John Wintrow

The Nexus between Organized Crime and Terrorism

By John Wintrow | March 15, 2018

In past articles, we have discussed the tactics, techniques and procedures used by transnational organized crime (“TOC”) and foreign terrorist organizations (“FTO”); however, we have yet to discuss the alliance between the two, including the role the financial industry plays. It is well-known in the law enforcement and intelligence communities, as far back as the 1970s and 1980s, that there are instances where a nexus exists between TOCs and FTOs. The term “narcoterrorism” is evidentiary…

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Terrorism Financing: Past, Present and Future

By John Wintrow | October 20, 2017

Recently, we observed the sixteenth anniversary of 9/11, recalling the tragic loss of life and the sustained terror threat that still exists. Numerous articles pertaining to the anniversary have been published; however, little has been written from a financial crimes perspective. In this article, we will recall what was believed to be one of Al Qaeda’s (“AQ”) primary means of funding its operations, discuss the current state of terrorism financing, and take a glimpse at…

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Developing an Anti-Money Laundering Transaction Monitoring Strategy

By John Wintrow | June 13, 2017

Are all rules created equal? How do you design effective transaction monitoring rules that are capable of capturing the vast majority of money laundering and related illicit activities? In this post, we take a closer look at a US financial institution’s (“FI”) AML transaction monitoring environment. Specifically, we examine how an FI can ensure comprehensive transaction risk coverage by utilizing a targeted top-down approach in the development of its monitoring rules. Crafting precise and simultaneously…

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Transnational Trade-Based Money Laundering

By John Wintrow | December 28, 2016

Transnational Trade-Based Money Laundering (“TBML”) constitutes one of the most challenging and malevolent forms of money laundering to investigate. According to Immigration and Customs Enforcement (“ICE”), “Criminal organizations frequently exploit global trade systems to move value around the world by employing complex and sometimes confusing documentation associated with legitimate trade transactions.” The flagrant volume of the criminal activity has resulted in ICE establishing the Trade Transparency Unit, designed to target transnational trade-based money laundering worldwide.…

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