One of my day job tasks is Money Laundering Compliance Officer. As a job title it’s up there with Actuarial Assistant and at the opposite end of the scale from Lion Tamer.
A greater challenge than the job itself is delivering the anti-money laundering training to other staff that is necessary. Like, how can you make obtaining client ID and address verification interesting? How can you make it relevant to staff who might have other ideas of what is interesting? How can you put that stuff into context?
Well I’ll have no problem next time around. Did you know that there are presently more slaves in the world than ever existed in the past? Some estimates say 27 million, the majority of whom are women and children. Human trafficking is estimated to generate profits of $32 billion per annum. These are incomprehensible figures and can only be hammered home by attention to some of the detail.
A couple of weeks ago we in Jersey got a gut-wrenching close up thanks to a film shown in the course of the Amnesty International Film Festival. Through secret filming it took us into the vast red light district of Mumbai, into what are known as The Cages. With the help of a ‘lucky’ few young women who had been rescued we learnt the fate of some of those they’d left behind. Girls are worth money in India and neighbouring Nepal. Some are sold by their families. Others are taken from the streets or easily tricked and drugged. They are as young as seven. They end up in one of the countless brothels in the city.
They are told that they now work in the sex trade. They have no choices. Many initially refuse but are beaten, raped, degraded until they comply. They are expected to go with up to 30 men each day. There is no notion of contraception or medical care. Most end up with AIDS and have multiple abortions. There is no escape, unless you are one of the very small percentage rescued.
Under pressure from various international agencies the local police check the brothels for minors. A small but regular bribe sees them turn a blind eye. If they survive the girls are worn out and sick, still at a young age. By now they are institutionalised and have nowhere else to go.
The AVERAGE age of the girls in the Mumbai sex trade is 14. The film in question told of two sisters, new recruits who, knowing their fate, hanged themselves with their scarves. The title of the film is taken from the girls themselves – it is The Day My God Died. They have no childhood. One in three Indian girls never see their teens.
One 14 year-old daughter of a work colleague viewed the film and arrived home distraught, asking what she could do to help. Truly our kids here in the West are fortunate – as Amnesty say, they have already won the lottery of life.
So, stop the money laundering, stop the crime. If crime for profit doesn’t pay then it won’t happen. It’s sometimes a tortuous link but there is logic in there. So keep collecting those copy passports guys.
You can watch the film here http://topdocumentaryfilms.com/day-my-god-died/ go on, I dare you. (Edit Nov 2018 – sadly this film appears to be no longer available.)
Back On The Rock 
Won’t your trainees ask, “What’s the link between a back-street brothel in India and money-laundering?”
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I imagine they might. In this particular example trafficking would be wiped out if the trafficker thought that the proceeds of his/her crime would be confiscated and there was a prison sentence in the offing. Add to that a strong policing and justice system and you’d no longer have the issue on such a scale.
In the wider context, if economic crime becomes more trouble than it’s worth then it won’t happen.
Of course there are other variables, such as demand. The culture of certain sects in India sees nothing wrong in having sex with minors, and indeed sees it as a ‘good thing’. Whether that can be addressed I’ve no idea.
But no, I’m not clever enough to make the leap from a Mumbai brothel to a Jersey law office. This is an example of how criminally-obtained money feeds into the legitimate money system thereby enabling the continuing criminality.
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You have certainly hit on the answer to your AML training dilemma: find a crime that will outrage your staff and show them how your AML procedures are designed to prevent people making money from it. The link is quite easy: brothel-keeper makes money from selling young girls – pays it into his local bank/hawala dealer – no questions are asked about his line of business or source of income – he gets away with it. Put due diligence into the mix, and there you have a solution. (OK, so I’m wildly optimistic, but – as Roy says – add strong legislation, enforcement and punishment, and suddenly the risk/reward calculation for the brothel-keeper is changed.)
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Wow, Roy – it is absolutely heartbreaking, and I’m so glad you have written this novel since then. Great work to raise awareness. Here in BC, 2 days ago a big money laundering case that has gone for 2 years, just fell apart. So important to follow the money and get people behind this inhumanity and evil into jails.
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