Welcome to Technical Post # 7: The Complicit Employee. This is one of a money launderer’s better tools. From the planted to the duped to the turned – they come in all shapes and sizes. But in the end, they all enable the launderer to bypass an institution’s safeguards or policies. The most common is […]
Welcome to Technical Post # 5: The Three Stages of Money Laundering OK, many of us have seen movies or TV shows where counterfeiters throw money into large dryers with poker chips or dice or some other items to make the bills appear to have been out in circulation when in fact they’ve just been […]
Welcome to my first topical post “What is Money Laundering?” Well, money laundering, quite simply, is the process of making dirty money appear clean. The Financial Action Task Force, FATF for short, is the multinational body that sets the global tone for AML efforts. Formed in 1989, it is based in Paris. Its working definition […]
To begin, I would like to clear up a few misconceptions about these two money laundering terms. First, they are NOT synonymous. Smurfing is often a method employed to structure transactions, but many a financial institution’s “structuring” reports have nothing to do with smurfs. Second, while it is likely true that structuring is, by far, […]
Welcome to Technical Post # 6: Refining Obviously, one of the challenges for a drug dealer is physically handling the money. The fewer bills in play, the fewer counting, handling, moving and storing issues one faces. That was a major reason the United States took all denominations over the $100 bill out of circulation 40 […]
It can be easy to understand the impact of money laundering on the initial victims – those who lost funds as a result of the predicate crime – but there can be an even deeper, more lasting effect on society as a whole. While some fear that Anti-Money Laundering (AML) efforts can have a damaging […]
On Friday (12/4), I delivered a presentation to over 100 lawyers during an all-day seminar they were attending for their continuing education requirements. My segment ran about 30 minutes. The rest of this blog is a reprint of my comments. My profile on LinkedIn (Paul Freeman, CPA, CAMS) has the PowerPoint presentation that accompanied it, […]
