A FORMER CAREER MONEY LAUNDERER EXPLAINS IT ALL REGARDING SUCCESS IN TRADE-BASED MONEY LAUNDERING

Inasmuch as most compliance professionals don't have a lifetime of experience in the identification of trade-based money laundering, like AVRAAM DEMETRIOU, I believe it is important for frontline compliance officers to understand how competent their TBML adversaries are, so that they govern themselves accordingly. Otherwise, the deck is, frankly, stacked against them.

First of all, many laundrymen who engage in trade-based money laundering have prior relevant industry experience, which affords them distinct advantages over bank compliance officers tasked with the identification of TBML. I remember attending an emergency Saturday hearing in Federal Court as a young bank lawyer, where it quickly became apparent that my opposing counsel had an extensive shipping background. Lawyers and accountants who have worked for freight forwarders, shipping lines, or law firms that handle maritime matters exclusively possess a familiarity with the industry that young compliance officers are sorely lacking, as they are dealing with a wide variety of client businesses.

Second, these TBML laundrymen generally have the ability to create legitimate-appearing documentation that, unless compliance takes valuable time to confirm, will pass muster every time, especially in the hurried environment of an international bank's compliance department, with deadlines on pushing out files, and ambitious junior compliance staff on the way up, conscious of their need to complete assignments not just on time, but actually ahead of schedule. That nasty end-of-day deadline on file reviews will result in TBML sneaking through every time, unless the compliance officer knows the tricks of the TBML "profession."

Finally, artful laundrymen in the TBML sphere apply money laundering tradecraft, used to penetrate other business sectors, which is usually missed by compliance officers intent on looking for industry-specific techniques. You are looking for apples, when your opponent is throwing oranges at you, and beating you.

Space doesn't permit further detailing of the winning TBML tradecraft; I have explained some of the tricks in prior articles, and if you require a tutorial on what to watch for, I can present a virtual seminar on those TBML methods for your compliance staff. Find me here: miamicompliance@gmail.com