My life in financial crime-the jigsaw puzzle with no picture on the front of the box, and with missing pieces.
The European FIU who pulled us out of queues at passport control every time we entered their country to interview us about the charges against our business rather than reporting the accusations to the UK FIU.
The embassy that wouldn’t tell us if it was safe to travel to their country after their ban on online gambling, but invited us to try anyway.
The Eastern European business that was so grateful for our advisory role that they offered us an Israeli rocket propelled grenade launcher as a gift.
The European regulator who did not like the fact that my country risk assessment rated their country as medium low and wanted me to restate it as low risk.
The forty million capital investment from an interested party whose due diligence results only showed two years media history, worked out of a virtual office and never wanted to meet in person. Resulting in fraud report being submitted both at home and abroad.
The not so subtle threats from a paramilitary group after i had reported and closed a number of accounts i suspected could be related to people trafficking.
The meetings in a famous London hotel with a “finder and fixer” whose hourly rate was close to four figures and conversations reminiscent of scenes from spy movies.
Being summoned as a witness in a recent trial earlier this year as a result of a SAR i had submitted six years previously on behalf of a company that i no longer worked for, and which had since ceased to trade.
Those are only some of the strange things that i have encountered during my career working as a financial crime investigator or MLRO for numerous companies and highlights why AML regulations and systems are so ineffective in reducing the impact of the underlying crimes.
Co-ordination between EU member states and similar bodies is riddled with distrust and lack of training standards, the same can be said for financial institutions and the home country regulators. This is however, a world-wide problem as money laundering is a complex and ever changing phenomenon that does not fit the generally taught three stages principle of placement, layering and integration. It does beg the question though, has the risk versus reward of taking on the MLRO role now become unacceptable?
Law enforcement appear to ignore small crime to try and get to the top of the crime ring where the big players and big money move. They want to get to the bigger players and hope that they will turn faster than old milk.
Every SAR reported, names suspects but the probability is that over 90% of them are never investigated.
The global anti-money laundering system has failed and has not slowed or redirected the predicate crimes. I am certain that the major criminals would want things to stay as they are because it keeps us all ineffectually busy.
To use a Afghan Dari proverb, “there is a road to the top of even the highest mountain”. I am not convinced that we have started building the road let alone mapped the trail to its destination.
