Monday, January 8, 2024

IS INTENSIVE AML/CFT TRAINING ON ADVANCED TECHNIQUES EFFECTIVE?





Having given AML/CFT Tradecraft training presentations in the past that are as long as two full days, during which time attendees are brought up to speed on the entire galaxy of methods and techniques used globally by money launderers, as well as what they might be focusing on in the future, a question has arisen; Can such a large amount of information be condensed into a short-form, intensive course, which will cram the laundryman's tricks into them, one after another, hoping that they will absorb them, so that they can identify them in real life situations?

I must, unfortunately conclude, based upon my more than 40 years on both sides of the issue, that there is no short-form method of educating frontline compliance officers by ramming the typologies into them in an abbreviated fashion. Examples of each technique, which illustrate how they are employed and deployed, are essential to comprehending the material. The use of actual case histories and fact patterns from reported cases that resulted in arrests and convictions, is also a necessary evil, if you may, to further round out the knowledge base of attendees. In short, there's no shortcut to that fund of knowledge, and to attempt to give frontline compliance officers "AML for Idiots" is folly.

Therefore, compliance directors should resign themselves to creating a course of study, which starts with a survey of all the tricks, and is built upon by updates twice a year, using qualified experts, and not your senior staff, to teach the material. Give your staff the knowledge they need to catch the bad guys literally in the act, please.

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