Crime needs professional and financial services; if you are not fighting it, then you are part of it

Published first on LinkedIn – April 2019

This week in Vienna there is a meeting of those from across the world who are fighting the use of the internet, money laundering and criminal activity to fund terrorism. Pretty much a gathering of angels. They are stopping bad people from doing bad things to fund horror. But the biggest challenge is not the violence of these criminals, nor the appalling nature of their crimes, nor the social disruption and fear they create. No, the real problem is the vast armies of people aiding and abetting these crimes through professional negligence. These are people who believe that a little fiddling expenses or going above the speed limit on a motorway are the limits of their criminal involvement. But their neglectful lack of attention at the wheel of their business life allows them to be the means that makes such criminal enterprise profitable and possible.

So a brief run down on the process. Terrorism needs money. It gets it either from rogue states, or it has to earn the cash through criminal enterprise. So terrorists use expert criminals. The big margins are earned from a number of sources; illegal drugs, falsified medicines, human trafficking (an all-embracing euphemism for a collection of the most applying crimes), trading in illegal wildlife products, cybercrime, fraud, and extortion. These all overlap and they require the same skill sets. Terrorist do not often do this work themselves, they have subsidiaries or contractors who do it for them. A very limited proportion of the money that is earned can be kept and used as cash outside the spotlight of regulatory scrutiny. Most of it needs to enter the mainstream; it needs to be legitimised; it needs to be laundered. For that they need bankers, lawyers, accountants, compliant regulators and government officials operating in less-than-exacting regimes (or preferably where governments have been captured through bribery and corruption). These aberrant professionals do not hide. They operate in plain sight, usually covered by legitimate business connections and activity that provide sufficient coverage and explanation of wealth.

So while the global enforcers meet (the people who daily track down the funds and their couriers, face up to the most violent and amoral of men, and deprive them of the means to bring pain and death to the innocent) what do they need from the people delivering professional and financial services? Very simply, know your customer and know your colleagues. Dodgy customers need financial and professional services to be at best inattentive, and at worst complicit. Dodgy colleagues and fellow professional simply need you to accept their front without question.

We have got beyond the point of KYC being an exercise which we try to minimalise. Its thorough and deliberate use by the City professions must be a pillar of their purpose as companies and as human beings.

If you are inattentive, if you do not care what your client does provided they pay their fees and do not make their crimes obvious, then you are willing to be an agent of international crime, a profiteer from the slavery and sexual abuse of women and children, and facilitator of terrorism.

The Commission on Crime Prevention and Criminal Justice is meeting on 20-14 May in Vienna. To understand this world, follow Neil Walsh, Chief of Cybercrime, Anti-Money Laundering and Counter-Financing of Terrorism at the UN on LinkedIn.

Previous recent writing to be found here