AML CHALLENGES
EMERGING
“MARKET”
TRENDS
B
y now, certain shelf items have been labeled
with a stock keeping unit (SKU), been adver-
tised in circulars and placed out on display for
resale. With the science of inventory manage-
ment applied to market commodities for a quick
profit, the question is should the abuse or misuse
of these swiftly replenished items ever become
a consideration factor for the financial institu-
tion’s anti-money laundering (AML) monitoring?
When are sales and product turnover “too good”
and this deposited revenue indicative of the cus-
tomer acting as a money laundering conduit?
Could the financial industry be inadvertently mis-
interpreting a customer’s profitability as a banner
year instead of a surreptitious effort to sell to
customers on the black and gray markets?
14
ACAMS TODAY | SEPTEMBER–NOVEMBER 2017 | ACAMS.ORG | ACAMSTODAY.ORG