2min chapter

The Jordan Harbinger Show cover image

450: Frank Maderal | The Dirty Money Behind Illicit Gold Smuggling

The Jordan Harbinger Show

CHAPTER

Do You Have an Inadequate Anti-Money Laundering Program?

In theory, you could be guilty of having an inadequate anti-money laundering program even if no money laundering was taken place. To prove deliberate ignorance would be proving actual involvement in the money laundering. This is just the failure to take reasonable steps to find out. It's separate here from the money laundering itself. It's just your failure to have a program. And your program is not supposed to be perfect. You really have to do a good job and have some sort of controls,. Some process in place so you know your customer.

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