Given the current position of America's regulators, that sponsor banks are ultimately responsible for the anti-money laundering shortcomings of their fintech partners, it is humbly suggested that they focus on imparting relevant knowledge to fintech compliance officers, regarding the money laundering techniques and methods that are known to be successfully employed to that specific sector of the financial services industry. Laundrymen often use shell and shelf companies, after artfully concealing beneficial ownership, to deceive busy fintech startups which are focused on expanding their customer base to reach profitable status. They bank on the eagerness of fintechs to attract new business, hoping that management will trump normal compliance concerns, when expanding that important client base. Money launderers also look for fintechs desperate to enlist strategic partners, for mutually beneficial business arrangements; under those circumstances, they are betting that fintech ownership may not look too closely at the background of partner ownership. Our concern is that proceeds of crime will be moved though the unsuspecting fintech, piggybacked with legitimate transactions. Who really owns that affiliated company? Often, fintech compliance officers are simply unaware of how advanced money laundering techniques, funneled through sponsor bank partners, appear at the their inbound end. It has become their responsibility to impart that tradecraft to them, even if it means regular training sessions at the fintech location, and not conducted virtually, so that message gets through of its importance. it may seem like an uphill battle, but unless a sponsor bank wants that unwelcome visit from regulators, exposing the fact that one fintech dropped the ball in a major matter, you must teach those generally inexperienced compliance officers how to spot specific money laundering methods in real-time.
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