How can we stem the tide of dirty money flowing through financial institutions?
A Plan to Inhibit Significant Money Laundering Offenses and Improve Enhanced Due Diligence
About this whitepaper from Robert Mazur:
Take a very close look at the dozens of deferred prosecution agreements and indictments pled to by major banks when they’ve been accused of anti-money laundering failures. In nearly every case, those institutions were very happy to plead guilty to “intentionally failing to maintain anti-money laundering policies and procedures” or some similar criminal offense that proclaimed bad things happened because someone forgot to turn on the AML alarm system.
Former U.S. federal agent and court-certified AML expert Robert Mazur believes a new regulation is needed to truly fight money laundering and reduce financial crime.
“The AML vulnerabilities of our banking systems can be significantly reduced by developing a uniform industry-wide strategy to document what criminals and their intermediaries claim to have known and said when they established and maintained high-risk accounts at an institution. The providing of false information during the onboarding process, and subsequently, is critical proof of criminal intent. Absent creating a reliable method of capturing those representations, criminal intent is significantly more difficult to prove beyond a reasonable doubt. Those facts are also critical to consistently achieving a meaningful and effective strategy to conduct enhanced due diligence that enables an institution to effectively mitigate risk. This proposal offers that strategy in a manner that does not unnecessarily burden a financial institution or violate financial privacy. It will also act as a deterrent that will cause many sophisticated criminals to be more reluctant to attempt to launder proceeds of crime through our financial institutions.”