ADAPTING TO THE NEW 2024 TBML REALITY MEANS DISCARDING YOUR LEGACY RED FLAGS AND GUIDELINES

Any compliance officer with Transaction Monitoring responsibilities at an international bank where customers and third parties send payments through have a difficult, but not impossible,mission: to cull out of rare trade-based money laundering transactions from a sea of normal, legitimate goods and services transfers in global trade. Difficult, yes, but not impossible if you adapt with these changing conditions.

Understand that your worthy opponents, the lawyers, accountants, bankers and career criminals who are taking full advantage of the chaos spawned by the Houthis, climate change, the laws of Supply and Demand, and other variables created by a number of factors, to build plausible scenarios, which mask dirty money hiding in plain sight. Don't let them succeed.

Adapt and innovate like the laundrymen do, to catch them. Throw out your legacy red flags and indivia of TMBL, and build new ones that change when conditions change, but return to them when conditions revert. For example, now that the Panama Canal is, thankfully, starting to return to normal capacity, don't let the laundrymen continue to fool you with excessive insurance and other costs in that area, such as surface transport across the US or the Isthmus of Panama.

On the other hand, when costs skyrocket, as they are doing in the Red Sea region, due to risk, don't let the laundrymen place clearly excessive amounts in payments. in other words, become as flexible as those who seek to move the Proceeds of Crime. Take each transaction on its own merits; throw out your preconceived rulebook; verify all the strange and nonconforming elements of payments, even though it may slow you down in completing tasks. Prove through investigation the falsity of costs and charges and catch them if you can; You can do this.