Risk-Based, guidelines obsolete, IMHO. Money launderers will seize upon the chaos to change up, and increase, their TBML operations, knowing that normal rules do not apply in periods of ongoing military action on the high seas.
I know from personal experience that money launderers, who monitor unfolding events much more closely that busy compliance officers, who are busy seeking to identify changing TBML patterns, and are innovative and and instantly adaptive to emerging opportunities, will modify their methods long before compliance officers themselves realize the game has changed. New TBML Targets of Opportunity will emerge and be accessed; compliance must be sensitive to every nuance if they wish to win the daily battle against trade-based money laundering within their bank.
Watch for newly-emerging TBML in places where you haven't seen it before, as laundrymen are betting that you are too busy trying to understand the chaotic situation to spot them; be alert to new pipelines.
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