If I was a compliance officer assigned to Transaction Monitoring at an international bank with a significant number of clients engaged in major levels of international trade, I would be looking for an increase in the number of trade transactions that are fronts for TBML operations. I would be assigning additional staff, with sufficient prior experience in detecting TBML, so that none of my existing compliance officers was overburdened with new volume, for that is a recipe for being too rushed to complete assignments each day, meaning that some TBML will be missed.
I hope that my recent articles about the new opportunities that have emerged for laundrymen to exploit the Suez/Panama/Black Sea vulnerabilities has been taken to heart, because your TBML opponents are most certainly trying, every which way but loose, to slip in dirty money whilst there is no uniformity in how the shipping industry responds to the challenges it faces in 2024. They may come at you hard, so push back with additional compliance talent, to ease the individual burdens suffered by your staff in these difficult times.
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