MONEY LAUNDERING IS FINANCIAL ASYMMETRIC WARFARE: TREAT IT AS SUCH

My generation, which personally experienced a fifteen-year foreign war, instead of happy childhoods, and which then required our participation as adults, was faced with what was then known as guerilla warfare. When one adversary is greatly more powerful than the other, the weaker party engages in what we now call asymmetric tactics; hit and run, escape & evade, exploit vulnerabilities when they emerge, and fade away when confronted with overwhelming power and force.

Money launderers, I quickly discovered when adapting what I learned on the battlefield to financial crime operations, employ all the same tricks in their tactics, and compliance officers would do well to look for them, as they create their own "counter-laundering" policies and procedures. Laundrymen:

(1) Seek out financial institutions that do not have effective (and well staffed) AML/CFT compliance departments. Is yours at the level of best Banking Practices, or are budgetary obstacles thrown out by Management keeping you from attaining such status?

(2) Use, abuse and swiftly lose financial institutions. is your Customer Identification Procedure an expedited process, with timely follow-up after account opening, or do you not get back to monitoring new accounts for six months, and give it to your newest, most inexperienced compliance staff?

(3) Move on abruptly to other banks after moving money, giving busy compliance officers an excuse not to continue to examine some transactions that might be questionable. Do you closely check those accounts that are "in-and-out" in a short time frame? This might result in a SAR filing to protects you, when law enforcement comes calling months later, after your former customer is indicted for conduct elsewhere.

I could detail such scenarios all day long, but it is your responsibility, as the compliance leader, to anticipate that money launderers will exploit your weaknesses; anticipate and close them now, or risk the adverse consequences of compliance malpractice, loss of employment or even indictment in some huge Federal case where you only knew one individual, but that was enough to destroy your career, your assets, and your future.