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Take On Payments, a blog sponsored by the Retail Payments Risk Forum of the Federal Reserve Bank of Atlanta, is intended to foster dialogue on emerging risks in retail payment systems and enhance collaborative efforts to improve risk detection and mitigation. We encourage your active participation in Take on Payments and look forward to collaborating with you.

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December 14, 2020

Fighting Financial Crimes outside Financial Institutions

Take On Payments is taking a short break and will return on January 4 in the new year.

You don't have to know anything about money laundering to know that it doesn't involve someone running a bundle of dirty cash through the washing machine, or even laundromats more generally. Well, it does, but only in the metaphorical sense. Money laundering refers to the act of legitimizing ill-gotten gains—that is, "cleaning" it to hide illegal activity. Anyway, we've touched on the topic of money laundering a few times in this blog, mainly focusing on how financial institutions might identify and report individuals acting as money mules. Today, I'm going to look at the types of businesses that are at risk of being used by money launderers.

Desmond Alston, my colleague in the Risk and Compliance Division at the Federal Reserve Bank of Atlanta and a Certified Anti-Money-Laundering Specialist, or CAMS, shares his expertise. Desmond explains that money laundering is a three- step process:

  1. Placement: Dirty money is placed into a legitimate financial system.
  2. Layering: The source of the money is concealed through a series of transactions, or layers of movement.
  3. Integration: Money is returned to the criminal from what appears to be a reputable source.

Any business that provides the capacity for this sort of manipulation—not just depository financial institutions—can be a conduit for money laundering. Desmond points out:

  • "Insurance companies can be conduits. A launderer can purchase a life insurance policy with a payment of criminally derived funds and then cancel the policy before a penalty would be applied or absorb a small penalty as a cost of the money laundering scheme. The resulting refund would be from a reputable source.
  • "At a casino, a launderer could use criminal proceeds to buy chips, hang around for a while, eat a hamburger, gamble a bit—or not at all—and then cash out."

That's why it makes sense for organizations in many industries—art and antiquities dealers, auto dealerships, travel agencies, and charitable organizations as well as financial businesses like foreign exchange, mortgage lenders, and money service businesses—to make sure staff members are knowledgeable about money laundering. If these sorts of entities fail to file suspicious activity reports, or SARs, for cash transactions that exceed reporting minimums, they are complicit in the crime of money laundering.

Nonfinancial businesses can protect themselves by employing the five components of a solid anti-money-laundering (AML) and compliance program: (1) written policies, procedures, and internal controls; (2) supervision by a designated compliance officer; (3) training and development for staff at all levels; (4) customer due diligence; and (5) independent audit of the AML program.

It's probable, however, that laundromats have no worries—they just don't have the cash flow. While early 20th-century mobsters did indeed intermingle cash from legitimate businesses like laundromats with cash from bootlegging and other crimes, they rapidly moved on to international accounts. The term "money laundering" was first widely used by journalists in connection with the financing of the Watergate burglaries in the early 1970s, when laundromats were not part of the picture.

Thanks, Desmond, for this helpful information.