Fighting the Last War

The Wall Street Journal had an article on Wednesday saying “New York’s top banking regulator is set to publish on Thursday strict and long-awaited anti-money-laundering regulations to take effect in 2017.”

You can read the statement from DFS here. Essentially it places the onus on the financial institutions (like Goldman Sachs, Deutsche, and others) to report on themselves.

In the WSJ article, the head of DFS stated:

“Management must set the tone of compliance from the top so that message is disseminated throughout the enterprise,” Ms. Vullo said. “With this new regulation, New York will lead both in the fight against terrorist financing and money laundering and in providing useful guidance to our regulated institutions.”

We are always fighting the last war. These were steps that should have been taken 20+ years ago after Bank of New York and the fallout from that, if not earlier.

And we are still only treating the symptoms. All the regulations in the world will not stop the illicit movement of cash. In the 70s, 80s, and into the 90s, people were moving money across borders in bags. I even came across a story a few weeks ago about a man in the mid-2000s who was still doing the same using his private airplane. And it would not surprise me if it was still happening.

Meanwhile, the professionals who are laundering money have adapted and moved on into new technologies. And they likely changed tactics about a decade ago, if my research is correct. And our law enforcement is only now waking up and reacting to it. It will take years to fully understand the damage done by the new ways of moving money, and law enforcement’s failure to react in a timely manner.

And so we’ll have more inquiries and finger pointing, but never find the real culprits. And we’ll just keep trying to treat the symptoms.


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