Footprint’s Post

This is NOT Fraud Advice--Cartel money laundering edition. If you want to learn about AML violations, you're likely learn more studying how the cartels move money than the FDIC resource center on AML violations. At first glance, things seem clean (at second glance, it is legally clean other than the whole cartel drug money thing). But then you'll find anomalies. Such as Minnesota sending more remittances to Mexico than Texas--pretty strange!! This is because the cartels use a series of "money mules" both in the US and then in Mexico to send an astronomical amount of small remittance payments to and from often regular citizens before they get aggregated into cartel bank/crypto accounts. It's tricky to combat this. Simple KYC will not (these are real people not associated with the cartel). Transaction monitoring won't do much better (these are small txns--the $$ likely will not get flagged). How may we combat this? Well for one, we need to stop looking at fraud in the vacuum of individual companies. The cartels take advantage of the fact that these payments only look suspicious if you make a social graph equivalent of outgoing money payments (which is how officials noticed the Minnesota anomaly). Once we can see financial activity across accounts and not just in each individually, we'll begin making progress. Until then, keep studying the cartels to learn about AML law. They are very good at evading it.