Most bankers will only run into a few actual money laundering cases in their careers.  Thus, they are looking for money laundering but have very limited knowledge of what money laundering looks like and how to spot it.  To address this difficulty, I have developed a course that is different than any other AML training I am aware of.  We will start with a list of money laundering strategies actually found in use. This is based both on research and years of experience, including with a Federal Justice Department AML Task Force.  For each strategy, we will describe it and discuss the clues (Red flags) indicating its existence.  We will discuss each of the characteristics which can cause a transaction to be considered high-risk.  

For each strategy, we will describe it and discuss the clues (Red flags) indicating its existence. We will also discuss the characteristics which can cause a transaction to be considered high-risk.   

Money laundering continues to be a national concern.  High levels of drug-related activity and violence have drawn additional attention in the form of the AML Act of 2022.  The Act will up the power of FinCEN and change their role in implementing Customer Due Diligence. They have recently issued an important list of priority areas for enforcement.

Overall, perpetrators have adapted to banks’ efforts so banks cannot combat money laundering with yesterday’s methods. Software is widely installed to identify specific patterns and “unusual” transactions. But the launderers know this and are constantly striving to create new patterns where their transactions are designed not to be flagged. Like in a game of chess, the advantage goes to the side that thinks the most moves ahead.