In Company And Conversation With Bob Mazur

November 2021 Martin Woods

On Tuesday I was in London, where I had the great privilege of talking with my good friend Bob Mazur (The Infiltrator). It was a small an intimate event, supported by intelligence partners, Kompli-Global, YOTI and Synectics Solutions. Given the need for security and discretion when meeting with Bob, this was an invitation only event, held in the private area of city restaurant.

Great food, good wine, stimulating conversation and good company. Thanks to all who attended and contributed to the event. The overarching theme was data, data and data, specifically corporate identity data and personal identity data.

So, what does Bob Mazur know about data and anti-money laundering in 2021, given he took down the Bank of Credit and Commerce International (BCCI – also known as the Bank of Corrupt and Crooks International) in 1990? Bluntly, he knows far more than most of us. Indeed, he may know more than all of us, given he has worked both sides of the business, as both a money launderer and anti-money launderer, advising banks, governments and lawyers.

Bob is an avid reader of all money laundering investigations, prosecutions and deferred prosecution agreements. At the same time, he maintains a global network, which keeps him updated and calls upon him for advice. He knows what is going on, he knows how the money is laundered, he knows the where, why and when, because he still makes it his business to know.

Thus, what better man to ask about the application of data, big data, machine learning and artificial intelligence to the fight against money launderers. You see, Bob loves data, more pointedly, intelligence and as he reflected upon his former life as an undercover money launderer he told the attendees at the event of his hunger for intelligence, he asserts he was an intelligence junkie. Nowadays, his addiction is under control, but not cured, he still craves the occasional intelligence fix.

Bad company

Bob was once in the heart of Pablo Escobar’s business, working adjacent to people who were themselves trusted lieutenants, adjacent to Escobar. Simultaneously, he was a valued customer of a bank, BCCI, that openly offered money laundering services to clients seeking to hide and launder funds. He recorded conversations and used intelligence to seize tonnes of cocaine and ultimately imprison high ranking drug traffickers, money launderers and senior bankers.

You get the picture, so I asked Bob, what is the primary data we should use when assessing money laundering risks presented by customers and transactions. His answer was short and to the point, “Pay attention to international fund transfers, cash and importantly the value/volume of transactions”. I therefore asked him, how all that fitted into his money laundering activities. He described how senior employees at the BCCI told him to go to Panama and meet with the law firm Mossack Fonseca1 to set up companies to facilitate the laundering. In essence, in the late 1980s Bob was told to use offshore companies to hide identities and launder money. Fast forward to 2021 and the Pandora Papers, I asked Bob, what has changed? And the answer was, not a lot. The fact is, we in the global anti-money laundering (AML) community have done nothing to cause the launderers to change. If it’s not broken, they have no need to fix it.

One man and his cash

All of which caused me to ponder, have we been looking at and focused upon the wrong data, the wrong customers and transactions, leading to the wrong outcome? It struck me that the bankers were not only helping Bob to launder the money, they were also protecting him, seeking to ensure he was not identified and subsequently captured by the authorities.

I asked the logical question, “Bob, did you use any of your personal accounts to launder the money?” Bob instantly said, “No, of course not”. As he did so he laughed and in a polite way, ridiculed me. I followed up and asked, “Why not?”, The answer was delivered in a clam and assertive manner, “I didn’t want to draw unwanted attention to myself”. He then described one of his laundering schemes involved a UK lawyer, with a connected office in the British Virgin Islands (BVI, also known as Beneficiaries Virtually Invisible), provided structures and accounts which ensured Bob was totally hidden. The lawyer signed the instructions and ensured Bob’s name appeared nowhere.

Eureka

Professional money launderers do not launder money in their own name, they use and hide behind offshore corporate entities. I told Bob of the recent revelation that 95% of Nat West Bank personal accounts have never debited £5,000 or more and I asked him how useful such accounts were to a professional money launderer. He said they weren’t.

Now some of you are saying, yes, but what about other money launderers? To which I reply, what about them? If they are not professional, they are by definition, amateur; small time; small money and small thinking. If we are applying a risk-based approach to money laundering, surely we are looking to counter the biggest risks and these are not found within accounts that do not debit £5,000 or more.

Here’s the conclusion, professional money launderers do not use personal accounts, they use corporate entities, often offshore, but they are the people behind these entities, pulling the levers, pushing the buttons and laundering the money.

Data is the answer

Corporate data is vital to understand what legal entity a firm or bank is undertaking business/transacting with, but it is the real steering minds and individuals who benefit from the activities of the said corporate entities who need to be identified. All of which should cause the AML professional to consider, why does the BVI feature so much in the Panama Leaks and the Pandora Leaks? Of course, it does not follow, all BVI companies are somehow engaged in or connected to money laundering.

There is an address in north London, where in excess of 100,000 UK companies and partnerships have been or are currently registered, likewise not all of them are bad, but the address features more than any other in FCA waning lists.

The money laundering data is clear for all to see, the risks are to be found in corporate entities, not individual/personal accounts. Pursuant to this, how can we move the thinking and practices to focus upon these corporate entities? How can we educate regulators to accept these small, almost insignificant risks within the vast majority of personal accounts? All of which begs the question, “What is more important within AML, who a customer is, or what a customer does?”

I’ll be back

Bob has recently finished his second book which will be published next year. The film rights for the book have already been bought and we eagerly look forward to both. As we drew the conversation to an end, Bob said, “I’ll be back” and has promised to return next year, to continue the conversation, to help all of us with our AML learning and development.