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Spotting money launderers rarely starts with something obviously illegal. More often, it begins with something that just feels… off
When most people hear “anti-money laundering,” or AML, they think of banks and finance departments. But the truth is, money laundering doesn’t just happen on Wall Street — it can happen in any workplace, in any industry and often in the most routine of ways.
Criminals aren’t always running elaborate scams from overseas. Sometimes, they pose as vendors, employees or contractors. All they need is a crack in the system — and that often comes from everyday tasks like hiring, approving payments or onboarding vendors.
Money laundering is the process of making illegally obtained money — often from crimes like fraud, drug trafficking or corruption — appear legitimate. Criminals do this by moving the money through a series of transactions or fake businesses to hide its true source. The goal is to “clean” the money so it can be used without raising suspicion.
Spotting money launderers rarely starts with something obviously illegal. More often, it begins with something that just feels… off.
Each of these moments can seem isolated and harmless. But when ignored, they become the open doors money launderers are looking for.
In one case, a nonprofit organization hired a contractor right before the holidays. The rush to meet end-of-year deadlines meant normal vetting steps were skipped. Months later, finance discovered that the contractor had been funneling fake payments into a shell account. By the time the fraud was uncovered, the contractor was long gone — and the organization had to answer to regulators and donors alike.
Just one employee feeling empowered to ask, “Are we sure about this?” might have prevented this.
It’s easy to assume your company is too small, too local or too cautious to be targeted. That is what money launderers look for:
Criminals know how to spot low vigilance: Fast growing teams without formal workflows, remote or hybrid workforces with less oversight. The less attention you pay, the more attention they give you.
Policies and checklists are important. But what really stops money laundering is a workplace where people feel safe to question the status quo. That culture is shaped by everyday choices — who we hire, what behaviors we reward and whether integrity is something we talk about only once a year or live out every day.
It’s also shaped by who gets trained, which should be every employee who touches payments, works with vendors, reviews contracts or makes hiring decisions — which, in today’s world, is just about everyone.
As businesses hire internationally or work with global partners, the risks grow. Vendors abroad may operate under different rules — or none at all. Background checks might not be as rigorous. And in some countries, whistleblower protections are weak or nonexistent.
For example, a fast-growing tech company outsourced hiring to a third-party firm in Southeast Asia. That firm turned out to be a front for laundering stolen funds through fake invoices and ghost employees. By the time someone in finance flagged the discrepancies, the damage was done — and HR had to rebuild processes, restore trust and explain the oversight to leadership.
Global scale demands global awareness. And it requires employees across departments to understand the risks and know how to respond.
Preventing money laundering starts by being alert, asking questions, noticing when something feels wrong and knowing what to do about it.
That might look like:
If you’re not sure whether a process has been followed, check. If something seems vague or rushed, say so. And provide employee training and reporting channels — anonymous or otherwise. Silence is what criminals count on.
Our 25-minute Global Anti-Money Laundering training provides an overview of international anti-money laundering (AML) compliance obligations and sanctions. The course explores how to comply with global AML laws, including requirements under the US Bank Secrecy Act, OFAC (Office of Foreign Assets Control) and FinCEN (Financial Crimes Enforcement Network), as well as Canada’s FinTRAC and Ireland’s Proceeds of Crime Act. It also covers high-risk countries, regions and Specifically Designated Nationals (SDNs) under the US Sanctions list.
We also offer a shorter, 15-minute Anti-Money Laundering course designed for domestic organizations that operate in the US without an international presence. This version provides a concise overview of US-specific obligations under the Bank Secrecy Act, FinCEN and other related AML regulations.