TO CATCH TRADE-BASED MONEY LAUNDERERS IN THE ACT, LEARN EVERYTHING ABOUT WHAT TBML LAUNDRYMEN KNOW ABOUT THEIR INDISTRY

We are in the middle of a TBML crisis; the perfect storm of choke point transportation issues with the Suez/Red Sea/Gulf of Aden, Panama Canal, Black Sea and Baltimore bridge accident have rendered the generally reliable red flags through which compliance officers working in transaction monitoring identify TBML in progress useless. So long as the global situation remains in constant transition, legacy compliance procedures are ineffective.

So, what to do? It is humbly suggested that compliance officers broaden their knowledge base in the shipping, insurance and transportation sectors, so that they possess the same information as the laundrymen are using to push the proceeds of crime right under their noses. Are you tapped into the daily status of transportation pricing, supply and demand regarding consumer goods coming from Asia to Western markets, insurance and risk management resources, meaning the shill sets that TBML laundrymen already have, by virtue of their experience in the industry. In short, learn what they already know, and access the relevant insider resources for anything that you cannot acquire.

Compliance officers,establish go-to people in the above fields, whom you can plumb for what passes for internal industry information in those sectors. Take some courses, even online in your precious spare time, or get your superiors to sponsor them, and allow you to devote a portion of your work week to education. If you really want to be able to spot TBML during this chaotic period, immerse yourself in the industry where laundrymen already have the training and experience, and are embedded in it. Emulate your opponents' background and knowledge, to beat them at their game.