'TIS THE SEASON TO MOVE THE PROCEEDS OF CRIME

As we approach the first major American holiday of the season, compliance officers would do well to remember that professional money launderers target every potential vulnerability at financial institutions, when choosing to move and clean criminal proceeds. They know that senior compliance staff often take additional vacation days when their children are out of school; some travel, others welcome visiting relatives. In short, the experienced compliance people at a bank who actually are the backbone of its AML/CFT gatekeeping ability are off duty.

That's when opportunistic money launderers strike; they try to move dirty money at the end of a business day, just before a holiday or weekend, because they also know that compliance directors, with all that seniority, and being the department head, often think nothing about leaving work early on those day, to get a jump on the rush hour traffic bound for the suburbs; Think about that. They bank on human foibles and shortcomings.

Therefore, don't let your senior compliance talent skip out, without leaving someone who know how to spot money laundering tradecraft, in real time, and  block those clever transactions, that only the best people in your office will recognize.