Moyara Ruehsen

This online workshop explores several areas of the professional financial crime fighting field, including law-enforcement investigations and prosecution strategies, government policy implementation and enforcement, investigations and compliance management at traditional financial institutions and fintech firms, public – private partnerships to address crypto crime, and multilateral agency efforts. All of these stakeholders have different approaches to investigations and different perspectives about compliance. We will also look at several sanctions regimes from the initial policy design to implementation, enforcement and compliance.

This course begins with an introduction to financial crime, beginning with traditional money laundering schemes, and then delves more deeply into financial crimes related to trade and investment, such as false trade invoicing, the black market “peso” exchange, the use of high value metals, and sanctions circumvention. Prevailing* laws, regulations and best practices will be reviewed. Students will look at a few case studies and learn how to spot “red flag” indicators, and conduct a simulation in class. This will require critical thinking. Students will also complete a take-home exercise involving visual presentation skills requiring the ability to convey a complex crime schematically.

This course is designed for students who hope to become financial crime specialists, or merely gain fundamental knowledge of financial crime risks and regulations. This expertise is useful for careers in public or private sector compliance, investigative analysis, trade finance, and security/intelligence.

Financial Crime Investigations & Compliance Management

This course is a follow-on to NPTG 8621: Introduction to Money Laundering and Trade-Based Financial Crime. It is designed for students who wish to pursue a career related to financial crime detection and prevention, whether in the government sector, private sector or multilateral agency.

The first part of the course covers all the elements of shaping an institution's financial crime compliance program, including AML, FCPA, OFAC and FATCA compliance. Students will develop their own risk scoring methodology for geographic risk and customer risk. We will also look at AML regulations and enforcement in other countries around the world.

Students will examine at what a number of multilateral organizations are doing like the Basel Committee Guidance, Wolfsberg Group recommendations, FATF blacklists and FATF mutual evaluations.

Many case studies will also be examined – both cases of banks behaving badly, as well as international criminal investigations – shedding light on how financial crimes are brought to light and how law enforcement can best investigate and prosecute.

Finally, any well-structured compliance program also has a system for escalating alerts for further investigation and reporting. In this class, students will review how to find and assess sources of evidence, spot red flags, and identify beneficial owners. Financial crime investigators, whether they be in the private sector or public sector, must master not only research skills, but also analytical and writing skills. For the final assignment, students will learn how to write up a suspicious transaction report with actionable intelligence.

Behind nearly every international crime involving money lies a money laundering scheme. In this course we look at how corrupt dictators, terrorists, drug traffickers, sanctions evaders, and North Korean cyber hackers, among others, hide and launder their ill-gotten gains. We will identify red flags of suspicious behavior and explore traditional money laundering techniques, trade-based laundering techniques, black market peso exchange, Chinese mirror trades, the use of virtual assets, shell companies, etc. There are no prerequisites for this course. What makes for a great investigator is curiosity, great research/analytical/writing skills, and broad knowledge about the world.