I often speak to state and local law enforcement groups around the country about money laundering and threat finance. In my introductory remarks I generally ask the following question; “Who here has ever worked a money laundering/ financial crimes investigation? Perhaps ten percent of the group responds positively. I next ask, “Who here is familiar with the kind of financial intelligence available from Treasury’s FinCEN and who uses it?” Invariably only a few hands go up.
This is admittedly an unscientific sampling but the results have been consistent. Generally speaking, state and local law enforcement are woefully ill-informed about money laundering and the tools available to them to help identify and combat it.
There are a myriad of reasons for the lack of knowledge and expertise. Some have been discussed in other steps in this series including failed management syndromes, fixation on the quick statistic, lack of data and analytics, etc.
One thing that amazes me is that for the seeming majority of the law enforcement personnel that I speak with they never really stop to think about why criminals and criminal organization engage in crime. Of course, it’s all about the money. Criminals are motivated by greed. They don’t traffic in drugs, or people, or counterfeit goods, or stolen cars just for the sake of the illicit act. They commit crimes for money. Unfortunately, many of my law enforcement colleagues get fixated on the crime itself. Their investigation ends with the arrest and/or the seizure.
I urge them to always remember to ask the next question, "What about the money?”
So in order to rejuvenate our stalled anti-money laundering efforts, we must do a better job of training state and local law enforcement officers on what money laundering is and how to follow the money and/or value trail. We also must do a better job of getting financial intelligence and advanced analytic tools into the hands of analysts and investigators that can use it at the state and local level (see step 6). In this era of budgetary cut backs this will be hard, but there are some excellent training programs out there that don’t cost that much money but pay huge dividends.
The metrics show that feds simply can’t do the job. We need reinforcements from the state and local level. Not only that, it is precisely at the local level where we should be able to better identify criminal activity that is the predicate offense for money laundering.
Well, that’s it; scroll back to review my seven point plan to revitalize and re-prioritize our efforts to combat money laundering.
1. Develop a Strategy
2. Accountability
3. Close the Revolving Door
4. Revitalize Treasury Enforcement
5. Change the Incentives
6. Data and Analytics are our Force Multiplier
7. Better Empower State & Local Law Enforcement
I would love to hear your views!
This is admittedly an unscientific sampling but the results have been consistent. Generally speaking, state and local law enforcement are woefully ill-informed about money laundering and the tools available to them to help identify and combat it.
There are a myriad of reasons for the lack of knowledge and expertise. Some have been discussed in other steps in this series including failed management syndromes, fixation on the quick statistic, lack of data and analytics, etc.
One thing that amazes me is that for the seeming majority of the law enforcement personnel that I speak with they never really stop to think about why criminals and criminal organization engage in crime. Of course, it’s all about the money. Criminals are motivated by greed. They don’t traffic in drugs, or people, or counterfeit goods, or stolen cars just for the sake of the illicit act. They commit crimes for money. Unfortunately, many of my law enforcement colleagues get fixated on the crime itself. Their investigation ends with the arrest and/or the seizure.
I urge them to always remember to ask the next question, "What about the money?”
So in order to rejuvenate our stalled anti-money laundering efforts, we must do a better job of training state and local law enforcement officers on what money laundering is and how to follow the money and/or value trail. We also must do a better job of getting financial intelligence and advanced analytic tools into the hands of analysts and investigators that can use it at the state and local level (see step 6). In this era of budgetary cut backs this will be hard, but there are some excellent training programs out there that don’t cost that much money but pay huge dividends.
The metrics show that feds simply can’t do the job. We need reinforcements from the state and local level. Not only that, it is precisely at the local level where we should be able to better identify criminal activity that is the predicate offense for money laundering.
Well, that’s it; scroll back to review my seven point plan to revitalize and re-prioritize our efforts to combat money laundering.
1. Develop a Strategy
2. Accountability
3. Close the Revolving Door
4. Revitalize Treasury Enforcement
5. Change the Incentives
6. Data and Analytics are our Force Multiplier
7. Better Empower State & Local Law Enforcement
I would love to hear your views!
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