WHEN ROGUE OR FORMER INTELLIGENCE AGENTS GET INVOLVED IN CYBERCRIME, THEIR TRADECRAFT AND SKILLSET WILL TRUMP COMPLIANCE EVERY DAY OF THE WEEK

First of all, a tip of the hat to the two Colins, for raising, properly, the spectre of property crime in the context of the fugitive Bulgarian super cybercriminal, the artful Ruja Ignatova's evasion of justice, reminding us that in Dubai, you can be a wanted fugitive and still be able to quickly divest yourself of your assets. But there's a much more dangerous threat at work here.

Ignatova's use of a former senior intelligence officer from Luxembourg, whom the "Cryptoqueen" engaged as a foil to combat emerging law enforcement investigations against her, and to insure that she would not be captured, demonstrates the clear and present danger that that trained intelligence officers present to AML/CFT compliance. Such individuals have received advanced training in the employment of shell, shelf and front companies, routinely and expertly launder funds in support of their covert operations abroad, and are frankly light-years ahead of most bank compliance officers.

They know all the laundryman's tricks and more, and operate in a very dark world in the tax havens and offshore centers with impunity, due to their skillsets. They tend to operate efficiently inside any tax evasion and proceeds of crime regime, where they are misidentified as garden variety criminals, if they are seen at all.

They had literally unlimited budgets, like narcotics traffickers, when on duty. In my humble opinion, the only people who have a chance at identifying and interdicting their criminal operations are the few retired and former military intelligence officers currently working in the compliance arena.

Compliance officers, when dealing as gatekeepers for high-risk individuals who show prior military backgrounds, should dig deeper, and if there's what appear to be an intentional gap in details, should consider whether your target was, in truth and in fact, a former intelligence officer, and govern yourself accordingly. Those individuals will run rings around your compliance program. Keep them from obtaining access, please if you want to keep your job.