By John O’Neill

If you’re laundering money or financing terrorism, what keeps you up at night? 

Beyond the day-to-day intrigues of a life of crime, you have a money trail to worry about. Sure, you fear the sophisticated law enforcement and intelligence agencies with the power to track you, shut you down and put you behind bars. But what about the thousands of watchful eyes observing your money as it flows through banks, casinos, real estate and other covert financial conduits? 

Some of those eyes belong to trained bank employees – BSA and AML analysts, financial crimes investigators, compliance officers and many others – tasked with enforcing regulations meant to prevent exactly what you’re doing. Still, those individuals only investigate cases that have been discovered, so you and your fellow criminals rely on the surveillance that is meant to find you to be unsophisticated, burdensome and technologically behind.

Prosecution for financial crime can come at you from a number of directions. It is certainly true that many important cases are developed from whistleblowers and informants, undercover operations and referrals from other domestic and foreign law enforcement agencies. 

But far and away, the most fruitful investigative sources are the banks and other businesses that have a detailed view of financial transactions and which submit suspicious activity reports (SARs) and other forms to report potential financial crime. Financial investigations begin with these reports and end with convictions and the shutting down of networks.

The writer has worked in the tech industry – specifically AI and machine learning – for twenty five years and holds a PhD in chemical engineering.



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