Why are hundreds of billions of dollars in dirty money repeatedly found to have been pushed through some of the most respected financial institutions on this planet?

Given the massive resources that have been applied to maintain Anti-Money Laundering (AML) protocols, why has the law enforcement community, regulators, and AML professionals had very little impact on the $2 trillion or more that the United Nations on Drugs & Crime has estimated to be laundered every single year?

This is unacceptable, and conducting AML policies and procedures as usual is not the answer.

Take a very close look at the dozens of deferred prosecution agreements and indictments pled to by major banks.

In nearly every case, those institutions were very happy to plead guilty to “intentionally failing to maintain anti-money laundering policies and procedures” or some similar criminal offense that proclaimed bad things happened because someone forgot to turn on the AML alarm system.

One thing we rarely see in these pleadings is the identification of the individual or individuals that were responsible for concealing and disguising the true ownership or source of funds.

Was the accountholder, the accountholders intermediaries, or a bank employee responsible for moving illicit fortunes through the bank?

According to most pleadings, this just mysteriously happened because of a systems failure. I believe there is something simple we can do to ebb the tide of seeing bank shareholders finance massive fines, and never figuring out the “who done it”.

In an effort to create a line of breadcrumbs that will later lead to individual responsibility, I have prepared a whitepaper I’d like to share with anyone interested in reducing financial crime and fighting money laundering.

In part this is necessary because anyone that is being honest with themselves knows that public access to meaningful registries exposing beneficial ownership of front companies will never happen.

I hope to find leaders in the law enforcement, regulatory, and banking sector that would be willing to participate on a committee that would assess my proposal, attempt to craft it into a regulation, and offer it to legislators for enactment.

I’m sure there will be some that say this isn’t necessary, but if not this, what new idea can the committee develop that will make a difference.

New ideas are desperately needed because business as usual is not making a difference.

So I put down my thoughts in a whitepaper, “A plan to inhibit significant money laundering offenses through improved enhanced due diligence”.

To read the full whitepaper click here.

Robert Mazur, a federal agent for 27 years, is a court-certified expert in money laundering-related matters in both the U.S. and Canada. He is the New York Times bestselling author of “The Infiltrator,” a memoir about the first half of his life undercover as a money launderer within Pablo Escobar’s Medellin Cartel, and was an executive producer of the film by the same name. His new book, “The Betrayal,” is a memoir about his final undercover assignment, a deep dive into Colombia’s Cali Cartel and Panama’s underworld that nearly cost him his life. He is president of KYC Solutions, a company that provides speaking, training, consulting and expert witness services globally.