MONEY LAUNDERERS; EXPERTS AT APPEARING TO BE SOMETHING WHICH THEY ARE NOT

I am enjoying the new Apple TV Plus dramatic series, "Dope Thief," in which two criminals who pose as DEA agents to rip off drug dealers in their place of business make the mistake of attempting to steal from an organized crime operation, and are fleeing for their lives as the result. It may sound contrived, but when I was a career money launderer in Miami, my narcotics clients had to be very careful to avoid criminals who specialized in armed robberies of their operations. Those individuals engaged in that sordid business knew their victims could not go to law enforcement. Those attacks forced traffickers to follow a Golden Rule: never keep the drugs and the money together in the same location, a drug dealer's necessary risk management policy. One of my clients actually specialized in negotiating with those ripoff specialists, because they often took hostages, and demanded still more drugs from their victims, and/or cash.

The relevance to today's AML compliance issues is that experienced money launderers are very good in creating, and operating, what look like legitimate businesses, but are, in truth and in fact, well-planned laundering operations. This is especially important when it comes to the payment and payments processing sectors, where a clever laundering operation can move millions in the proceeds of crime into legitimate commerce, completely unnoticed and undetected, if compliance is not aware of the methods employed. Unlike the fictional series now streaming, the real-life posers generally succeed, and are long gone by the time someone in compliance in Payments Processing wakes up to the possibility that money laundering is occurring on a massive scale.