Professional Money Launderers – FATF Guidance and a US criminal case

FATF’s report on Professional Money Launderers is a must read. The public version of the report was released on July 26, 2018 (wouldn’t we all love to see the non-public version!). In an ironic twist, the report team was was co-led by the delegations from Russia and the United States (HUGE collusion!). The Report does a great job of describing the techniques and tools used by the three types of PMLs: individuals, organizations, and networks of associates and contacts. There are sections on: the four types of dedicated money laundering organizations and networks; three supporting mechanisms used by PMLs; and five types of complicit or criminal service providers. And like many FATF reports, the 25 “boxes” or examples are very useful and add some color to the report.  Well done FATF! And after reading this … are lawyers and accountants high risk customer classes???

The report is available at

And just two days before the FATF report was issued, an indictment was unsealed in Federal Court in Miami charging 8 defendants with money laundering. A press release provided, in part:

“According to the criminal complaint, the conspiracy in this case allegedly began in December 2014 with a currency exchange scheme that was designed to embezzle around $600 million from PDVSA, obtained through bribery and fraud, and the defendants’ efforts to launder a portion of the proceeds of that scheme.  By May 2015, the conspiracy had allegedly doubled in amount to $1.2 billion embezzled from PDVSA.  PDVSA is Venezuela’s primary source of income and foreign currency (namely, U.S. Dollars and Euros). 

The complaint alleges that surrounding and supporting these false-investment laundering schemes are complicit money managers, brokerage firms, banks and real estate investment firms in the United States and elsewhere, operating as a network of professional money launderers.

The alleged conspirators include former PDVSA officials, professional third-party money launderers, and members of the Venezuelan elite …”.

The indictment can be found here: US v Venezuelans Money Laundering SDFL 18CR03119