Recently I wrote about starting out in AML. One of the first websites I found (and let’s remember that my AML education started before websites…) was Billy’s Money Laundering Information Website, which is still there. I am not sure when it was last updated, but the copyright notice mentions 2006, so perhaps that was it. It is good at explaining the basics but – like everything to do with money laundering – it goes out of date. To be honest, this is one of things I like best about this subject: it is a constant challenge to keep up, and challenges are good for the brain. (I will stop short of using that hackneyed saw of reality TV shows – that I have been on a roller-coaster journey – but you get the picture.)
And to underline this constant development, there is a steady stream of websites and webpages that appear in order to explain money laundering to us – as it is at the moment of publication. Back in 1998, when Billy’s website was born, it was all about placement, layering and integration. And the examples given were of their time: travellers’ cheques and postal orders, bearer share companies, shell companies and “off the shelf” banks. Thankfully most of these opportunities have been closed down for the launderer. But – like that arcade game Whac-A-Mole – they simply pop up elsewhere. So in the latest of these “how to” websites that I have spotted – “A Beginner’s Guide to Laundering Money”, written earlier this month by the editor of the National Post – the suggested laundering methods include gambling in Macau (and then sending your winnings via “a US trust managed by a shell company in Grand Cayman, owned by another trust in Guernsey with an account in Luxembourg managed by a Swiss or Singaporean or Caribbean banker who doesn’t know who the owner is”), over- and under-invoicing (to be fair, Billy suggested this back in 1998), and investing in diamonds. Thankfully there is optimism too, as the author notes that “the hard reality for launderers is that ‘good’ banks are harder to find every day, and so are jurisdictions providing complete anonymity [and] as a result, some very big fish are starting to get caught in the dragnet”. I wonder what the “how to” sites will be recommending in 2015 and beyond.
I hate money laundering 