Deb's recent statement, that money laundering techniques have indeed expanded beyond the traditional three-step diagram, is spot on. Indeed, the only way one can now describe it is to liken it to a TESSERACT, a representation of a four-dimensional cube, to approach what is a complex operation with many facets, some of which are designed to confuse and mislead, and others set to allow the user to arrive at his or her destination successfully, without being caught by either vigilant compliance officers, or law enforcement. A conundrum without a solution.
Speaking Truth to Power.
Perhaps we need to take a whole new approach to AML/CFT, as what we are doing now is akin to people living and working in a two dimensional system, while the laundrymen are operating in three- and four dimensions. There are multiple AML perspectives pushing back against mysteries that are often on a much higher plane. Almost forty years after the passage of the Money Laundering Control Act, compliance officers are still playing catch-up with their opponents. When will next generation technology finally level the playing field, as we cannot outthink the money launderers, who are constantly adapting and improvising in real-time, while compliance plods along, fighting last year's war this year. Compliance is playing checkers, on the laundrymen's chessboard. Who will invent the perfect AML platform, and when?
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