SPONSOR BANKS FACE THREATS IN THE FORM OF OLD WINE IN NEW BOTTLES- ADROIT MONEY LAUNDERERS APPLYING LEGACY TRADECRAFT AGAINST FINTECHS

If you read my recent articles, A FORMER MONEY LAUNDERER EXAMINES THE SPECIAL MONEY LAUNDERING PROBLEMS THAT ARE FACED BY SPONSOR BANKS,  and  HOW DO SPONSOR BANKS INSURE THAT THEIR FINTECH CLIENTS ARE NOT OWNED OR CONTROLLED BY MONEY LAUNDERERS? you know that sponsor banks have an increased level of money laundering risk, when it comes to the threat of money laundering through the accounts of their fintech clients

Experienced professional money launderers, who are highly adaptive in responding to today's anti-money laundering compliance programs, which means the widespread use of software effective at both account opening (CIP) or transaction monitoring, actively seek out targets of opportunity, of which fintechs, for the reasons I stated in the above-mentioned articles, stand out as vulnerable, in my humble opinion, based upon a decade of hands-on experience, as a career money launderer ferreting out such potential victims.

Knowing and understanding the money launderers' mindset and I do, let me humbly suggest that compliance directors at sponsor banks initiate a comprehensive program of education, with their frontline opposite numbers at fintech clients, to educate them in all legacy advanced money laundering techniques, to reduce the risk that such methods, with modifications, are being employed to deceive fintech compliance officers. I know that laundrymen regard fintechs as good targets, and these companies' compliance officers must be able to recognize advanced money laundering techniques when they see them in operation.

It is humbly suggested that you take the extra step to train your fintech compliance officers in the advanced, esoteric, unusual and exotic money laundering techniques that international banks face each day, for I guarantee that innovative money launderers are already successfully applying them to your fintech clients, and as you do not want to have such techniques resulting in the movement of the proceeds of crime coming through their accounts at your banks. Additionally, for the purposes of mitigation of your future exposure to regulators, operating such proactive programs could benefit you regarding your relations with them.

Compliance officers, teach your fintechs to interdict the money launders in their own houses, so they don't impact you in yours.