Forget the carrot – where’s that stick?

Years, nay, decades ago, when I started out in AML training, I vowed to myself that my training would be different.  It would not concentrate on money laundering penalties, or feature the phrases “clapped in irons”, “bread and water” or “say goodbye to your pension”.  No: my plan (to which I have stuck) was to concentrate on the why of money laundering and the why of anti-money laundering.  Make people care about money laundering, make them angry about it, and they’ll want to prevent it, I reasoned.  But it turns out that I might have been wrong.

Just before Christmas an article appeared on the Forbes website entitled “10 Ideas to Curb White Collar Crime” – catnip to me, as you can imagine, as I’m always on the lookout for nuggets of wisdom to pass on to MLROs.  And top of the list is this: “Ditch Ethics Training For Teaching Federal Sentencing Guidelines – Every white collar felon I [the article author Walter Pavlo, himself a white collar felon] talked to over the years, and I have talked to many, had never heard of the guidelines used to sentence people to federal prison for white collar crime.  People would make better decisions of choosing right over wrong when they clearly understand the consequences.”  So perhaps I shouldn’t skate so quickly over the penalties, with my usual, glib “…and fourteen years on offer for this one”.

This entry was posted in AML, Money laundering, Training and tagged , , , , , . Bookmark the permalink.

4 Responses to Forget the carrot – where’s that stick?

  1. Benjamin Stark says:

    Thanks for the article!

    I’m super interested to know if you’ve started looking into anything to do with electronic currency – such as bitcoin or the likes.

    Also, I work int he corrects space – do you have any info about the use of Poker Accounts or Gambling sites to easy transfer money and facilitate payments?


    On Mon, Jan 9, 2017 at 7:00 PM, I hate money laundering wrote:

    > ihatemoneylaundering posted: “Years, nay, decades ago, when I started out > in AML training, I vowed to myself that my training would be different. It > would not concentrate on money laundering penalties, or feature the phrases > “clapped in irons”, “bread and water” or “say goodbye to yo” >

    • Thank you for the comment, Ben, and welcome to the blog. If you use the Search box on the right and put in “bitcoin”, you will see that I have done a few posts on the subject. (I know that there are other forms of electronic currency, but Bitcoin serves as a sort of shorthand.)
      Best wishes from Susan

  2. Robert Long says:

    My problem with this idea, the teaching of the sentencing guidelines is that I don’t think knowing what sentence they will receive will be much of a deterrent IF they do not think they will get caught. Most criminals in more hands-on acts of knavery are well aware of sentencing guide lines, repeat recidivist quite able to predict what they are likely to receive for there perfidious conduct. They just never imagined they would be caught (even when we have managed that “extraordinary” feat before
    Anecdotal I know, but my experience leads me to strongly suspect of that a lot of white collar criminals believe themselves quite the genius and rather clever fellows. Even if they know they could get X amount of years, they will operate under the assumption that they will not be detected. That is discounting the ones who manage to convince themselves they aren’t doing anything wrong to start with or that the institution they work for would approve…

    (So I say your initial instinct was correct!)

  3. You’re on the money here, Robert – my instinct is that most criminals (and doubly so for white collar ones) are confident that they won’t be caught. And, as you say, add to this the ones who don’t actually think that what they’re doing would count as crime, and perhaps I’m not so wide of the mark. Which is a relief!
    Best wishes from Susan

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