The real truth about Georgian money laundering probably somewhere between the Russian claims that it is rampant, and Georgia's official statements that it is totally untrue, and purely politically motivated on the part of a hostile neighbor unhappy with a shift in Georgia's alliances.

What has been disclosed is as follows; We caution you that these are mere allegations that have not been independently confirmed, but, if found to be true, may spell trouble for international banks:

• Laundering activities of Georgian criminal organisations have transited Russia, Latvia and the United States.
  

• Expatriate Georgian nationals are involved in these illicit financial operations.
  

• The reputed kingpin has fled to France, and now resides in Monaco.
  

• The strategic aim of these laundering operations is to support what the Russians consider "terrorist" independence movements in breakaway Russian regions bordering Georgia.
  

Should any of the foregoing be true, MLROs and compliance officers in the EU and North America need seriously consider the implementation of certain enquiries with respect to their customers:

• Are there any major bank customers who are expatriate Georgians, and who conduct large international  business involving funds transfers ? If you have no idea which clients are from Georgia, perhaps an academic can supply you with common Georgian family names, or your bank counsel can engage a professional of Georgian extraction to assist the bank in reviewing your client lists. This is not profiling, but good compliance KYC practice.
  

• Have there been any funds transfers, in the few months, from those Russian banks whose licenses have been revoked by its regulators ? If you have been reading the World-Check articles since June, you know which ones I mean. If you are not up to speed, It is suggested that you access the article archives for this information.
  

• Have you seen any large funds transfers into Georgia this year ? Were they all supported by legitimate business operations ? Are you sure about Source of Funds ?
  

Good compliance officers investigate and identify possible problems. If the ethnic makeup of your bank
is diverse, you may have clients possibly engaged in funneling money to Georgia. Please confirm that it is not the proceeds of crime, to reduce the risk of reputation damage later on.