I'm honored to be an instructor for a new on-line course; "Understanding AML/TBML to fight Kleptocracy, Illegal Trade, and Financial Crime."  The ten approximately 75 minute modules will begin Tuesday, April 6.  They will run every Tuesday and Thursday ending May 6.  The course is offered by George Mason University's Schar School of Policy and Government.
I'm delighted that Ms. Lakshmi Kumar will join me as co-instructor.  Lakshmi is the Policy Director of Global Financial Integrity.  We are also fortunate to have a special guest speaker, David Luna.  David directs the Luna Global Network of Convergence Studies.  He is a former U.S. diplomat and national security official. 

We did a similar course in the fall of 2020.  The course proved to be so popular we are offering it again with a slightly different focus along with some tweaks and updates.

The link to on-line registration including a syllabus of the course subjects, fees, and other details can be found here:
schar.gmu.edu/prospective-students/programs/executive-education/understanding-aml-tbml-to-fight-kleptocracy-illicit-trade-and-financial-crime-executive-certificate-program

Further questions?   Interested in this program? Contact Sisi Jou at [email protected].

A few days ago, the Financial Action Task Force (FATF) and the Egmont Group of Financial Intelligence Units collaborated on a new report on trade-based money laundering (TBML).  The report updated the prior 2006 FATF report on TBML.   I was hoping for insight and a new direction forward.  But on the whole I was disappointed.  The paper discusses the same tired mantra of a rules based approach dealing primarily with filing  Suspicious Activity Reports (SARs) via trade finance.  That's probably because the FATF has always focused on financial intelligence as the panacea and also because Egmont helped draft the report.   While trade-finance is important, the great majority of international trade is open account and/or between the same multinational group.  The money transfers are automatically processed.   There is no document review and SARs will not be filed.  For example, according to recent numbers released by Treasury's FinCEN, less than 1% of all SARS filed over the last five years have dealt with TBML.   In my opinion, the report gave little attention to enforcement.  The report did not mention trade transparency units (TTUs).  I couldn't find mention of China or India - two of the largest players in TBML.  There were some nice case examples but they were from the usual contributors.  I don't think any new ground was broken. However, I was pleased to note they did have a short section on Service Based Money Laundering (SBML) - correctly noting that SBML is not TBML.   I didn't see anything about a possible FATF recommendation covering TBML.  In my opinion, until and unless FATF incorporates a new recommendation devoted specifically to TBML nothing is going to change.  In the world of AML/CTF the FATF makes things happen.  Unfortunately, the new FATF report will not be the catalyst for needed change.  The new FATF TBML report can be found here: www.fatf-gafi.org/publications/methodsandtrends/documents/trade-based-money-laundering-trends-and-developments.html

On December 9, I was honored to testify before the Cullen Commission.  The Commission was established to examine the "Vitoria model" of money laundering in British Columbia.  This occurs via capital flight, gaming, trade-based money laundering and value transfer, and underground financial systems.  I submitted a written statement.  Most of my remarks were focused on trade-based money laundering. My 3.5 hour oral testimony can be found here: cullencommission.ca/webcast-archive/    Click on the December 9, 2020 broadcast.

I am honored to collaborate with George Mason University's Schar School of Policy and Government to put together a course on Illicit Finance and Trade Based Money Laundering.   The course is going to take the form of an "Executive Webinar."   I'll be teaching the course along with my friend and colleague, Lakshmi Kumar.  Lakshmi is extremely talented and is an engaging speaker.  She is the Policy Director for Global Financial Integrity.   Lakshmi and I will be offering ten 1 hour modules on various topics related to trade-based money laundering.  Starting the week of October 20, 2020, there will be two webinars a week for five weeks.   If interested, contact me and/or see the below link for further information:
https://secure.touchnet.com/C20788_ustores/web/product_detail.jsp?PRODUCTID=1555&SINGLESTORE=true

I was honored to join a prestigious panel discussing trade-based money laundering.   The August 4 webinar was hosted by former Congressman Robert Pittenger.  He currently heads the Parliamentary Security Forum.  The approximately 100 minute video is found here:  pittenger.zoom.us/rec/share/zM5OA_bSx09Iebf38X7Dfu09AorqX6a81yNL-vcFxRxoaqf-YwVzpP_GfAaQDClo?startTime=1596548573000    I'm on about the 37 minute mark.   I found the panelist remarks very informative.  I hope you enjoy!

I'm honored to join TBML experts Ross Delston, Dom Semesky, and Kim Manchester July 15 at 1000 hrs EST to discuss new developments in trade-based money laundering.   The one hour webinar is FREE and is being hosted by Manchester CF.  I have so much respect for my fellow panelists and we are hoping to make it a free-wheeling conversation with lots of insights.  Here is the registration link:  ​https://www.eventbrite.ca/e/tbml-roundtable-tickets-110682913574

My new book, Money Laundering and Illicit Financial Flows: Following the Money and Value Trails, is now available via Amazon.    This is my fifth book.  I still get excited with a book release!   I am interested in your feedback particularly because in the world of AML, this book breaks some new ground.   I hope you like it! 

Bank compliance officers are well aware of anti-money laundering (AML) “look-backs.”  A look-back might result after a period of lax compliance and repeated warnings by regulators triggered perhaps by evidence of suspicious transactions not reported or internal procedures not followed.  This type of reactive look-back is inherently negative.   A proactive look-back, on the other hand, is positive.  Undertaken in response to self-initiative, a look-back can identify issues that need to be corrected and recommend positive action.   That is exactly what my goal is for my new book, Money Laundering and Illicit Financial Flows: Following the Money and Value Trails. I have investigated and studied money laundering and related subjects for 30 years.  So this book is a roughly a 30 year proactive look-back on money laundering methodologies and our AML policies and actions.  The book is designed to be a candid proactive appraisal that will result in recommendations and steps forward.  I promise to tell it “like it is.”  I can't cover everything.  I'm selecting topics of particular concern.  Written primarily from an enforcement perspective, chapters include Sobering Statistics, Money Laundering Basics, Illicit Financial Flows,  Bulk Cash Smuggling, Trade Based Money Laundering, Alternative Remittance Systems, Real Estate, Illicit Tobacco, Misuse of the International Gold Trade, China - the Biggest Money Laundering Threat, Technology, Enablers, and More Forward Steps.   The book should be out in another ten days or so.  It will be available via Amazon in both soft cover and e-versions.   This is the first book on money laundering to be released in years.  It's a bit different. . . Please let me know if you like it!  Thanks!

I’m excited about my new book, Money Laundering and Illicit Financial Flows: Following the Money and Value Trails.  It should be released in early May, 2020.  It is the first new book on money laundering in years.   This AML book is different than most as it the first book to take a hard look at our AML track record.

I started my work in AML enforcement 30 years ago.  Written primarily from a law enforcement perspective, the book examines old and new money laundering methodologies.  It exposes threats, enablers, and facilitators.  Making the case for an AML paradigm shift, the book offers alternative steps forward. 

AML is a broad topic. I can’t cover everything.  I’m selecting topics of particular concern.  But the book is designed to be a candid pro-active “look back” and appraisal.  I “tell it like it is.”

Chapters in include:   Why Laundering Matters; Sobering Statistics; Money Laundering Basics; Illicit Financial Flows; Bulk Cash Smuggling; Trade-Based Money Laundering; Alternative Remittance Systems; Real Estate; Illicit Tobacco; The Misuse of the International Gold Trade; China: The Biggest Money Laundering Threat; Technology: Cell Phones and Cyber Laundering; Enablers; and More Forward Steps.

I combine facts, straight-forward explanations, case studies, as well as my personal experiences, views and commentary.   I think you will like it!  

​ The book will be available via Amazon in both hard cover and e-version.

Over the last year plus, I've been slowly working on a new book.  The working title is "Money Laundering and Illicit Financial Flows:  Following the Money and Value Trails."   The manuscript is almost complete.  I anticipate the book's release by May 1 of this year.   I'm excited about the project.   I'll have more details in later posts.