CONFESSIONS OF A
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:

  • 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

Confessions of a Money Launderer - Part 73
Confessions of a Money Launderer - Part 72
Confessions of a Money launderer - Part 71
Confessions of a Money Launderer - Part 70
Confessions of a Money Launderer - Part 69
Confessions of a Money Launderer - Part 68
Confessions of a Money Launderer - Part 67
Confessions of a Money Launderer - Part 66
Confessions of a Money Launderer - Part 65
Confessions of a Money Launderer - Part 64
Confessions of a Money Launderer - Part 63
Confessions of a Money Launderer - Part 62
Confessions of a Money Launderer - Part 61
Confessions of a Money Launderer - Part 60
Confessions of a Money Launderer - Part 59
Confessions of a Money Launderer - Part 58
Confessions of a Money Launderer - Part 57
Confessions of a Money Launderer - Part 56
Confessions of a Money Launderer - Part 55
Confessions of a Money Launderer - Part 54
Confessions of a Money Launderer - Part 53
Confessions of a Money Launderer - Part 52
Confessions of a Money Launderer - Part 51
Confessions of a Money Launderer - Part 50
Confessions of a Money Launderer - Part 49
Confessions of a Money Launderer - Part 48
Confessions of a Money Launderer - Part 47
Confessions of a Money Launderer - Part 46
Confessions of a Money Launderer - Part 45
Confessions of a Money Launderer - Part 44
Confessions of a Money Launderer - Part 43
Confessions of a Money Launderer - Part 42
Confessions of a Money Launderer - Part 41
Confessions of a Money Launderer - Part 40
Confessions of a Money Launderer - Part 39
Confessions of a Money Launderer - Part 38
Confessions of a Money Launderer - Part 37
Confessions of a Money launderer - Part 36
Confessions of a Money Launderer - Part 35
Confessions of a Money launderer - Part 34
Confessions of a Money Launderer - Part 33
Confessions of a Money launderer - Part 32
Confessions of a Money launderer - Part 31
Confessions of a Money launderer - Part 30
Confessions of a Money Launderer - Part 29
Confessions of a Money Launderer - Part 28
Confessions of a Money Launderer - Part 27
Confessions of a Money Launderer - Part 26
Confessions of a Money Launderer - Part 25
Confessions of a Money Launderer - Part 24
Confessions of a Money Launderer - Part 23
Confessions of a Money Launderer - part 22
Confessions of a Money Launderer - Part 21
Confessions of a Money Launderer - Part 20
Confessions of a Money Launderer - Part 19
Confessions of a Money Launderer - Part 18
Confessions of a Money Launderer - Part 17
Confessions of a Money Launderer - Part 16
Confessions of a Money Launderer - Part 15
Confessions of a Money Launderer - Part 14
Confessions of a Money Launderer - Part 13
Confessions of a Money Launderer - Part 12
Confessions of a Money Launderer - Part 11
Confessions of a Money Launderer - Part 10
Confessions of a Money Launderer - Part 9
Confessions of a Money Launderer - Part 8
Confessions of a Money Launderer - Part 7
Confessions of a Money Launderer - Part 6
Confessions of a Money Launderer - Part 5
Confessions of a Money Launderer - Part 4
Confessions of a Money Launderer - Part 3
Confessions of a Money Launderer - Part 2
Confessions of a Money Launderer - Part 1
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