Baptiste  🕵 Forestier - CAMS

Flowdesk

Head of Compliance - EMEA

spektr

Ambassador

Hero 

Head of Compliance

The Laundromat (podcast)

Unraveling the day to day as well as the craziest stories of eminent professionals from the world of compliance! 🔍

Podcast Host

Faculté de droit et de science politique Aix-Marseille Université

AML-CFT course in the M2 Criminal Law - Fight against financial and organized crime

University Lecturer

BeSAF - BUSINESS EUROPEAN SCHOOL of ANTI FRAUD MANAGEMENT

Professor of AML-CFT/KYC

Spendesk

- Obtention of a Payment Institution license from the ACPR (French regulator)
- Creation of the Compliance Dpt. « from scratch » & Optimization of all compliance
related processes (KYB, transfers management, cards orders, frauds,..)
- Main point of contact with our regulated partners (SFPMEI, TPL & Marqeta)
- KYB management (mandate given by SFPMEI & TPL)
- Establishment of the regulatory context for the opening of the US market
- Implementation of the PSD2 (SCA on logins & payments)
- Obtention of a payment institution licence from the ACPR (french Prudential and
Resolution Control Authority)

CONFORMÉMENT VÔTRE

Preparation of an application for a Payment institution license (ACPR)

Regulation expert

Lemon Way

- Automation of documentary controls and Account openings (use of OCR software, real-time sending of origin/destination requests for funds) => Average processing time divided by 10 in less than a year !
- Industrialization of processes (Design of a new KYC workflow management module)
- Outsourcing of KYC/KYB in Romania (10 analysts)
- Compliance audits (PCI-DSS, Payment Thresholds and Schemes, Data quality, Closure of inactive accounts or accounts with false information,...)
- Communication (via Mailchimp) and Follow-up with Lemon Way Partners of the necessary compliance actions
- Legal intelligence (KYC, AML-FT, Internal Control, GDPR,...)
- Drafting of procedures
- Member of the Data Protection Committee

Head of KYC & Operational Compliance

Join a Vibrant Community of 30K+ Compliance Enthusiasts & Expand Your AML Knowledge Every Week 🧠 | Head of compliance & DPO @Hero ⚖️

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Head of Compliance & DPO

⚖️ FATF Recommendations ⚖️

➡️ Money laundering offence (3/40)


🌍 The Financial Action Task Force (FATF) is an inter-governmental organization that sets international standards to combat money laundering, terrorist financing, and other related threats to the integrity of the global financial system.

Its 40 recommendations are a crucial framework for countries to adopt measures to combat these threats.

This 3rd rec. focuses on the criminalisation of money laundering offenses. ⚖️

It requires countries to apply this crime to all serious offenses, including the widest range of predicate offenses.


🧑‍⚖️ The FATF recommends the criminalisation of ML on the basis of the Vienna Convention and the Palermo Convention.

The Vienna Convention (1988), established the framework for international cooperation in combating drug trafficking, including provisions on asset forfeiture and mutual legal assistance. 

The Palermo Convention (2000), expanded the scope of the Vienna Convention to cover a wider range of transnational organized crime, including ML.

Countries are also required to ensure that ML is an offense under their domestic law and that it is punishable by appropriate sanctions.


📉 ML is a serious crime that undermines the integrity of financial systems.

By criminalizing it, countries can better disrupt the flow of illicit funds and deter criminals from engaging in illegal activities. 

It also enables law enforcement agencies to seize and confiscate the proceeds of crime, thereby depriving criminals of the financial benefits of their activities.


🏦 The responsibility for detecting and preventing ML falls on financial institutions such as banks, securities firms and insurance companies. 

They are required to implement AML programs to identify and report suspicious activities to the relevant authorities. 

These latter include customer due diligence, transaction monitoring and reporting of suspicious transactions.

Law enforcement agencies also play a critical role in investigating and prosecuting ML offences. 


⚙️ The FATF's third recommendation requires countries to have robust legal and regulatory frameworks in place to criminalize ML offences. 

This includes laws that define ML and prescribe criminal penalties for offenders.

Additionally, regulations must require financial institutions to implement AML programs.

The FATF also calls for international cooperation and information sharing among countries to combat ML on a global scale. 

Which is essential because it is often a cross-border activity that involves multiple jurisdictions.


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#compliance #financialcrime #moneylaundering #aml

Once a month, I interview an eminent compliance professional in The Laundromat & I dissect for you new money laundering, terrorism financing & fraud techniques, as well as ancestral methods. 🔬

If you are interested, you can check out my podcast & follow my newsletter! 🙂 ⬇️ 

🎙 
https://podcasts.apple.com/us/podcast/the-laundromat/id1648262953

https://open.spotify.com/show/4LkDkYI4EzZvQBapFk0qYI

https://www.deezer.com/fr/show/5227897

https://music.amazon.fr/podcasts/cd2d8336-2472-491a-ba8f-3b3c066892c1/the-laundromat

🗞 
https://www.linkedin.com/newsletters/money-laundering-techniques-6947129492909772800/

Recommendation 3: Money laundering offence

Head of compliance - EMEA @Flowdesk ⚖️ | Top Voice | spektr's Ambassador | Join a Vibrant Community of 40K+ Compliance Enthusiasts & Expand Your AML Knowledge Every Week 🧠

💸 Money laundering techniques 💸
 
➡️ Real estate 🏠
 
 
💰 Investing in real estate is a classic technique for laundering dirty money, especially in politically and economically stable countries.
 
On a daily basis, many real estate projects are done using escrow accounts.
 
They are usually held by real estate agents and brokers.
 
They are attractive to money launderers because of the large number of different transactions that can be conducted through them. 🔀
 
It helps them conceal illegal activity in the account, while appearing to operate a legitimate business.
 
 
Real estate is an attractive channel for laundering illicit funds because: 
 
📌 It can still be acquired in cash in many countries 💶
 
📌 The ultimate beneficial owner can be hidden 😶‍🌫️
 
📌 It is a relatively stable and reliable investment
 
📌 The sums involved are significant
 
📌 The value of the property can be increased through renovations and improvements 📈
 
 
Common methods of money laundering involving the property sector include:
 
📌 Use of fictitious buyers
 
📌 Use of loans and mortgages as a cover, which may involve cash refunds to introduce illicit funds into the economy
 
📌 Manipulation of real estate to conceal cash payments, hidden through over/undervaluation or through successive sales to increase the value of the property
 
📌 Structuring of cash deposits used for purchase ⚙️
 
📌 Rental income that legitimizes illicit funds
 
📌 Carrying out criminal activity, such as the production of cannabis in the property purchased 🌿
 
📌 Using illicit funds to improve the property to increase its value and the profits from its sale
 
📌 Use of front companies, shell companies or trusts and to conceal the beneficial owner and obvious links to offenders 🐚
 
📌 Use of intermediaries, such as real estate agents or lawyers to conceal criminal involvement, complicate the laundering process and provide an aura of legitimacy to the transaction 🤝
 
📌 Investment by offenders based abroad to hide assets and avoid confiscation by authorities in their home country
 
 
🚩 In order to prevent these practices, there are red flags to look out for:
 
➡️ The use of cash to accumulate funds for a property purchase, down payment or loan repayment
 
➡️ Multiple purchases or sales over a short period of time, sometimes involving over/undervalued property or straw men buyers 🥤
 
➡️ Use of offshore lenders 🏝
 
➡️ Unknown source of funds used for the purchase, such as foreign wire transfers where the originator and beneficiary are the same person
 
➡️ Ownership of the property is the only link between the customer and the country in which the property is purchased


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💰 Infamous money launderers 💰

➡️ Semion Mogilevich 🇺🇦


🔍 Often referred to as the “boss of bosses” in organized crime, Semion Mogilevich is a Ukrainian-born figure whose name is synonymous with large-scale money laundering. 

Known for his ruthlessness and intellect, Mogilevich is alleged to have masterminded financial crimes that span the globe, earning him a spot on the FBI’s Ten Most Wanted list.

Mogilevich didn’t just launder money, he industrialized it. His operations involved:

📌 Complex networks of shell companies in tax havens

📌 The use of legitimate businesses as fronts for criminal activities

📌 Sophisticated manipulation of financial systems

His schemes laundered billions of dollars, making him one of the most influential figures in financial crime.


🇨🇦 One of Mogilevich’s most notorious ventures involved YBM Magnex, a company listed on the Toronto Stock Exchange. 

Promoted as a manufacturer of high-tech magnets, YBM was, in reality, a front for money laundering and securities fraud:

1️⃣ Investors poured in over $150 million, unaware of the fraudulent nature of the business.

2️⃣ Funds were siphoned through offshore accounts, obscuring their origins.

3️⃣ When law enforcement uncovered the scheme in 1998, it exposed one of the largest stock frauds in North America.

This case highlighted the dangers of unchecked corporate and financial oversight.


🚨 Despite multiple accusations, Mogilevich has remained elusive. 

Based in Russia, he operates beyond the reach of many international authorities due to geopolitical complexities.

Authorities continue to link him to:

➡️ Drug trafficking and arms smuggling

➡️ Human trafficking networks

➡️ Financial crimes that exploit weak regulatory frameworks

The US are currently offering a reward of up to $5 million for information "leading to his arrest and/or conviction".

His ability to adapt and evade capture underscores the challenges in combating global money laundering.


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📅 The Daily AML Snapshot | 10/12/2025

Your morning briefing on money laundering, sanctions, and regulatory shifts.


1️⃣ Europol releases 2025 migrant smuggling report | 05/12/2025

43,000. That is the number of intelligence messages contributed to Europol's databases this year regarding migrant smuggling, a figure that has tripled since 2016.

The agency's 2025 activity overview reveals a disturbing rise in "content-creator academies," where criminals mimic influencer strategies to teach others how to digitally recruit and manipulate victims.

Financial flows are evolving rapidly, with networks increasingly integrating crypto-enabled payment systems into traditional hawala structures to obscure money trails.

Violence has escalated into a core business model, with gangs using torture and kidnapping to extort ransoms from migrants' families or intimidate rivals.

Investigators also highlight a shift toward "poly-criminality," where groups simultaneously execute human trafficking, document fraud, and complex money laundering operations.

The agency supported 266 cross-border operations this year, including a high-profile Spanish case dismantling a deadly network smuggling migrants from Senegal 🇸🇳  and Gambia. 🇬🇲

2️⃣ Illinois brothers indicted in $300M healthcare fraud scheme | 05/12/2025

The US DOJ has charged Minhaj Feroz Muhammad and Sufyan Feroze with orchestrating a massive scheme to defraud Medicare and Medicaid of nearly $300 million.

The indictment alleges the pair used four clinical laboratories in Illinois and California to submit fraudulent claims for COVID-19 testing services that were never actually provided.

Prosecutors claim the brothers laundered the proceeds by transferring funds through a network of businesses and purchasing luxury real estate overseas and gold bars.

While they billed insurers over $293 million, they allegedly succeeded in collecting approximately $65 million in reimbursements before being caught. 💸


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Europol migrant smuggling activity overview

📅 The Daily AML Snapshot | 08/12/2025 

Your morning briefing on money laundering, sanctions, and regulatory shifts.


1️⃣ EU updates high-risk third country list | 2025-12-04  

The European Commission has officially updated its list of high-risk third countries, adding Bolivia and the British Virgin Islands to the roster.

This strategic move compels obliged entities in EU member states to apply EDD measures when dealing with these jurisdictions. 

This decision highlights the ongoing scrutiny of jurisdictions with strategic deficiencies in their national AML/CFT regimes. 🌍

2️⃣ FinCEN issues trend analysis on ransomware activity | 2025-12-04

$2.1 Billion. That is the staggering total of ransomware payments reported to FinCEN between 2022 and 2024. 

The data reveals a record-breaking 2023 with $1.1 billion in payments, followed by a sharp decline to $734 million in 2024, a drop directly attributed to the major law enforcement operations.

The report identifies manufacturing, financial services, and healthcare as the top target sectors. 

67% of these threat actors now communicate exclusively via TOR to obscure their tracks. 😶‍🌫️

3️⃣ UK sanctions terrorist actor and organization | 2025-12-04

In a landmark action, the UK Treasury has utilized its Domestic Counter-Terrorism Regime to sanction Gurpreet Singh Rehal and the Babbar Akali Lehar organization. 

This is the first specific use of this regime to target Pro-Khalistan militant financing, effectively freezing all assets and banning Rehal from holding any directorships in UK companies.

Rehal is accused of purchasing weapons and funding recruitment for Babbar Khalsa, a widely proscribed terrorist group. 

This designation signals a shift in the UK's appetite for using domestic powers to dismantle niche funding networks that exploit the British financial system. 🇬🇧


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My wildcard prediction for 2026 🔮

➡️ The Lazarus Group executes the most devastating cyber heist in modern financial history...


...But they don't just steal funds. They destroy the bank’s memory.

Through a months-long infiltration, they corrupt core banking systems, wipe mirrored backups, and scramble cloud replicas.

The next morning, the bank is functionally data-blind.

Transaction records? Gone.

Customer histories? Corrupted.

Settlement instructions? Missing.

The global system freezes not because of insolvency, but because a major institution cannot prove what it owns or owes.

We prepare for liquidity crises. Are we for erased history?


This is the "unhinged" scenario I wrote for spektr's 2026 Wildcards initiative.

You want to check the other predictions they got for next year?

🔗 It's right there: https://lnkd.in/emuasK7m


Are you passionate about an AML related topic?

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If so, just send me a message to work out the details! 📩


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