A reader who read the last Chapter* enquired as to the amount of punishment, if any, meted out to the participants in the Ponzi scheme where I once worked, discharging my duties, but unaware of the covert billion dollar criminal activities of the principals. That's a fair question, and I will answer it, as well as to detail the present whereabouts of the fraudsters, as much as I could glean from the records of the US Bureau of Prisons. Where information is incomplete, there's usually a reason; prior or ongoing cooperation with law enforcement agencies; sentence reductions post-conviction quietly entered for what the US Sentencing Guidelines call Substantial Assistance, meaning testimony rendered to convict another, or to obtain criminal profits for the United States, for forfeiture purposes.

If you missed my lecture, at the FIBA Anti-Money Laundering Conference, on what it is like to work inside a Ponzi scheme, and then watch it self-destruct all around you, I will lay out here both the tactics of a practising Ponzi schemer, and the red flags (indicia) that such a fraud is occurring under your nose. Remember well that the president of that investment firm, who pled guilty, is now serving a 20-year sentence, the CFO, a female accountant (a single mother) received 5 years, the officer manager, attorney and several sales staff all convicted, and the principals, having already disgorged millions of dollars in illicit profits on the civil side, could eventually be imprisoned for the rest of their lives, when their pending cases are resolved a trial. This alone should confirm that the United States Attorney's office is seeking to send a message to potential Ponzi schemers; don't do it.

We last saw cousin Peter, extradited from Brazil after twenty three months in a squalid Brazilian jail,, finally being released from custody pre-trial, but into the restrictions of home confinement, not bail. Then, a strange thing happened; years go by, and his securities fraud case is not set for trial. Peter says it's because the US Attorney cannot put a finite dollar figure on the amount of damages suffered by the victims. But is there something else at work? Anyone who has the temerity to sue a former US President should understand that he has a lot of friends in the Department of Justice, and adding Hillary to the case might have offended certain individuals working in the US Attorney's office in New York. Whatever the reason, I know of no other recent case where a defendant, through no intentional dilatory action of his own, is waiting for trial for several years. Is not home confinement for four years some form of punishment?

The recent events in Haiti take me back to my experiences in that troubled country, especially after having seen that the place where I conducted lectures, and always stayed, the Hotel Montana, home to the United Nations staff, was destroyed, with victims still trapped and lifeless, inside. I have already written about that nation's new vulnerability to money laundering and financial crime. (See "Money Laundering opportunities Abound in Haiti Crisis," World-Check 16 January, 2010*) because all my time spent in Haiti was not, strangely enough, as a money launderer, but as a compliance and financial crime consultant, all before 9/11.

As you may have suspected, from time to time I was engaged to participate in what one might call alternative anti-money laundering matters. Sometimes this meant posing as a money launderer for an American law enforcement agency, and stinging some despicable narcotics trafficker. Other times it meant consulting in a civil matter, like the time I was retained to perform enhanced due diligence on a prominent Russian company that wanted to buy a large portion of a successful US medical device company. (It turned out that the Russian company was a front for ROC money laundering). Still other engagements involved conducting money laundering investigations which appeared to be for a civil client, but were probably for a governmental agency that didn't want to publicly be seen as making enquiries. Perhaps the most satisfying involved the opportunities to conduct what I call the "scared straight" seminar, because the preventive nature of the programme is unique. You may also call it "when bad things happen to good bankers."

When the investment firm that I was performing compliance officer duties for went into receivership, one of the firm's most productive sales executives asked me to step into a compliance role at a new start-up that he had decided to form. Since he was in the top tier at the firm, and had a large number of major European investors who had become his continuing clients, my job, as gatekeeper, would be to keep out the unsuitable ones. He was your typical overbearing successful A-type sales executive; obnoxious at times, but a proven producer of new business. We visited two established firms in our industry in Miami and in Canada, and were on our way to creating a viable entity, when he took in an old friend, with a "colourful" background as a partner, and that's where I drew the line. I am happy to be reporting on white-collar crime, in my articles, but I want no part of it as a participant. I got out quickly. Here's why.

It took the US Attorney five years from the date of the receivership order to indict the company's beneficial owners. In that time, they obtained guilty pleas, and most likely cooperation, from the firm's CEO, CFO, office manager, physician, and a number of senior officers who had high levels of culpability. They also obtained tax evasion convictions against sales staff. All these individuals can only earn a sentence reduction (5-20 year sentences currently being served) if they engage in what is termed Substantial Assistance, meaning that they assist in securing indictments against additional defendants, and/or help bring criminal profits and assets into the custody of the United States. You know exactly where this is going: the prosecutor, having now a number of senior company officers in custody and convicted, rolls them over on the company's owners, completing the construction of an ironclad case, with extremely damaging live testimony, overwhelming documentary evidence, and possibly even victims of the massive fraud.

Why was a receiver appointed to take over management of the company where I served as a compliance officer? It was later disclosed by regulators and law enforcement that the ownership and senior management were allegedly engaged in a massive fraud upon the investing public. Though many investors ultimately enjoyed high rates of return, (often in excess of 15 %) medical estimates of the life expectancies of many of the insured were allegedly improperly revised downward, to reportedly make the investments more attractive, and to increase profits. It appeared that only a few key company members were in on the fraud; most of the others, including yours truly, labored daily in total ignorance of this hidden agenda. The company was the largest of its kind in the world, placing investments in excess of $250m annually, and the life settlement industry, which deals with investments in the secondary market for life insurance, was shaken up by its court-ordered closure.

I spent a year as a compliance officer. How it came to an end is perhaps just as interesting as the details of the more colourful clients I have recounted in the past few chapters. If I didn't explain it before, the compliance officer job was offered to me based upon my experience as a money launder, not despite it. For that I will always be grateful to the owner of the firm, who wanted someone in the compliance division who could spot the financial criminals on a real-time basis, and deny them entry. Unlike others in the financial and legal community, he saw my experience as a valuable human resource. My job was to handle the problems, the potential clients who required enhanced due diligence. But let's get back to the story.

After settling in my job as a compliance officer specialising in enhanced due diligence investigations, I did my best to diffuse the already-existing adversarial relationship between compliance and new accounts staff. Most of the top producers were quietly critical of compliance, especially when they declined a major piece of new business that they were proffering, on behalf of what appeared to be a high net-worth new client. Whilst most did not engage in open trickery, there were a few who skirted the edge of "information management" in crafting their prospective clients' personal information for compliance review. However, I believe that they had no part in the serious efforts of top-flight money launderers to place dirty money with us. Well-constructed profiles, if created by experienced money launderers, generally pass muster with new accounts staff, who never dig beneath the surface, mainly because they do not want to see any warts on their new clients.

I started my new job as a compliance officer at the investment company, knowing that it was a global business, with clients around the world. Arriving at work every day before 7a.m., I was able to speak to clients and sales staff located in the Middle East, as well as in Eastern Europe. The offer was for me to spend four hours each day in the office, but it soon became apparent that I needed to be there all day, every day, just to keep up with the volume of new clients. I got the tough ones, the Colombians, the high net-worth investors, the corporations, the funds, even foreign foundations, elusive investors from faraway places, all the problem cases. Was it challenging? You bet, but by now, you know that I wouldn't have it any other way.

So how did I become a compliance officer in an investment firm that was later revealed to be a covert billion-dollar Ponzi scheme? And what happened after it was exposed by regulators? Let us start at the beginning. As a compliance consultant, I was often called upon to step in with little or no prior notice. One afternoon, a prominent Miami banking attorney who is a personal friend called up with a problem; he was scheduled to present a lecture on hedge fund money laundering the next morning at a conference on Miami Beach, but his firm had just ordered him to fly immediately to Argentina on urgent business. Since I am known for being able to speak at length, without notes, on most major AML topics, he asked me to take the lecture, to be presented early the next morning. If you've been reading this series since its inception in 2006, you know what my answer was; yes, of course. I took the offer as an intellectual challenge to be accepted.The programme organiser was a group from New York, and the conference took place at a boutique hotel on Collins Avenue. Arriving at the venue, I noticed that I knew one of the attendees, the director of compliance at a major investment firm located in Fort Lauderdale. She was there with the company's CFO, who was a certified public accountant .

See the article about the series in " From a Different Angle," appearing this Thursday.

Whilst serving as a compliance officer, whether it is ordinary due diligence or the enhanced variety, I often used investigative tricks to help to verify the client's personal information. Remember, never box yourself into a corner, with perennially fixed procedures, and nothing more, because innovative money launderers will test your compliance system, learn from your information requests and your responses, and adapt the next time, to pass your compliance, and gain customer entry into the bank. Remember my golden rule: money launderers who are denied accounts by approaching the bank through the front door will often use the back door, or even the trap door. This means disguising an associate, and dressing up his or her personal information, specifically to pass compliance scrutiny. They learn from their mistakes, and are highly motivated to try again at the same exact financial institution where they were formerly denied access. Call it ego, or perhaps due to pressure from their employers/clients, but good money launderers will repeatedly attempt to place a confederate in a specific bank or NBFI that they want to use for funds transfers, or for laundering of illicit cash.

One of the issues that I encountered as a compliance officer that was most troublesome was the 'creativity' of corrupt Politically Exposed Persons, or PEPs, all of whom wanted to place their funds of somewhat dubious origin. The tactics and tricks that they cleverly employ, whilst seeking to hide their illicit wealth, are difficult for most compliance officers to detect, but not impossible when you understand the techniques. What you need to have to uncover the truth is a healthy amount of cynicism when it comes to PEPs and an understanding of the typologies they resort to in their manoeuvres.

One of the most vexing problems that I encountered as a compliance officer is that of the arrogant and difficult client. We have all heard the horror stories; the billionaire client that new accounts cannot find, due to his constant globe-traveling nature; the distant customer who refers all queries for information to his even-more-distant law firm, which is located on the other side of the world; the looming client-set deadline for approval of the account, after which the wealthy client has threatened to go to our closest competitor; the affluent, but absent, individual whose new business would be a quantum leap in additional revenue for the bank, but nobody has met him yet. Whilst we do not focus on human relations issues in this series, it is important for compliance staff to recognise that some negative personality traits may just be clever ploys intended to deny critical information to the bank. One must exhibit patience with difficult clients, all the time never losing focus on the objective; vetting the client, irrespective of the hurdles placed in front of you. Is it really a difficult, demanding new client who brushes off your demands for additional personal information, or a criminal advised by a manipulative money launderer/fraudster? Perhaps a list of common techniques employed by the latter may open your eyes to their presence.

Today we conclude the methods of coping with the often adversarial relationship that I, and most compliance officers, have experienced when interacting with New Accounts, New Business, Account Relationship Managers and Sales staff at financial institutions, and several types of NBFIs. Whilst I often am generally quite critical of the-end-justifies-the-means viewpoint of New Accounts staff, I certainly recognise that they are not going to change. The secret is to handle them with tact, and to establish positive relationships with them as partners in the client approval process. At the same time, to thine own compliance profession be true. This means that you keep the Accounts people honest by catching their clever tricks, and those of their prospective clients, and acting swiftly to deny entry to such clients, and committing to memory the tricksters and manipulative staff who engage in "creativity" when it comes to personal customer information. I found that, after a while, the more intelligent new accounts people develop a grudging respect for you and your skills. They still don't like it when you kick out what might have been a lucrative client of theirs. Way back when, most businessmen accused lawyers of often being responsible for the death of a deal; now, since 9/11, the compliance officer frequently faces such negative criticism from the people responsible for generating business. Remember this, if they like you in New Accounts, you're probably not doing your job.

Confessions of a Money Launderer is on holiday hiatus until 5 January. If you haven't read all 81 chapters, this is your opportunity to catch up on the story. Thank you for your interest in Confessions. We will see you on 3 January. The compliments of the season.

As a compliance officer, I maintained a friendly, yet decidedly adversarial relationship with the new accounts staff. After a while, you learn who you can usually trust to give you accurate information that was not adulterated or created by sales as a means of securing compliance approval. You also know who those individuals are that are totally untrustworthy, and who will audaciously pervert the compliance process with manufactured personal data, which they believe will pass compliance scrutiny. The real problem people, in my humble opinion, are the staff who only from time to time. try to slip in a bad one, cobbled up to look acceptable. You just do not know, from one day to the next, exactly what they have sent over to compliance for vetting. Is this new client's information unchanged from what was originally submitted, or did they just make him look good? That's the human factor complicating what is already an occupational challenge; culling out the unacceptable risks amongst the new customers' files.

Whilst a compliance officer, I witnessed a wide variety of cute tricks, intentional disinformation, and even bold untruths contained in the applications from the prospective clients. The problem was, you never know how much of the client information was subsequently altered or doctored by the sales staff, either remotely, or in-house, so that they will pass muster with compliance. Your compliance training allows you to recognise information that is clearly inconsistent with the client's total picture, but the real challenge is to spot personal information that seems odd to your trained eye, and, using your analytical abilities, prove or disprove its truth and accuracy. That is where compliance advances beyond a learned skillset, and approaches a professional calling. Your ability to tie together a couple of seemingly authentic and ordinary answers to the clients' application and, after dissecting them, to either approve or decline the customer, is nothing less than an art, in my humble opinion. It must be learned over a period of time on the job, and cannot be taught. In law school, we are taught what is called issue perception, the ability to glean and extract the primary issues from a lengthy appellate decision. In compliance, there simply is no way to impart this focused analytical ability. You acquire it after reviewing many, many files; learning from your mistakes, and becoming sensitised to the nuances of new account personal information.

When I worked as a compliance officer, my short list of "red flags" consisted of the techniques that I personally used, or had observed other money launderers employing with a high degree of success. It was, at first, quite strange to see those tricks and clever gambits from the other side of the playing field, so to speak. I know that the financial criminals that I identified, and prevented from attaining client status probably never realised that a person who was formerly one of their own was reviewing their techniques, simply because I never considered it when I was working in that illicit industry. Whilst I never underestimated the abilities of compliance officers as a practising money launderer, I never conceived of the concept of a former laundryman working on the side of the banks. if I had known such a thing existed, I would have been forced to make major modifications in my strategies and tactics, abandoning the more simplistic tricks in favour of new methods. Not just old wine in new bottles, but totally new tradecraft.

Now on with the conclusion of last week's segment on how and why I testified against my clients. I went off to the minimum-security prison at Eglin Air Force Base, in the Florida Panhandle, with a four-year sentence. Gain Time, or time deducted from one's assigned sentence, is only 15% since the Federal Sentencing Guidelines became law in 1987. That meant I would be serving roughly 41 months in custody. This was not a very pleasant thought, understanding three and a half years of confinement. It was difficult to take, because I knew I was there because clients whom I had zealously (and recklessly) protected for a decade had put me there to lessen their own sentences. Since they had thrown me under the bus, my loyalty was gone, and that would represents a problem for the clients, as it was yours truly who had started a lot of their drug profits on a long journey into the tax havens of the world. I knew intimate details of their placement, layering and integration techniques, as I had created many of them myself. In short, I knew where the financial bodies were buried.

I want to digress a bit today, due to a comment I received recently during the Q & A at one of the New York seminars. The questioner bluntly asked me whether I was concerned for my safety, due to my chosen occupation, and wondered whether my cooperation with US law enforcement during my criminal case might be the real reason. That is a fair question, and if you have ever been to any of my lectures, you know that there is no question I will not answer, which I candidly did, but the underlying story was much too complex to explain, so I will do so here. Our readers have the right to the unvarnished truth, and to the realities of the criminal justice system, because if the unthinkable happens, and one is arrested for money laundering, whether guilty or innocent, my experiences may make their journey a little less frightening.

We return to my experiences at the compliance desk. For me as a compliance officer, it was all about efficiency, for the never-ending pile of files that were delivered to my desk daily had to be completed, and returned for processing after approval, unless there were issues with the prospective client, and then everything stopped, whilst I made my case for declining the client and his business. New accounts staff/client relationship managers would frequently call me up, or even drop in unannounced, to enquire as to the status of a particularly lucrative potential client's file. Just as many businessmen dislike lawyers, claiming that they always kill a transaction, sales staff often heaped anger upon the compliance staff, complaining that they rejected otherwise acceptable clients. I call it shoot the messenger.

When I was a compliance consultant, the new accounts staff at times seemed to be as committed to deceiving me into accepting unsuitable new customers, as I was in rejecting them. Was I just being paranoid, or were they really looking to fool me? I cannot say, because just when I wanted drop a claim of obstruction on one, he would come through with all the documents I had originally requested. Zealous sales practices I can tolerate, but when New Accounts/Sales tries to finesse the truth, I draw the line. The usual methods involve the use of business entities; if one is not careful, unwanted officers, directors, and even shareholders can make it past the gateway. You do not want to hear, two years later, that a law enforcement subpoena was served upon your company, naming an individual who is a client, or that you violated OFAC sanctions, or that documents were seized from an individual who has a minor relationship with your firm, following his arrest for major crimes. Catch them at the portal, please. Shall we return to business organisations, then?

What I found as a compliance officer is that I was not only matching wits with new clients, but also fending off clever techniques practised by the sales & new account staff, some of whom were determined to place money from customers who would utterly fail our due diligence. A few of the the new accounts people deliberately coached the client in their presentation of information, and supporting documents, so that they would be accepted, based upon bogus data or evidence that the customer relationship officer knew (or hoped) would suffice, based upon prior experience with compliance. Some of them actually resented the fact that I was doing an effective job, and caught their clients regularly in the act of submitting incorrect or untrue personal information, or that I refused to accept documents which purported to establish beneficial ownership. Many of the top producers were close friends with not only senior management, but the owner as well, and they wasted no time going to him over particularly lucrative new business that I declined. That's why I ended up actually going to the daily sales meeting, being literally Daniel in the lions' den. That way, if they had issues, I could be there to defend not only the compliance programme, but my own decisions and rulings as well. I also could offer tips on exactly what information and evidence would result in a positive result from compliance.

I found that I liked the compliance job very much; it was truly the flip side of my life as a money launderer. Whereas, in my earlier life, I was trying to move the proceeds of crime into the financial system, as a compliance officer my task was to deny the entry of which I believed to be criminal funds, funds whose provenance were suspicious, or funds from entities whose beneficial ownership could not established by the preponderance of the evidence. I used very objective standards in enhanced due diligence investigations, and demanded complete cooperation from new accounts/ customer relationship/sales staff, who received a short list from me of the exact documents and information we needed to approve the high-risk clients. At times, the staff who stood to gain substantially from our approval of their client would seek to influence me, or even take proactive steps to circumvent compliance, but I usually caught them in the act when I verified the information through my own devices. Naturally, once their subterfuge had been exposed, the staff members became quite sheepish, but never apologetic. They wanted those clients accepted by compliance, notwithstanding their dodgy nature. Did they resent me? You bet they did, but they also came to respect me, because I was totally on their side if the client passed muster.

I accepted the offer of a compliance position at the investment firm, with the understanding that I would be in the office daily for at least four hours. Though originally anticipated as a part-time position, I found that the heavy workload soon made it a full-time task. I made it my business to be in the office every day at 7 AM, so that enquiries from Europe and the Middle East would find me at my desk, and ready to respond on a real-time basis. I was responsible for the difficult customer identification files, from high-risk jurisdictions, or high-volume investors, or clients using corporations from tax-haven jurisdictions. I also got the ones that my associates could not find sufficient information on, and ones where the information was suspect, inconsistent, or otherwise found to be of a suspicious nature. For the first time, I learned about the direct and indirect pressures compliance officers face daily; first, there's the obvious pressure from New Accounts sales staff to complete and forward the files. Then, there's the pressure from your associates on a file, simply because they couldn't find sufficient information to accept or decline a file, or have a problem and need assistance. Finally, there's the pressure from senior management when Sales has a big one who is a bit dodgy, and the party who stands to make the most from approval of the client goes up the chain of command until he finds someone willing to seek to intimidate me into passing it.

Readers have asked me to relate the enhanced due diligence techniques that I employed in last week's chapter (Confessions of a Money launderer - part 70, dated 15 September, 2008), and this might also be a good time to also review the topic in detail. When several compliance officers get together to talk shop, and the subject of what is appropriate and necessary for the proper enhanced due diligence investigation in a customer identification programme comes up, there is generally a marked disagreement as to what one must do. If in doubt, follow this maxim: just when you think you have done all that you should, press on and continue, until you have either satisfied yourself as to the bona fides of the target, or you have found him to be an unacceptable risk. It's one or the other, and to do any less is simply not enhanced due diligence, in my humble opinion. Remember, I have been there, and know what you have to deal with every day: anxious relationship managers who want you to quickly and amiably approve all their new clients, ambitious senor staff who want to bring in that high net-worth businesses, that pile of unfinished files, already sitting on on your desk. That's why I used to be at my desk at 7am every morning; so that I could complete my unfinished work before the New Accounts staff came by during normal business hours to bother me with their pending CIP complaints.

How did I become a compliance officer? Totally by accident; I regularly criticised the profession in my writing, for failing to understand, and appreciate, the skills possessed by financial criminals. Due to an unusual chain of events, I was about to find out what it is like to discharge those important responsibilities on a day-to-day basis. By way of background, a friend of mine is a banking attorney in Miami, with one of America's major law firms. He had left the firm to become a compliance officer with a major banking client of the firm. When their international banking division moved away from Miami sometime later, he returned to the law firm in a prominent role in their global banking division. He frequently lectured on important issues, and at times, we jointly covered AML/BSA topics before local banking groups. One evening, he approached me with a problem; he was scheduled to give a money laundering lecture the next morning before a conference on Miami Beach, and the topic was "Hedge Fund Money Laundering." His firm had called him to immediately travel to Argentina on urgent business, and he asked me to take the lecture. By now, I am sure you know that I love to lecture on money laundering tactics and trade-craft, and I readily accepted. The attendees at my lecture included the compliance officer and the CFO of a Florida investment firm. I actually knew the compliance officer, a Peruvian-American who was the daughter of a Key Biscayne neighbour, who was formerly with the US State Department, and now a trusted financial adviser to Latin American investors. (More about the CFO later).

So, what else did I show the students in the investigations classes? Here are a final few that may one day allow you to extract an incriminating gem which will cause you to decline an otherwise promising client who is, in truth and in fact, a fraudster. When that happens, you know that you have properly discharged your compliance role. Though reference each day to all the Internet resources I have discussed during the past three weeks is not necessary, I hope that I have been able to broaden your Internet horizons a bit with these four lists of resources.

What I found was that my presentation on Internet resources useful in money investigations required weekly updating, as the world wide web was expanding during the mid-1990s at an exponential rate. Whilst websites important in compliance due diligence enquiries evaporated for unknown reasons, this was more than made up by the explosion of both commercial and governmental sites which greatly facilitated armchair investigating. The days when one was forced to visit the city's largest library, public records office, property appraiser, civil & criminal courthouses, law library and newspaper morgue were giving way to quick Boolean searches of websites. True, some of the data useful to me had been converted to CD-ROM format, but the moment you took possession of it, it started to become outdated. The Internet's constant updating feature rendered most other resources obsolete.

In conducting the lectures on the efficient use of what was then the relatively new Internet, I always held a Q & A session at the end of each class. Their questions revealed not only a lack of knowledge of the best websites, but an inflexibility in search techniques. Whether this was specific to the industry, as law enforcement culture encourages conformity in all things, or simply a lack of imagination, it required a solution. Since many searchers were glued to one or two search engines, I encouraged the use of sites that featured multiple search engines, such as Dogpile (www.dogpile.com), or the use of more obscure search engines, like Northern Light, and similar significant alternatives to Lycos. AltaVista, Excite, HotBot and others. They needed to understand that search engines were not a substitute for an inquiring mind. But on to the resources I found that were of great value in money laundering investigations, due diligence enquiries, customer identification procedures, and suspicious activity queries.

When the Internet became a commercial reality around 1994, I realised that I needed to add this valuable tool to my lectures, for the resources that were coming online gave law enforcement investigators and financial institution compliance staff the ability to access the information without regular and time-consuming trips to the urban university & law school libraries, courthouse file rooms, public records microfilm storage facilities, newspaper archives, and other information locations that they had been required to visit to conduct thorough investigations or proper due diligence enquiries. I created a class specifically to address the relevant websites that were beginning to come online, who they were, where they could be located, their value, and efficient search methods.

As I continued to lecture, conduct training classes, and present at anti-money laundering and law enforcement conferences, I began to understand that the audience, whether they be compliance officers or law enforcement investigators, were reactive to money laundering, and not proactive to its identification and suppression. I realised that they were not anticipating emerging threats as they surfaced in the global financial picture. By the time they became aware that a new method of laundering, or new opportunity, or permutation or combination of an established scheme, had been employed, the damage had already been done. I sensed that I had found my niche; increasing their level of sensitivity and awareness to current events as the instrument upon which imaginative money launderers practise their profession.

Not all of my cooperative work with law enforcement resulted in the arrest and conviction of the targets, generally because of mistakes made by the federal agents handling the matter. Some of those guys were guilty of the cardinal sin of arrogance, which can lead to overconfidence. When you think you know everything, you make mistakes. Understand that though these specific cases took place over the course of a decade or more, that most of the errors could have been prevented. The law enforcement culture of many agencies unfortunately perpetuates a conformist mindset that discourages original thinking and improvisation. Watch and learn how inflexibility can turn a certain win into a loss. Rather than soundly embarrass the agents involved, I have omitted the name of the agencies involved. Of course, if a reader really has to know, all you have to do is e-mail me for the name of the guilty one in any of these stories.

My personal view on money laundering: if you're not part of the solution, you're part of the problem. To be truly rehabilitated, a former money launderer must not only keep his or her nose clean, but also be pro-active, and take the battle to your new enemy. That's why I agreed to work in a undercover capacity, to masquerade as a practising laundryman, on behalf of law enforcement. And why not, since I had the skills, put them to use in a positive manner. Here's how it happened.

Then there was the time I was engaged by a major television network to set up and operate an undercover operation targeting money laundering lawyers working in Caribbean Tax Havens, for broadcast on a popular prime-time programme that specialised in investigative journalism. The theme was to demonstrate that that offshore financial centres were still accepting illicit cash. Several that were blacklisted by the Financial Action Task Force (FATF) had enacted anti-money laundering laws, created Financial Intelligence Units (FIUs), and ultimately been taken off the list. My task was to show that these "reforms" amounted to little more than window dressing, and that, when dirty money presented itself, it would be eagerly accepted by local lawyers, who had the ability to place the same in offshore banks affiliated with them.

My initial efforts in anti-money laundering instruction, which began in late 1992, were generally limited to law enforcement, as the level of interest I found early on in the banking community was, in my opinion, insufficient. Were many financial institutions were not interested in my skills because I was a former money launderer? That may have been a factor, as I certainly experienced disapproval, and at times, even hostility, when I approached bankers with my offer to instruct their compliance officers in money laundering trade-craft. However, the appreciation of the clear and present danger, of reputation damage, presented by money laundering, was the second reason. Therefore, I favoured approaching the class of potential client who demonstrated a genuine interest in having their staff learn both the techniques and strategies of that dark calling: American law enforcement agencies.

Once I had given my first law enforcement money laundering trade-craft lecture, I realised that there was another benefit to be derived from giving back. I was laboring under a three-year post-incarceration period of what is known as Supervised Release. This is basically parole in disguise. The US Congress, in its infinite wisdom, abolished parole for new offenses committed after October 31, 1987, pursuant to the Sentencing Reform Act of 1984. Remember, prisoners could be paroled after as little as one third of their sentences, and faced mandatory full-term release after two-thirds. What the Sentencing Reform Act cleverly did is ensure that criminals served 85% of their sentence, and were liable, after their release to a term of years of supervision, generally three or five years. Should they re-offend during that period, they could be returned to prison for the balance of their Supervised Release period. It directed that the US Probation Office, which was then supervising those parolees still under the old law, supervise all the new law (post-1987) cases. It was parole under another label, and I was required to serve three years of it by the sentencing judge, in line with the then-mandatory US Sentencing Guidelines (the Guidelines are now optional, but still a powerfully persuasive authority). Could I not have my Supervised Release reduced for some reason?

Opportunity sometimes arrives unexpectedly, as did mine. In 1994, I received a call from a sergeant in the intelligence division of a police department in Florida. He had an unusual request; would I be interested in lecturing on the subject of money laundering before a state-wide organisation of law enforcement agents involved in acquiring intelligence about criminal activities in their respective jurisdictions. He wanted me to tell the story of my experiences over the previous fifteen years, and to lecture on money laundering tradecraft, the actual techniques and strategies I employed on behalf of my narco-clients. At first, the idea sounded ominous. How could I possibly stand up before a room full of law enforcement officers who knew full well that I had been convicted of, and did prison time for, the serious crime of racketeering? I am no shrinking violet, but these people had been, until I decided to cooperate with law enforcement during my incarceration, my adversaries, and they were sworn to bring me to justice, meaning arrest and conviction. Furthermore, I was being asked to appear at their annual conference, meaning that I would be the "odd man out," or sole non-law enforcement type at the event. Classes given to attendees at such conferences generally contain information restricted to law enforcement, and I would be barred from sitting in. This means I would be sitting around for a while, under the watchful eye of some of the officers. Does this sound like something you would like to do? I was apprehensive about the reception I would receive from the attendees, but agreed to appear.

On the day of my release, after nineteen months and several days in custody, I gave away my Army watch, law-books and all the other useful items, as I wouldn't need them on the outside. I said my goodbyes to people who wouldn't get out for some time, some former clients, some friends from Miami's legal scene, and to my clients' accountant, who would not be released for several more months. I was going "to the door," to actual release, not to the halfway-house. My sister, who had been the only constant during my incarceration, and who would later go to law school herself, came to pick me up. Leaving the camp for good was a lot like being permanently transferred out of a military installation during service, but infinitely better; A breath of fresh air. At Eglin, the civilian airport was part of the air base. When I boarded the aircraft, and saw that the pilot, first officer, and flight engineer were all female, I thought I'd been away for far too long, as the world had changed around me. Maybe it was me that had changed, but in any event, I was free, airborne and on my way to the next chapter in my life.

I was returned to the Federal Prison Camp at Eglin Air Force Base, in northwest Florida, where I had begun my incarceration, because it was my permanent assignment. With less than six months to go before my release, things were looking up, although my future was cloudy. I had no law license, wife had divorced me, and I knew that I would certainly be shunned in Miami by the professionals and bankers who had worked with, or against, me for twenty years, but the prospect of freedom seemed to push all those concerns to the back of my mind. Fortunately, one of the lawyers who had represented me offered me a paralegal assistant job, so I did have some sort of "release plan," as the Bureau of Prisons called it. Beyond that, I had no clue what the future would bring.

They dumped me at the Escambia County Jail, which is in Pensacola, (a Navy town on Florida's Gulf Coast, at the boder with Alabama) solely because the Prison Camp where I was permanently based, inside Eglin AFB, would not take weekend transfers. I assumed it was only to be for a day or so, but it turned out to be much longer than that. I look upon it as simply another chapter in my practical education concerning the shorrcomings of the correctional system. If you regard untoward events as educational, then your sense of humour saves you from the generally negative experiences that will, of course, follow.

All good things must come to an end, and I was transferred from the small-town county jail in rural Gilchrist County back to the high-tech one in Wakulla County, which serviced the US District Court in nearby Tallahasse. Although I was going to the minimum-security block, the conditions, though clean, were spartan, with few privileges. But I had an idea; since I had been successful in reducing my 4-year sentence to 2 years (meaning that I would be serving around 22 months, as gain or good time earned equaled about a month per year), I wanted to do more. Could I actually get my now-two year sentence cut to one?

I would soon be transferred from that small-town jail, as I had achieved the goal every inmate aims for; a sentence reduction, in this case, a fifty per cent cut. As the man said, "you will not want to leave that jail, " and, strange as it sounds, he was right. The creature comforts experienced at the Gilchrist County Jail would be missed, for wherever I went in the future; the conditions of my confinement would never be that good. But we're getting ahead of ourselves. Before leaving, it is important to describe the jail's unique usefulness to law enforcement. I knew one of the trustees at the jail, for he was a former client, and he had been specially placed there by a US law enforcement agency, because he could assist that agency in ways that could not be accomplished elsewhere. What am I talking about? Read and learn about some of the more obscure tactics utilised by law enforcement to combat the money laundering of narcotics proceeds.

After I gave testimony in camera, describing the circuitous path my clients' narcotics profits took, ultimately ending up in Switzerland when the clients themselves, seeking to hide the final destination from even yours truly, quietly moved their wealth there, the government advised that it had other plans for me. I was to be moved to another institution, with a number of other inmates, this time located in Central Florida. The new location would turn out to be much more user-friendly than I anticipated. It all started when I asked a more experienced inmate about the jail conditions at my destination. His answer, which led me to believe that he was suffering from some sort of mental condition, was "when you get to the county jail at xxx, you won't want to leave." Was he crazy? What prison inmate actually likes the place where he is confined? It sounded like extended incarceration had affected his mind. Whilst enjoyable conditions, if that term can ever be described in connection with serving time, might be portrayed in such Hollywood movies as "Goodfellas", they certainly do not exist in real life. Or do they?

I spent several weeks locked down in a solitary cell in the Special Housing Unit at Tallahassee FCI, after which time I was transported by the DEA to a local county jail in adjacent Wakulla County, where I ran into a number of my clients, as well as one of those individuals who had testified against me. Most of them were there in the event that they were needed to testify at the trials of a couple of subsequently-arrested defendants in our case that had elected to go to trial, rather than plead out. To obtain that prized sentence reduction, they would either testify against a former associate, or the prosecutors believed that their mere presence and announced availability to testify was responsible for another defendant deciding to change his or her plea to guilty. I had not seen some of these clients for a couple of years, ever since their arrest before the first major trial in the case. At least there, I had the small comfort of others that I knew intimately to talk to. My prior experience in Federal and state custody was not with clients, with rare exceptions. Also, I was able to be briefed on who was a fugitive overseas, who fled to avoid prosecution, and who was already doing time in other cases when arrested; All the sad details.

Serving a long four years in a Federal Prison Camp was a very unattractive reality. Could my sentence be trimmed under Rule 35, which allows the US Attorney to move the court to reduce the sentence for what the law calls "Substantial Assistance," delivering information to the prosecutor or to law enforcement, that will result in the arrest of additional individuals, or the recovery of criminally-derived assets by the government? Whilst every inmate dreams of a sentence reduction, either through some magical feat of his or her lawyer, or through cooperation, obtaining one is purely at the discretion of federal prosecutors, who alone can file such a motion. Remember, I was in prison precisely because I did not cooperate in years past, when my stubbornness and misplaced sense of loyalty to clients who failed to reciprocate, resulted in my eventual imprisonment. Could I switch sides, and return to the legitimate society, which I had left a decade before? The clients had certainly abandoned me, and I was on my own, and no longer bound by my perverse interpretation of the attorney-client privilege.

About a month after I arrived, the weather turned cold and windy. Of course, I should have expected it, and steeled myself for it, but coming as it did so close to the Christmas holiday season, it was doubly depressing. Here I am, thrown in with a motley crew that for the most part consisted of drug traffickers who are also serving short sentences for one reason or another, and it is becoming downright dreary, both mentally as well as physically. I see that a large number of the inmates are seeking solace (and perhaps redemption) at the chapel, the one place in the prison where they don't harass you. The intimidation and constant belittling is unnerving to those prisoners who never had to endure some form of military service, and many are clearly looking for a quiet area to hide from the stress. Many also hit the law library, where kindly and well-meaning inmate librarians seek to assist those who have some sort of issue about either the outcome of their case, their lawyer's perceived lack of skill, or their sentence. Is there really a get-out-of-jail card? I am afraid not, except in the world of fantasy.

We return to the daily regimen of Federal Prison Camp life; I arrived at Eglin, which is in the Florida Panhandle, a portion of the state that juts out into the Gulf of Mexico, and more like Alabama or Mississippi than the rest of the state, just before Thanksgiving, meaning mid-November. The weather in that area was soon to change to a cool, and then cold, state the likes of which I had not known since my days spent freezing during a winter in the Army at Fort Dix in the 1960s, and it was a physical shock. After all, I had by that time been living in a sub-tropical climate for an uninterrupted two decades. I'll take 40 degrees Celsius any day before zero, believe me. It's bad enough to have to adjust to the reality that you are going to be spending the next four years in a Federal correctional institution, but to have to endure cold weather makes it far more depressing. Here I am getting up every day just before dawn, and donning a out-of-fashion Air Force blue work uniform, to trudge down to a military-style mess hall for a bland breakfast, followed by an artificially-created work day where most of inmates must journey out to the far corners of the surrounding airbase to perform menial labour, in penitence for their white-collar or drug-trafficking transgressions. At least going to war was interesting; this place is terminally boring, and full of bored and stressed-out inmates who just want the experience to be over. Back to our story.

Today we shall continue on with my typical, ordinary Federal Prison day, as patiently endured by for yours truly for a little less than two years. I spent more time in the US Army than I did in prison, and in the military your adversaries have a bad habit of shooting rockets at you at sundown, but being in custody, though generally safer, is terminally boring to anyone in the professions. Street-level drug organisation members can go lift weights, watch and infinite amount of television whilst not on work details, and share embellished tales with their brethren about their favourite wild escapades, but the doctors, lawyers, judges and politicians who were doing time were usually bored to tears. Fortunately, I found a few ways to amuse myself. Let's talk about those after we complete a description of my work-day routine.

What is life like in a Federal Prison for inmates doing time for financial crime? Perhaps a snapshot of the daily routine I experienced will give you a feeling for the utter boredom of living a life where each month is mindlessly endured, day after day, and then triumphantly checked off on some tiny calendar kept somewhere, as the inmate tries to measure progress in what feels like an infinitely long stretch. Of course, I cannot hope to do more than give you the flavour of imprisonment, and more than watching a war movie will let you feel what it is like to really be on the receiving end of a rocket attack, but I trust that this will show you the futility of it all, of marking time in a place you don't want to be, with roommates you could do without, in an institutional system you profoundly dislike, as a defrocked professional in a sea of drug offenders.

Mike's attorney, one of Miami's most capable, sought to cut a favourable deal for his client. Trouble was, the client had chosen to "visit" his son in California, meaning technically that the DEA could not locate him. Was he a fugitive from justice? The judge later opined that he thought so, but his lawyer disagreed. Anyway, the lawyer called me up and asked for a meeting. We had gone to law school together. The purpose: there were dozens of defendants in the case, and it seemed that nobody else could identify many of them. That's how large the criminal organisation had grown. Fortunately or unfortunately, I had either moved cash for them, socialised with them, done cocaine with them, or knew what their sins were from disclosures made in moments of candor. I went through the Indictment and pass on what I knew about the true occupations, and roles of the particular individuals, as I felt I had to assist Mike in the defence of his case. Mike had assisted the clients in legitimising their illicit income through the use of the "commission salesman method" we discussed earlier in the story. Of course, he ethically couldn't advise me that he knew that I was a target of the investigation, but I figured that since Mike had a problem, I was part of the case as well.

I ran into Mike, who was the accountant for one of my client criminal organisations, outside the prison mess hall. We hadn't seen each other for some time, for when the authorities started looking for Mike, as he had been indicted along with dozens of out mutual clients, he quietly moved to California, and dropped off the radar. Whilst he later would claim that he was merely out there to spend some quality time with his son. in truth and in fact, he was ensuring that he would not fall into the hands of law enforcement by relocating to an area where they would not think of locating him. In the meantime, his lawyer worked very hard to learn all he could about the case, and sought to make a deal. But we're getting ahead of ourselves. Back to the beginning.

When one arrives at a Federal prison or prison camp, you are placed in an "Admissions & Orientation" programme, where the correctional staff presents several seminars & lectures intended to orient the new inmates into the requirements and expectations of the Bureau of Prisons. It includes ensuring that all the inmates prove that they have a high school diploma; otherwise they are sent to the institution's school to obtain sufficient instruction to allow them to pass the state high school diploma examination. Some of the issues that have arisen out of this policy are quite comical, such as demanding that individuals who have post-graduate or professional degrees prove that they finished high school. Whilst this is a prime example of the governmental mindset, there is a reason for all their concern. I discovered to my amazement that no less than twenty-five per cent of the inmates did not have a high school diploma. It seems that the lure of easy money, meaning drug trafficking, caused them to leave school before finishing. Strangely enough, I was eventually to be assigned to the education centre, where my role was to prepare the inmate-students for the mathematics section of the examination. As one of those who detested math in school, but learned it nevertheless, perhaps it was part of my punishment that I would be thrust in the role of math teacher.

I was standing next to my bunk at what the Federal Bureau of Prisons said was to be my new home for the next four years, when the rest of the residents, meaning inmates, arrived from their daily duties. Minimum security facilities, known as prison camps in correctional parlance, require their residents to perform menial duties, often at adjacent military bases or forts. They actually pay something like five cents per hour for these manual tasks. If one is unwilling to submit to such mindless activity, they find a way to transfer you to a higher-level facility, which means controlled movement, an environment where one cannot move around the facility except at specified times, which severely restricts you. We will discuss security levels shortly. Anyway, the returning inmates, a couple of whom I had known or met earlier in civilian life, came in the door; most were dirty and tired from a day spent cutting grass or performing some other repetitive chore at Eglin Air Force Base, which surrounded the prison camp, taking up the better part of three north Florida counties, and is the largest base of its kind in the world.

When the time came, my name was called, and I walked through the prison administration building into Receiving & Discharge, the input/output facility of the institution. There, my belongings were examined, and those few items that I could not bring into the prison were boxed up and sent home. I had worked from a list sent to me weeks before, and the only thing I wanted in that they wouldn't let me have were some OD (olive drab) t-shirts, a personal link to my military past, when only soldiers going to combat zone were issued OD. My civilian clothes off, I donned a navy blue air force-type work utility uniform;I was, after all, totally inside a USAF facility. No name tag, though, no stripes to denote rank, no patches or other identification. It was a totally anonymous identity, and, carrying my issued bedding and other items, like a new recruit in any military, I went into the next room to be interviewed by one of the staff.

I had a farewell dinner with close friends, and it was time to pack for my trip to the Federal Prison Camp at Eglin Air Force Base, in the Florida Panhandle. The night before, I felt feverish, but figured out that it was stress related. There was a specific list of things to bring, in the way of clothing and accessories. To meet the specified cost of a watch, I journeyed to one of my favourite Little Havana stores, an army surplus facility where I had picked up a lot of useful equipment over the years, some to assist me in my covert life, and some for the pure utility that military gear has for one who knows how to use it. An olive drab watch of military design was perfect for where I was bound.

As the time drew near for me to journey to the Federal Prison Camp at Eglin Air Force Base in northwest Florida, where I had been ordered to report to begin serving my four-year sentence, the little things in life, which I would not be enjoying for a long time, were especially dear. Such mundane domestic things as walking the dog, or taking my small son to the park were appreciated, for when I returned from confinement, years later, everything would be different. As I had felt the same exact way during my leave prior to being shipped out to Vietnam twenty years before, I was somewhat on familiar ground. The only thing one can do is to cut one's hair short, and prepare mentally for one of life's more difficult experiences. After all, many of the clients had already done this, and it was now my turn.

Looking at serving a sentence in a Federal Prison from the front end, whilst depressing, is not the end of the world. It's certainly not like going to war, where you know you could very well come back in a box. It just seems like a long, long time when one thinks about a term of years of incarceration. You know intuitively that the world will still be there when you come back, with only minor changes. However, and more importantly, you are the one thing that will have changed. One aspect is the world of work. When your identity for 20 years revolves around your chosen profession, and you know that those privileges will be revoked, one way or another, as the result of your criminal conviction, you know that your workday and life will be very different when you get out. So, as I began to close out my law practice, I realised that I was soon to lose an important piece of my perception of who I was. What would survive?

For a lawyer, attending your own sentencing hearing is one of the most humbling experiences one can experience. It is one thing to be representing a client in such proceedings; you are there purely as an advocate, and are also providing moral support for your client, who is fearful of the outcome. When you are an attorney-defendant, and you know exactly how much prison time the judge could potentially mete out to you, that information makes the experience all the more dreadful. Since my case was prosecuted by an Organised Crime Drug Enforcement Task Force in another city in Florida, I had to travel to the hearing. I think the term fear & loathing is an appropriate description of how I felt on that day; Imagine what it would be like if it happened to you. It was, for me, a necessary rite of passage between my life of financial crime and normal society.

My situation was dire; there were at least three important former clients who were obviously going to be assisting the US Attorney, and who would testify against me. I had opened companies in tax haven jurisdictions for them, transported illicit cash offshore with them and banked it, and advised them on a wide variety of criminal ventures involving narcotics smuggling and laundering the proceeds of crime. With the Gainesville jury pool composed of conservative small-town Floridians, and the anticipated introduction of evidence of my many other money laundering ventures, my eventual conviction was pretty much a foregone conclusion. A good lawyer knows when to be a zealous advocate, especially on his own behalf, and when it is simply hopeless, and a lost cause.That possible maximum sentence of twenty five years to life made the decision for me. It was time to admit my guilt, and accept the consequences that ensue from such an action; the legal equivalent of shooting one's self in the head.

I needed to decide on how I would conduct my defence; my lawyer, known to me personally to be experienced and a veteran of many Federal Court cases, told me that I was at a fork in the road. If I decided to go to trial, the possible maximum sentence that could be imposed was twenty-five years or more. He said that only the defendant himself can decide whether to risk that amount of prison time by taking the case to trial. I knew that the kingpins in the case had already been sentenced to extremely long terms of imprisonment. The judge had actually meted out a sentence of three life sentences plus 200 years to the most culpable individual who had taken his case to trial. My case was pending before a very conservative judge. Should I plead guilty, or prepare a defence, and risk spending the rest of my life in custody? What would you do? Remember, in Federal Court, the prosecution usually takes years to build up an ironclad case. I had been under active investigation for the past seven years. Did they have a good case against me? Let's look at the possible evidence.

What does one do when faced with 25 years to life in prison? I was charged with 20-year and 5-year felonies, but the Organised Crime Drug Enforcement Task Force Force that had brought the case could certainly add up all the drugs & all the money, and come up with a life sentence pursuant to the then-mandatory Federal Sentencing Guidelines. Under the Guidelines, there is no gain time, time reduced from one sentence for good behaviour, and a life sentence would be exactly what it is, life in prison without the possibility of release. Think about what it is like to face that exposure as a defendant in a criminal case. What would you do, and how would you cope?

Arriving in court as a criminal defendant, in handcuffs, and chained to a bunch of street-level drug dealers, was a rude awakening. After all, I was used to sitting quietly at the counsel table, and here I was, the center of attention as a person who has just been arrested. The First Appearance is mainly a formality, but it does have one aspect dear to all defendants, a preliminary enquiry into whether the arrested is eligible for pretrial release, more commonly known as bond. My case was no different, but as the arresting agents remarked whilst transporting me downtown after they picked me up at my office, (see Confessions of a Money Launderer - Part 33) they fully expected me to be allowed to bond out. Most lawyers or other professionals arrested were granted bond, otherwise known as bail, which allowed them to stay out of prison until the resolution of the case, usually at trial. Few if any serious felonies were ever dismissed in District Court.

Everyone has important days in their lives that they will always remember, and I've got a few great ones. The birth of my first child; graduation from law school; the opening of my own law office; marriage ceremonies, all were memorable. But I also have a few not so positive, like the first time I was on the receiving end of a rocket attack in Vietnam; discovering that I was under active surveillance by law enforcement; eluding customs agents on the streets of Miami; Coming into the US with documents that I did not want the authorities to see under any circumstances, and many other high-stress events that most people would prefer to forget. One day, which began much like all others in my office, was to be one such event; the day of my arrest for racketeering, a serious charge, and one which is generally only brought against career criminals who richly deserve it. Was that me? You bet it was.

Waiting for the ax to fall when you are under investigation is an eerie feeling; You know that your adversaries in law enforcement are out there somewhere, unseen. One can almost feel, or even smell, their presence. I had that feeling every day when I was in the field in Vietnam, and here it was back again, twenty years later. When I went out in the morning to walk the dogs, I half expected to be confronted by a team of DEA agents who had my name on their warrant. Are they out there? Nope, not today. Perhaps tomorrow. One becomes very fatalistic under those circumstances, but the tension never fades.

So how did I evade arrest for a decade? Readers often ask how I was caught, assuming that I went to federal prison after being arrested with a suitcase of illicit cash at some US border checkpoint. In truth and in fact, I was never caught in the act, but because three clients, convicted and looking at serious prison time, turned upon me and the organisation's accountant. It is known as Substantial Assistance in the Federal Sentencing Guidelines (then mandatory and now officially only a guide to District Court judges) and it allowed my former clients to reduce their sentences. But just how did I escape justice for all those years? Today I provide a glimpse into the precautions I observed to minimise my personal risk during that period, for the consequences of failure or discovery in a money laundering operation are serious.

In the money laundering business, where mistakes could result in a twenty-year vacation, courtesy the Federal Bureau of Prisons, or even termination of your employment with extreme prejudice, you need to keep your sense of humor. When the clients suffered setbacks that could result in your immediate arrest, you had to roll with the punches, practice damage control, and if necessary cut their losses as efficiently as possible. And things had a habit of going south without warning; that's the nature of crime. One time, two clients tearfully called me to come for a visit late at night. They had recently smuggled some prime grade marijuana in from Jamaica and, secreting it artfully in the attic of their Coral Gables home, had gone off on a vacation. They returned to find their house broken into, with only the drugs missing. Had there been a breach of security, or had a member of their crew ripped them off? We never found out. Episodes like that will make you crazy if you let them. For that reason, I always chose to focus on the humour in the drugs trade.

His street name was J.R., not because of any resemblance to the television star from "Dallas," but because those were his initials. His was a long haul life, Miami to the Midwest, over and over and over again, moving cocaine overland in a Jaguar sedan, blending in with the interstate traffic in and out of Florida. His wife was from a prestigious Illinois family, and I don't think she actually knew exectly what he did for a living, notwithstanding his long absences from their Florida Gulf Coast home. I used to watch him cut kilos of cocaine, sitting on the floor, with a non-toxic derivative made from corn called inositol, prior to driving the results all the way to Chicago, for sale to his customers. He escaped criminal prosecution for his crimes, though there was once a close call, when his wife left some marijuana in a rental car, and I had to take her into a small-town Florida police station to explain that she had no idea how that pot got there. Back to our story; it was J.R. who introduced me to Rick, a clerk who worked in a Miami music store, and had a powerful cocaine habit. Rick dropped out of sight for a while, but when he returned he had both an interesting story, and some clients with money laundering business for me.

Operating a money laundering enterprise whilst under a law enforcement microscope required that I exercise extreme care, but criminal clients can get sloppy, which may have a resulting impact on the laundryman. One such episode involved a client who was purchasing a light aircraft for use as a marijuana smuggling vehicle between Jamaica and Florida. The human factor was that the organisation's leader was of small physical stature, which he overcompensated for by being arrogant, imperious and difficult. Of course, those characteristics could be applied to many normal-sized drug smugglers, as their successful operations caused them to often be incredibly egotistical, to the point where they tended to ignore instructions from the professionals advising them in their money laundering operations. For example, I have previously referred to the placement of $6m in Switzerland by my clients, against my specific advice, as I feared it would be lost. As fate would have it, both the US & Swiss governments shared in that plunder when they later seized those accounts.

Operating a money laundering enterprise when you know you are under active law enforcement investigation is stressful, to say the least. One simply does not know when the proverbial "knock on the door," meaning your arrest, will occur. Since such untoward events generally take place in the wee hours of the morning, you never sleep as soundly as you'd like whilst at risk of arrest. One knows that those law enforcement adversaries are out there somewhere, unseen, close enough that you can sense their presence, or at least think you can. It is not an experience that I recommend to anyone, and the only functional equivalent I have ever experienced with the same degree of fear and loathing is being in the field during a time of war, with the enemy out of sight, but known to be at close quarters, and prone to attack at night. It's that kind of feeling; not for the faint of heart. But it does cause you to be hyper-vigilant. Paranoia? You betcha.

I traveled that evening to another Florida city, for though the Federal judge who presided over that particular matter held court in the city where I had declined to testify, his permanent chambers were in the state capitol. He only traveled the circuit to the other cities in the district for certain scheduled hearings and trials, and the hearing upon my refusal to testify was an unforeseen event. Having appeared in court hundreds of times as counsel, I was familiar with the procedure, but even lawyers are under a certain amount of stress when they are scheduled to testify themselves. It is more suspenseful when one is looking at potential jail time for failure to obey what are lawful orders of a court of competent jurisdiction. In short, if I wilfully disobeyed a United States District Judge, I could be incarcerated on the spot. This was therefore not a routine court appearance for me, as my freedom depended upon the outcome of a short hearing.

Needless to say, after several million dollars of client money had been mysteriously unfrozen from shell company accounts in Anguilla, and instantly transferred, upon my orders, to the nearby Federation of St. Christopher & Nevis (conveniently an independent nation), US & British law enforcement agents assigned to the case were very, very unhappy. Although the official reason for the lift of the stay order was the failure of the DEA to timely deliver proof of guilt, the magistrate who entered the controversial order was alleged to be the recipient of an illicit gratuity (bribe), and was summarily terminated. I did not learn the truth about the real grounds for the release order, nor do I know the secret at this time, but I had other problems to worry about. I was now a target of law enforcement, with all the dangers and stress attendant thereto. It now begins to get ugly not just for the clients, but for myself as well.

How does one accomplish reverse bulk-cash smuggling and layering under pressure? That is to say, how is illicit criminal proceeds that was previously smuggled out into the Caribbean tax havens, moved back into the Continental United States and elsewhere? Such was the order of the day after the magistrate who froze millions of dollars of my clients' money, on the word of the DEA and Scotland Yard, later chose to release those funds. They were safely transferred within minutes to a nearby tax haven (one that had recently gained its independence from the UK), and were subject to my order. What now? Different clients had different needs, different levels of paranoia after the seizure, and above all, wanted to protect their illicit wealth.

When a money launderer has millions of dollars of client money frozen by law enforcement, as I had, your credibility, and indeed competency, as a professional becomes an issue. Most criminals rely upon their laundryman to mimimise the ever-present risk of of seizure, and subsequent forfeiture by selecting the appropriate venue for secure storage of client illicit assets. A seizure mean either (1) you were dead wrong on the location, or (2) there was a breach of security. With millions of dollars of client funds in the hands of HM government in Anguilla, my troubles were trebled. Not only was client money in jeopardy, but other former clients had money there, in addition to yours truly.

Sometimes a clever money laundering operation can successfully masquerade as a legitimate financial institution for years. You don't believe me? Let me tell you about one that operated in plain view right in front of me whilst I was a very young lawyer, and I didn't spot it. The law firm where I worked, which maintained London and New York branches, had an international financial institution as a valued client. This powerful entity, which had its offices in the upscale Miami suburb of Coral Gables, where many Fortune 500 companies had their Latin American headquarters, had a global reach. I once saw it lend $25m to a Latin American government for a public works project, and was suitably impressed with its ability. What I did not know was that the company was the longest running, and largest, money launderer for cocaine traffickers and smugglers, and that it had a guardian angel, the Central Intelligence Agency.

Sometime around the period during which I was representing Parisian George, I became a target of US law enforcement. Perhaps they were angry about the way in which I managed to extricate one of his smuggling captains from their clutches, after which he immediately fled to Panama, whilst I took a flight to St. Maarten. If you've been following the story to date, you know about that episode. Today we will cover the attention that was focused upon me as the direct result of something that happened to an accountant in the British Virgin Islands who sold shelf companies, with bearer shares, to any and all who needed them. Scotland Yard tumbled into my operation completely by accident, in a way that I could neither have anticipated, nor planned for: happenstance.

In this and future installments, we shall discuss tradecraft and tactics in support of the central role. The job often demands that one perform certain additional duties that are necessary, yet are on the periphery of the primary mission, which is the covert movement of illicit client funds into the legitimate economy. They call upon the laundryman to protect his client from unnecessary and unwanted attention (particularly of the law enforcement variety) by adroitly creating owner-less entities and properties, yet maintain control nevertheless. It is the skill with which these supporting tasks are accomplished that distinguishes the journeyman from the real professional. Let us dissect my creative use of these generally routine and mundane tasks, and observe the attention to detail that gives them magical properties.

Eventually, many of a money launderer's criminal clients get busted, if they don't first die of a drug overdose, die whilst driving drunk or stoned, or quietly disappear for a faraway destination. Unfortunately, many become so arrogant at the consequence of their (illegal) monetary success, that they make stupid mistakes, delegate serious tasks to inept subordinates, or neglect to observe the basic precautions that had kept them out of the hands of law enforcement before they got sloppy. Anyway, when clients are arrested, their money launderer may have a lot of loose ends to tie up. On the other hand, law enforcement may be looking to charge the laundryman, hoping to squeeze the location of the client's illicit wealth out of him, in exchange for a favourable sentence.

Today we complete last week's topic, A Day in the Life. When we left the story, I had just retired for the night in a nondescript Dutch hotel in Philipsburg, in Sint Maarten, Netherlands Antilles, with a large amount of cash and monetary instruments secreted aroud the room, and a busy day ahead of me. Working in the Caribbean is like a perennial vacation; you have great weather, beautiful scenery, and superb seafood awaiting you every day. Of course, the tax haven banks are the best part , if you are a practising money launderer on the job. Where else do financial professionals work so hard to help conceal the proceeds of crime, whether it comes from narcotics, arms trafficking, or white-collar ?

By popular demand, I herein present my typical "Day in the Life" as a practising laundryman, a profession where a single client's errors can cost you twenty years in federal prison, and where your own errors can result in that same client terminating your employment with extreme prejudice. Whilst there is absolutely no intent to glamourise this life, admittedly it did have its interesting moments, albeit sandwiched between actions which involved high-risk, and the tedium of constant travel. The primary directive is to seek to clothe one's activities within an anonymous, uninteresting business routine that never stands out, even when illicit acts are in progress. The best international money laundering scheme is that in which, the day after you have left town, they cannot remember who you were.

I am frequently asked, why on earth did you do this ? You were a young lawyer, well on your way towards a successful life in your profession as a member of the establishment. Recently, a person who has not seen me since I returned from the Vietnam war in 1970, posed that very personal question. A response is indeed necessary. The answer is complex, and is composed of two interrelated components. Neither involved avarice and greed, nor the desire for power. The first part was a legacy of the intense changes of the nineteen sixties, the second a malaise and general distrust of institutions that resulted from surviving a long personal experience that had turned into a national nightmare.

What is a day in the life of a money launderer? I've read plenty of those "day in the life" stories in UK trade magazines when it comes to compliance professionals, but nothing is ever written about how laundrymen spend their typical workday. I am therefore reconstructing a typical day in my life during that period. Whilst there are, of course, operations that contain a high degree of financial or personal risk, money launderers do lead, for the most part, normal (though stressful) professional lives. In fact, they strive to blend in with the mainstream, routine flow of the business world, often performing far more legitimate work than illicit criminal acts. In fact, it is their legitimate persona that allays suspicion, and allows them to successfully manipulate bankers, bureaucrats, public functionaries and naive businessmen.

What did my criminal clients choose (with my assistance) as legitimate investments to launder their ill-gotten gains, and just how efficient were they as straight businessmen? The answers give you a glimpse into the mind-set of individuals who bankers surely do not want as customers, both because of the severity of the punishment for conspiracy to commit money laundering, and for the reputational and regulatory damage that results from the exposure of money laundering operations at your bank.

Lest our readers think that I spent all my time as an outlaw and money launderer, perhaps its is time to reveal the flip side of my legal practise. Whilst I was, admittedly, representing narcotics traffickers and sundry smugglers of what the law refers to as "controlled substances," I was also representing members of the law enforcement community in civil and yes, even criminal matters. Why is this so unusual? After all lawyers, as Officers of the Court, are obligated to provide legal services to virtually all who seek their counsel. There was another, much more personal, reason. I may have been single as a laundryman for good reason, but celibate was I not.

Sometimes, my criminal clients' business ventures were quite unusual, and at times they reflected their colourful backgrounds. One client had once spent time working deep in the rural Mississippi Delta for the Library of Congress, preserving the music of its famous but obscure blues musicians. The bluesman Robert Johnson was one of his idols, and he introduced my one day to a tormented but talented Miami intellectual who had written a screenplay about the life of the legendary musician, whose classic blues tunes have been recorded by Eric Clapton, the Rolling Stones, and Bob Dylan, amongst many others. The Stones and Clapton had actually purchased an option to produce the screenplay, but it had expired before they could take any action. The client, flush with the profits of narcocrime, wanted to make the movie in Hollywood, notwithstanding his lack of experience, because he had actually grown up in Beverly Hills, an only child of film industry people.

It wasn't all work and no play. Being a money launderer for me was more than a day job, as I chose to participate in my clients' social events, as well as their offbeat legitimate business efforts. Most lawyers tend to put up a wall between themselves and those for whom they perform services, but since my clients and I were both engaged in illicit enterprises which involved covert operations, we tended to socialise, travel, dine and generally recreate together. Career criminals exhibit a healthy amount of paranoia concerning "straight" (non-criminal) people, as their true occupations could be discovered, and reported to law enforcement, by their neighbors, tradesmen, or just about anybody. Therefore, they are inclined to prefer members of their organisation for reasons of self-preservation. Also, some of the more arrogant clients exhibited disdain and contempt for those who pursued their goals legitimately.

George the Parisian, finally extradited to Miami after 14 months, was in good company. There were several of my other clients in custody there, all looking at decades of prison time for narcotics smuggling. But George had a decided advantage: we had put together a "dream team" of experienced defence lawyers, backed up by a veteran private investigator formerly with the Metro-Dade Organised Crime Bureau. There were some of the city's best members of what was referred to as the "white powder" bar, drug lawyers, and since the first trial had ended in a mistrial;, we already had a good look at the prosecution's case.

One of my best Cuban-American clients asked me to provide money laundering services for a Frenchman that they were doing a substantial amount of business with. At the first meeting, which took place in a riverside seafood restaurant frequented by smugglers, my new client, George, showed up in an XKE with a pretty Chinese companion that I would later find out was his wife. This man knew how to operate under what I would call extremely adverse conditions - he could consistently bring in large loads of contraband around Customs and Coast Guard vessels determined to terminate his operation.

The money laundering pipeline into the Caribbean tax havens having been established, I now turned my attention to other clients, who were drawn to me by word of mouth. Additionally, laundering the proceeds of crime merely removes the taint of illicit origin. I also needed to mainstream some of that money into the domestic US economy.

What was it like the first time ? To quote Churchill, " nothing in life is so exhilarating as to be shot at without result. " I never liked taking incoming fire myself, but stealing out of the Continental United States with millions of illicit dollars was a heady experience on the same level that Sir Winston so eloquently mentioned. As long as you don't get caught.

Ed passed me the name of a prominent East Caribbean lawyer, Peter Hendrix,* who was his trusted facilitator in money laundering matters. I knew that man; I had actually visited him two years prior, when I inspected a factory site in the Caribbean to determine its suitability for a corporate client who manufactured industrial cleaning agents. However, Peter was much more than a just a lawyer, as I was about to find out.

How did Ed Edwards fare in the American justice system ? He soon found that stealing millions of dollars is sometime easier than keeping it, as others attempted to help themselves to his ill-gotten gains. He also learned, to his chagrin, that when one is involved in a major crime, one should really try to cut back on other criminal pursuits. Otherwise, it starts getting ugly real soon.

Where does one go when one has no experience with financial crime and needs a referral into the dark side ? You ask an expert, of course, and I knew just who to go to. His story would make a book unto itself.

Why did the smugglers and drug dealers come to me for money laundering ? I had operated in the Eastern Caribbean before, albeit in a legitimate capacity. More importantly, I knew who to go to, for a Caribbean connection.

So how did I end up as an accidental tourist on the narcotics circuit , living in a house occupied by a drug trafficker ? As a young lawyer, I was probably as far away from that life as I could possibly be. I can only describe it as the result of a combination of circumstances that took me down a completely different path than that of my law school classmates.

How did I get to be a money launderer and what is it like for those who practise that dark art? Today we publish the first installment in a series that will answer those important questions, and further detail how I went from career criminal to financial crime consultant and compliance officer.