TRADE-BASED MONEY LAUNDERING AND THE POWER OF IMAGINATION

Money launderers engaged in TBML are constantly pushing the envelope in their quest to outwit compliance officers, and they succeed more often than not, due to their ability to adapt to the financial environment in which they must move, and ultimately clean, the proceeds of their clients' criminal profits. They achieve this by constantly moving the goalposts, by being infinitely flexible, and by watchful waiting for opportunity to occur.

We are presently living in a situation which is the functional equivalent of a natural disaster: with the Suez Canal/Panama Canal/Black Sea transport issues affecting global commerce, laundrymen tactically employing TBML schemes have the commercial world, which is preoccupied with these obstacles, at a serious disadvantage. Money launderers are certainly exploiting the chaos, which we know because of the paucity of reports of compliance departments and law enforcement agencies interdicting TBML operations.

I know from personal experience, gained through a decade of laundering drug profits, that it's all about applying one's imagination to the problem. For example, I guarantee that a number of enterprising laundrymen have created shell companies purporting to be engaged in insurance coverage, to shield the transfer of dirty money, disguised as insurance payments for losses,,whether from wartime damage, delay and spoilage issues, and a number of other types of insurable events that arise constantly in times of danger and exposure to risk. They may have already set up front shipping companies for that purpose. Other laundrymen certainly are involved in that most esoteric trade crime, International Product Diversion, which we have discussed here at length.

Money launderers in the TBML field are, as we consider it, brainstorming over new ways to take full advantage of the confusion over trade route risks. They are actively engaged proactively, seeking out new methods, which they use, and then lose, effectively defeating unimaginative compliance officers who don't embrace the possibility that what they are seeing are not necessarily legitimate payments for trade, but creative criminal variations on a number of themes, forever changing form and format.

Take another look at that transaction; analyze it, dissect it, and you may find it is more than it appears to be. Be as creative as your worthy laundrymen opponents, gentlemen, and you can stop them. Happy hunting.