Money Laundering Bulletin
From BMPE to CMLN: how compliance missed the bigger picture
The past five years have seen an unexpected change in the AML typology landscape. From the once-dominant Black-Market Peso Exchange (BMPE) to the newly defined Chinese Money Laundering Networks (CMLNs), the compliance community faces an uncomfortable truth: banks are often the last to know when the ground beneath them has already shifted, says Mikhail Karataev.
Mikhail Karataev (karataevnew@gmail.com) is an independent AML professional, based in Florida, USA.

The past five years have seen an unexpected change in the AML typology landscape. From the once-dominant Black-Market Peso
Exchange (BMPE) to the newly defined Chinese Money Laundering Networks (CMLNs), the compliance community faces an uncomfortable
truth: banks are often the last to know when the ground beneath them has already shifted,
says
Mikhail Karataev.