REMEMBER, THE MONEY LAUNDERERS ARE FIVE MOVES AHEAD OF YOU, AS THEY ARE PLAYING CHESS, WHILE YOU ARE BOGGED DOWN IN A GAME OF COMPLIANCE CHECKERS

As we wait and wonder what Iran, and its proxies in the Middle East, will do this week, rest assured that the money laundering community is already deeply engaged in pre-planning, so that when the shooting starts, they can achieve success, whether that be in Trade-Based Money Laundering (TBML) amidst the chaos in international waters, or creating an employing bogus charities to move dirty cash with impunity, or even appearing to aid ni relief,when in truth they are facilitating their criminal clients' illicit enterprises.

Laundrymen are inveterate chess players, while compliance officers tied to "check-the-box" procedures are clueless about new and innovative permutations and adaptations of existing techniques. Compliance officers must be flexible, always questioning the legality of transactions that they do not fully understand, and being on the lookout for anything that might possibly represent money launderers' taking advantage of unfolding "opportunities."

The moment that things so south in the Middle East this week, compliance officers should start looking for anything which was not there previously. If it looks like a new development brought on by the attacks, check it out for you may find it's merely a well-planned and executed operation that seeks to fool you and any other frontline compliance officers that spot it. Be proactive, please.