Chef’ s final thoughts
AML pros need to think like rival chefs— not just tasting the final dish but breaking down every layer of prep that went into it. This recipe is not just a guide to laundering; it is a blueprint to understanding modern-day money laundering.
Understanding each step expands the ability to analyze each transaction from a goal perspective. Using this goal base model, AML professionals can look at transactions from the perspective that someone may be trying to accomplish one or more of the following goals:
▪ Hide
▪ Transfer
▪ Convert
▪ Clean
▪ Spend
This way of sizing up transactions can help better identify detection points where the sauce thickens, where the heat drops and where the real flavors hide. For instance, spotting a sudden rest in the timeline or an over-garnished fake business is like catching an oversalted risotto: It tells you someone is covering up mistakes.
To catch a five-star launderer, you need to analyze every step like you are judging Top Chef: Financial Crimes Edition— because the best money laundering cooks do not just serve, they deceive.
Bon appétit … in silence.
Paul Camacho, CAMS, vice president of compliance, Yaamava’ Resort and Casino, retired IRS special agent in charge,
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