Table Of ContentKevin Sullivan
Anti–Money Laundering in a Nutshell
Awareness and Compliance for Financial Personnel
and Business
Kevin Sullivan
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ISBN 978-1-4302-6160-5 e-ISBN 978-1-4302-6161-2
DOI 10.1007/978-1-4302-6161-2
© Apress 2015
Anti–Money Laundering in a Nutshell: Awareness and Compliance for
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To the members of the New York State Police and the El Dorado Task Force.
Some of the finest and bravest people on the planet.
Introduction
Many readers of this book may be involved with a financial institution as part of
an anti–money laundering (AML) program or government agency investigating
money laundering. As far as financial institution AML programs, I have found
that many of these programs do a great job covering the basics; however,
sometimes they lack in the area of truly explaining why the employee does the
specific job assigned. Sure, AML employees have learned to click this box and
select that radio button—a sort of “if this, then that” programing for AML
personnel. I have often enjoyed seeing that “light bulb” moment when I have
explained to AML employees the reasons why they click this button and select
that box. It helps to know a little about the nomenclature of money laundering,
what happened before a financial institution became involved, and how it came
to be that they have this incident report or alert currently sitting in front of them.
You should have at least a rudimentary understand what the bad guys did, how
they did it, and why they did it that way. You should be clear on how that
particular activity gave rise to an alert coming across the desk of an AML
employee in some small credit union in Smallville, USA, or a big-boy bank in
Manhattan. Further, understanding what happens after a financial institution
completes its mission and information is handed off will make your notation of
that information substantially more thorough and complete.
The other side of that coin stands law enforcement agencies and personnel
who understand wire taps, subpoenas, and pick-ups yet may have little
experience in how a financial institution operates. Knowing the ins and outs of
the Bank Secrecy Act and how AML programs are applied could be a huge asset
to law enforcement. It is a major asset for law enforcement to be familiar with
the methods of filtering, documentation, and record keeping at a financial
institution.
That leads into another important factor: the dynamics between the three
major players on Team Good Guy. The players are the financial institutions, the
regulators, and law enforcement. They each have various responsibilities and
perspectives. At times, they have been at odds with each other. However, from
my perspective, the dynamics have gotten much better over the last few years
with the introduction of the FFIEC manual, FinCEN’s new reporting forms, and
more communication across the board between the financial institutions,
regulators, and law enforcement. If 9/11 is the day that changed everything, then
we have come a long way in a relatively short period of time to bring all these
various money-laundering fighters together and zero in on the best way to fight
the battle.
With this book I hope to deliver to you some insight into various money-
laundering methods and an awareness of the AML process. You are now part of
a law enforcement money-laundering ride-a-long. I include real stories where I
can and offer my opinion based on my education and experience.
Acknowledgments
To the entire staff at Apress, who originally were
looking to do a mountaineering book on substantial
climbs but dialed a wrong number and got me. I
thought they said financial crimes, and here we are.
To the mountain climber stuck on the side of
Everest reading a book on money laundering and
wondering how the heck this helps him.
Seriously, though, the folks at Apress have been
great, and I thank you all.
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