Wednesday, April 3, 2024

DO YOU HAVE TO GO TO LAW SCHOOL TO BECOME A TRULY EFFECTIVE COMPLIANCE OFFICER?




Several years ago, upon request, I wrote a screenplay about two elderly retired (and convicted) Miami money launderers, toiling late at night in a downtown office building. After their release from Federal Prison, the only jobs they could get were as cleaners in lawyers' offices. Think grey-haired Don Johnson and Andy Garcia; They are found by a Madrid detective, who hires them to find an elusive global money launderer thought have died before a Cuban firing squad years before, but who is, in truth and in fact, very much alive, and hard at work cleaning drug profits in South Florida. They closely worked with him decades ago, and could be the only ones capable of bringing him to justice.

Correctly assuming that their target has eyes everywhere in his native Miami, they conduct their investigation from the unusual anonymity of a museum, located in the city's Historic Overtown, which was the police department and courthouse in the pre-1965 segregated past, knowing that he would never consider looking for them there.Eventually, they find their subject, performing on stage on Miami Beach, having long ago assumed a new identity, and altering his physical appearance. The identified him from a specific technique that he employed to launder the proceeds of his clients' crimes.

The moral of the story if there is one, is that to catch a money launderer, you need people who have the tools, and skills to rein him in. Although many may disagree with me, I firmly believe that, to be really effective, a compliance officer must start with the education and training that only a law degree can confer. Learning about a wide variety of legal subject prepares the individual to meet the challenges that the job presents. The fact is, many laundrymen are practicing attorneys, who use their acquired skills to create tradecraft that deceives and confuses traditional compliance officers, who don't have the perspective, as well as issue perception, which three years of learning from the casebook method instills in them. Simply put, I believe that there's no other training and education one can acquire which will put you on a level playing field with what former DEA Special Agent Tom Cash once referred to accurately as
attorney-criminals.

I rest my case.

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