MONEY LAUNDERERS AND RED COLLAR CRIME

I was leaving the stage after speaking at an anti-money laundering event, about my decade as a career money launderer, and how laundrymen create new techniques, when I was approached by someone that was most likely a DEA agent attending the event. He asked me whether I knew a certain now deceased Miami lawyer known for having had a large clientele, consisting of Latin American businessmen. Coincidentally, we had both worked at an international law firm in the 1970s, when he chose to go out on his own, as often occurs with young ambitious lawyers in a big city.

He had been found floating face down in Biscayne Bay, and most of us assumed it was suicide, due to the stresses of dealing with difficult, affluent clients, compounded by marital troubles. Apparently, the agent said, that was definitely not the case, as he had  been killed by a client, most likely to cover up any possible future damaging testimony against him, as he felt threatened the lawyer might choose to cooperate, concerning his money laundering activities.

We call this Red Collar Crime, when a violent act is committed to cover up a white collar crime. It happens more often than you think to money launderers whose clients feel threatened that the lawyer-laundryman may choose to avoid prison by rolling over on his criminal client, and render what we call Substantial Assistance. When I was once subpoenaed to appear before a Grand Jury in Florida, I had a lunchtime visit where I was asked about what my testimony might be. Readers know I chose to not testify, which led to my evential indictment for RICO, but I am the exception. Most lawyers don't have the stomach for incarceration, and they are the weak link in any criminal organization.

It might surprise you to know that this conversation with a law enforcement agent, advising me that a lawyer had been killed to cover up his money laundering past has occurred a number of times over the years. Lawyers who launder money for narcotics traffickers are often targeted by paranoid, or simply careful, clients to keep them from revealing where all that client's laundered proceeds of crime are located. Most lawyers never consider that when they begin a life of crime; perhaps they should.

The lesson here for compliance officers is this: when your bank client who is a wealthy lawyer passes away, you might want to confirm the circumstances of his death, and while you are at it, check his accounts. Were there any suspicious transactions? Any indicators of activity inconsistent with normal business practices? What about trust account activities? You do not want a visit, two years down the road, from someone with a subpoena for his law firm records, because that may mean you failed to catch his money laundering for clients.