TRADE-BASED MONEY LAUNDERING; COMPLIANCE OFFICERS ARE STILL AT A DISTINCT DISADVANTAGE

Most law enforcement agencies who are tasked with interdicting TBML conservatively estimate that 90-95% of most trade-based money laundering operations are completed without being discovered and exposed by compliance officers at international banks who are involved with Transaction Monitoring. One only needs to look at the dearth of TBML prosecutions at the Federal level in the USA to know that this may even be an underestimate of the threat level. Why is this the case?

You can blame tightening banks compliance budgets, for when a bank's boards of directors, concerned about compliance costs eating into their precious shareholders' dividends, cuts the budget for training, compliance loses. You can also point to the total lack of advanced, recurring TBML instruction by compliance directors, who may themselves have never held a frontline compliance Transaction Monitoring position, and most likely do not have a sufficiently sophisticated grasp themselves of the topic. Finally, the tendency of law enforcement agencies to consider advanced techniques "Law Enforcement Sensitive." and not getting the typologies out to compliance, when speaking at conferences, outside of perhaps one case study at a time for fear that laundrymen might learn about such techniques, all add to the problem.

Unless and until compliance directors start giving TBML training on an advanced level, especially to new newer frontline staff, laundrymen will continue to push through, and thereby repatriate, the proceeds of narcotics crime, financial fraud, insider trading, and a hort of other white-collar crimes, each and every day of the banking week. Train them now, or endure the consequences of failure later, gentlemen.