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Countering Money Laundering : Compliance, Investigation and Management (Trainer: Ian Ross)

over 1 year ago by Ian Ross
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No money, no laundering!

Methods and means of disguising, moving or disposing of criminal proceeds have operated not for hundreds, but thousands of years. Records relating to the earliest activities of money laundering trace back to China in 2000 BC. ‘Traders’ fled the country and ‘invested’ in business transactions elsewhere. In those days (and even now) the concept of revenues from crime being someone else’s money probably didn’t register as such. The ‘what’s mine is mine’ maxim was harnessed in a way that those involved in ‘laundering’ would go to serious lengths to put those proceeds beyond the reach of authorities.

But the recognition of money laundering together with the acquisition of that title appeared in the United States in the 1930’s with Mafia-run activity, running launderettes to ‘launder’ proceeds of bootlegging and prostitution. Therefore, and one piece of criminal ingenuity later, we have Al Capone to thank for the term ‘money laundering’ from the 1920s and 30s gangster era in New York and Chicago.

In New York in the 1990’s, this was argued to be so in a weekly news column called ‘City Slang’ about the lively and speckled criminal vernacular of the city. But whatever the definitional debate is, money laundering has been an entity which over ensuing centuries has both evolved and spiraled.

A modern day truth is that money laundering is de-facto unmeasurable. True, there are annual reports, volumes of suspicious transactions reports, whitepapers, and crime stats, but these do not get beyond numbers of measures taken in different ‘ML’ contexts.

And what must be understood is that money laundering and terrorist funding are not the same thing.

But two key elements from an Ancient Chinese dynasty have not changed: either the movement or disguising of criminal proceeds – or both. Money does not need to ‘move’ to be laundered. And in keeping also, ‘money’ in money laundering can be gold, diamonds, crypto currency ….

Modern concepts of money laundering have been added, such as the placement, layering and integration stages of money laundering introduced to explain how criminals target the banks for money laundering purposes, as banks and other financial institutions became and remain the main targets for financial crime. Likewise modern additives of who is defined in risk terms as a potential facilitator of ‘enabler’ of money laundering, and ‘politically exposed persons’

So why this training? Countering money laundering is no longer a problem confined to law enforcement, or a crime that is randomized. It affects businesses, orgainsations, individuals every minute of every day. The methods get more advanced and those involved appear and evolve from all parts of society. Social and leisure industries are targets which would be unheard of only 10 years ago. All increasing the threats and the challenges to combat it.

- The first of our sessions for our new program, Countering money laundering: Compliance, Investigation and Management will be on Thursday 23 April 2020, Castille Learning, Floriana, Malta.

Keywords: Money Laundering: precision explanations, definitions and advanced concepts. Key underpinning ‘funding’ crimes, impacts, reading ML patterns. Overlaps with terrorism funding.