TD BANK SCANDAL THROUGH A DIFFERENT LENS
The TD Bank scandal, the most recent earth-shattering case in the AML world, deserves a different analysis than what I've found in the mainstream media and AML publications.
Where do the problems lie? Is it really with an outdated AML transaction monitoring system as everyone seems to suggest, or does the problem go much deeper. Do the AML watchdog agencies share responsibility? To what degree do the senior executives of TD Bank have blood on their hands from the deaths of hundreds of thousands of Americans during the time that the bank and its employees laundered hundreds of millions in drug proceeds?
I took a close look at the pleadings in the TD Bank case and those related to their criminal clients. As a result, I offer you my unvarnished view of the most important facts about TD Bank's VIP treatment of their money laundering clients.
To those of you in the AML world that publish articles, you have my consent to re-publish my article, attributing me as the source of the article. In my view, it examines the facts through the prism of my 40+ years in the public and private sector battling money launderers.
I welcome your comments about my analysis:
Money Laundering Reporting Officer All views are my own and don’t represent those of my employer in any way. All connection requests from sales people will be rejected immediately.
9moVery informative
Senior Research Fellow at Hudson Institute and Co-founder of Sayari
9moTruly great article, Bob. You remain the best investigator and analyst of money laundering around.
I Defeat Money Laundering with Rational Thinking and not Compliance Red-Flags
9mo"Quit the game of blaming" If only had the power to name my book "The AML Blame Game and the Actors"... unfortunately I had to go with a diplomatic title "....compliance"
AML Sanctions Mgr Sr
9moThis is a feature or ‘bug’ of modern society that decision-makers are often the most protected from the (intended or unintended) consequences of their decisions.