COMPLIANCE OFFICER, KNOW THINE ENEMY AS YOU KNOW YOURSELF

Then there was the time when some bright soul advising World-Check, during the time when I served there as Financial Crime Consultant, convinced senior management to adopt a certain IT upgrade, reportedly to speed data to the clients faster. Well, not only was the so-called improvement a failure in its promised goal, it crashed the entire program for an extended period of time. Needless to say, the PR problem was a nightmare, because the clients needed 24/7 access for Customer Identification Procedure, as well as due diligence inquiries in progress when the system broke down.

While some clients demanded that they receive credit for the time in which they were denied access, and other sputtered about financial losses sustained, one client, a major London law firm whom I shall not name, had a simple request of the W-C management to compensate them for their loss of service; they demanded that yours truly be assigned to the firm for a day, allowing them to receive a presentation from me, on the laundryman's perspective, and to respond to the many detailed questions posed by members of the firm, including the CEO, who asked them over lunch. Most important of all their wants and needs was to understand their adversaries.

The point of my visit was to help the client understand the perspective and viewpoint of the practising money launderer. Management that supervises AML/CFT compliance departments whose goal is to identify and interdict laundrymen would do well to emulate that goal. here are some tips to follow;

1.identify the specific money laundering vulnerabilities at your shop which you face.
2. Assemble the individuals in the law enforcement sector who are most familiar with those threats, and have them discuss how they can be identified and dealt with in real-time.
3. if possible, find a former fraudster or convicted money launderer in your geographic area, and bring him or her on to speak to your frontline compliance staff about how laundrymen typically operate in your region.
4. Have your outside bank counsel brief your staff on recent money laundering indictments and investigations, to get a feel for what's out there, and who is most likely to be targeting your bank.

Start trying to understand your worthy opponents, by speaking with those who know them by their deeds, as well as their thoughts.