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CONFESSIONS OF A
MONEY LAUNDERER by Kenneth Rijock
MONEY LAUNDERER by Kenneth Rijock
Financial Crime Consultant, for World-Check
Confessions of a Money Launderer - Part 65
19 May 2008
As I continued to lecture, conduct training classes, and present at anti-money laundering and law enforcement conferences, I began to understand that the audience, whether they be compliance officers or law enforcement investigators, were reactive to money laundering, and not proactive to its identification and suppression. I realised that they were not anticipating emerging threats as they surfaced in the global financial picture. By the time they became aware that a new method of laundering, or new opportunity, or permutation or combination of an established scheme, had been employed, the damage had already been done. I sensed that I had found my niche; increasing their level of sensitivity and awareness to current events as the instrument upon which imaginative money launderers practise their profession.
What I did was to expand the level of consciousness of my audience, so as to allow them to fully grasp the dynamic exercise that is opportunistic money laundering. I did this by opening their eyes to the intellectual aspects of the craft:
He must imagine himself as the launderer looking for a way to move money through the bank, and set measures in place to either identify the acts, on a real-time basis, or close the gaps in the system to foreclose anyone taking advantage of them.
It's a serious game, but if you focus on how money laundering could happen to you, it is possible to erect sufficient barriers to either discourage and deter the financial criminal, or catch him or her in the act.
Next week: More actions against the Bad Guys.
- Money Launderers are constantly focused upon the global media, for it is through that invaluable asset they learn of what are referred to as targets of opportunity. These may be political or economic situations, emerging industries or products, weaknesses or vulnerabilities exposed, legal loopholes or opportunities created, whether intentionally or accidentally, through operation of law, or other developments that might make a clever money laundering scheme that will not be discovered or intercepted by law enforcement or the financial community.
- These opportunities are often found in obscure or arcane locations, such as advertisements, small wire-service articles about faraway places with new laws, press releases and other esoteric media. All may contain a small note that the money launderer capitalises upon to work a new scheme unnoticed by law enforcement or the financial community.
- For example, whenever an Eastern European nation announces that it is a candidate for entry into the Euro-zone, money launderers move in early on to place the proceeds of their client's criminal profits inside that country, knowing that, when conversion to the Euro occurs, the local government will have neither the political will, nor the law enforcement resources to vet the source of funds on all its citizens come conversion. Nor does it want to, because it encourages all that money to come out of the mattress and into the economy. The launderer may also buy a number of cash-intensive businesses pre-Euro, and pump them up for later sales when the laundered "profits" can be taken in Euros.
- Should local newspaper articles in a developing country remark on the total absence of money laundering prosecutions, notwithstanding active anti-money laundering and counter-terrorist financing laws, a money launderer, after confirming the reason, be it corruption, a weak prosecutorial agency, or other vulnerability, may target that jurisdiction with large wire transfer activity.
- Reports of specific items of value confiscated from criminal elements, whether they be money launderers or their clients, in one US jurisdiction, can be adapted, and put to good use, on another continent. Money launderers always look at DEA, FBI and Secret Service seizure summaries for ideas. I am not the only person reading those in the Wall Street Journal each week, believe me.
- You may have noticed that my coverage of money laundering cases often delves into the actual trade-craft, the techniques and strategies employed by the arrested money launderer or client. I generally want to look at the arresting officer's affidavit to learn exactly what he found, and how he tumbled to it. Since many techniques are passed around, or used for more than one client, the odds are I will see it again somewhere, perhaps in the context of a compliance officer's question.
- The whole idea is to get the compliance officer to think like the money launderer, to place themselves in the shoes and mind-set of the adversary, and look for potential targets of opportunity as they present themselves. There may be opportunities due to geography, temporary economic conditions, bank staffing shortages , the opening of a new branch, any one of a number of specific vulnerabilities that the compliance officer may recognise as specific to his situation.
He must imagine himself as the launderer looking for a way to move money through the bank, and set measures in place to either identify the acts, on a real-time basis, or close the gaps in the system to foreclose anyone taking advantage of them.
It's a serious game, but if you focus on how money laundering could happen to you, it is possible to erect sufficient barriers to either discourage and deter the financial criminal, or catch him or her in the act.
Next week: More actions against the Bad Guys.
The facts and opinions stated in this article are those of the author and not those of World-Check. World-Check does not warrant the accuracy of any facts and opinions stated in this article, does not endorse them, and accepts no responsibility for them.
Read more in this exciting series
11 April 2010
8 March 2010
8 February 2010
24 January 2010
6 December 2009
27 September 2009
9 August 2009
3 August 2009
30 March 2009
9 March 2009
2 March 2009
22 February 2009
18 February 2009
26 January 2009
18 January 2009
11 January 2009
5 January 2009
29 November 2008
24 November 2008
17 November 2008
8 November 2008
3 November 2008
27 October 2008
20 October 2008
13 October 2008
4 October 2008
28 September 2008
20 September 2008
15 September 2008
15 June 2008
8 June 2008
1 June 2008
26 May 2008
19 May 2008
12 May 2008
4 May 2008
27 April 2008
20 April 2008
13 April 2008
31 March 2008
18 March 2008
4 March 2008
25 February 2008
16 February 2008
10 February 2008
3 February 2008
27 January 2008
20 January 2008
14 January 2008
6 January 2008
16 December 2007
9 December 2007
1 December 2007
25 November 2007
18 November 2007
11 November 2007
3 November 2007
27 October 2007
21 October 2007
14 October 2007
7 October 2007
1 October 2007
23 September 2007
16 September 2007
3 June 2007
27 May 2007
21 May 2007
6 May 2007
30 April 2007
22 April 2007
15 April 2007
8 April 2007
2 April 2007
24 March 2007
19 March 2007
12 March 2007
5 March 2007
25 February 2007
19 February 2007
12 February 2007
4 February 2007
28 January 2007
22 January 2007
15 January 2007
7 January 2007
2 January 2007
16 December 2006
10 December 2006
3 December 2006
27 November 2006
19 November 2006
11 November 2006
5 November 2006
29 October 2006
22 October 2006
16 October 2006
9 October 2006
2 October 2006
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