How do we give fraud and money laundering investigators the confidence to confront suspects, customers and others who are often bold, assertive, aggressive and deceptive?
Fraudsters are sometimes known as ‘con men’, which is an abbreviation for men who are confidence trickers. Both money launderers and fraudsters seek to deceive others and ordinarily operate with confidence in order to convince their victims and others to believe in them and fall for their deceit.
Investigators within firms frequently find themselves in dialogue and confrontation with fraudsters and money launderers. In the event the investigators lack confidence, the fraudsters are more likely to prevail by exploiting this weakness. Thus, how do we help investigators to develop their confidence? I believe this is an area where a former law enforcement officer will commonly have an advantage because he/she has previously been accustomed to dealing with confident and aggressive con men.
Knowledge equals power.
This being so, does it follow that the lack of knowledge presents a weakness? And what knowledge is relevant here? Well, knowledge of the applicable laws is beyond necessary, it is vital, whereas knowledge of how money launderers and fraudsters think and operate is helpful and most welcome. Which leads on to the next question, where do young money laundering and fraud investigators obtain knowledge about how fraudsters and money launderers think?
I was an experienced police detective, but I did not learn all I know through practice and operational work alone. No, I attended multiple courses, including a three-week, residential company fraud course, where the instructors were seasoned fraud investigators. OK, I was a trained law enforcement officer, but nowadays fraud appears to be coming less and less of a priority for law enforcement agencies, even more so during these Covid-19 times, notwithstanding, fraud is on the increase.
Some authorities are suggesting the UK government may have lost as much as £26 billion to fraudsters abusing the Covid-19 business continuity loans. I have looked at some of these frauds and determined they were easy to identify and prevent, but they were not prevented. Simultaneously, AML and fraud controls failed, albeit the banks have a 100% guarantee for the loans from the UK government. Armed robbers of yesteryear never stole so much money from banks or governments, so how and why are we now losing so much money to organised fraud gangs?
The answer is very simple, crime has changed, indeed it constantly changes, and we do not keep pace with the fraudsters. In America armed guards stand within bank premises, but there are no armed guards online. Criminals have learned, there is more money to be made with fingers on a computer keyboard than there is to be made with a finger upon the trigger of a gun. In addition, on the rare occasion a criminal does point a gun and demand money, his/her actions are clear to see, there is no ambiguity, no doubt and consequently an intervening party, such as the armed guard or a police officer, can confidently engage the suspect.
Fraud is different because the fraudster seeks sew doubt and in so doing, he/she challenges the confidence of the investigator. Thus, please allow me this opportunity to share some investigative tips with you.
- Fraudsters do like to deal with people who say they don’t know what is being spoken about; those who seek explanations; those who seek more information.
- Do not be intimidated by them; they may seek to make you feel stupid because you do not know something, take it from me the really stupid ones are not strong enough to admit they do not know, and the fraudsters play upon this.
- Just like in the movie The Sting, fraudsters are looking for a mark and the easy marks are the stupid and weak marks.
- Treat the encounter as a learning experience, retain an open mind, do not ignore the gaps and do not allow the fraudster to fill them with nonsense, which obviously means something makes no sense.
- Fraudsters do not like to be asked to provide reference points, which an investigator can use to research or corroborate the fraudster’s story. Thus, in the event they previously worked for bank X or firm B, ask them who they worked with; the address of their office/branch; their manager’s name; their old work email address. Importantly, ask who you can verify this with?
- Challenge generic email addresses – in 2020, businesses people do not run their operations and customer relations through Gmail, Hotmail or me.com.
- Always seek a website address, businesses in 2020 do not operate without one.
- Ask for a copy of their CV/resume – this should be full of reference points and therefore they are likely to refuse to provide it.
- Then go behind the webpage, when was it set up, how and where is it hosted etc.
- Challenge bad spelling and bad grammar, ask yourself, would the CEO of your bank/firm want his/her staff sending out emails or letters with ban spelling and grammar? The answer will be no, so why does a fraudster think bad spelling is OK?
- Do not be intimidated by aggression, as this is often a sign that your instincts are right. Pursuant to this, trust your instincts, do not supress them and do not allow others to belittle them.
- For supervisors, support your staff and tell them, they are not to tolerate abusive or aggressive behaviour from anyone, including customers. Give them the confidence in you, that you support them, this way they act more positively, with reduced anxiety.
- During these restrictive Covid-19 times identify ways in which you provide mentoring to young investigators who are currently missing chats with senior colleagues; not overhearing interesting conversations and consequently, their ‘on the job’ learning is suffering.
- In the event a fraudster threatens to take his/her business somewhere else, let them go, because no single customer is bigger than your bank/firm and when investigating suspicions of money laundering or fraud, you are your firm. Remember that, you are your firm, you stand against the fraudsters and the money launderers, you protect legitimate customers, colleagues, shareholders and executives. Your actions can make your bank/firm a hostile environment for money launderers and fraudsters.
Legitimate customers can always be persuaded to be appreciative of your fraud/money laundering prevention endeavours because next week you may use the same approach to stop someone stealing from their account.
If you act with confidence, you will immediately present an obstacle to the fraudsters and many of them will walk away to seek another ‘mark’ elsewhere. Confidence is key to your success as an investigator, in contrast your weakness will be exploited by, and therefore help the fraudster/money launderer. Don’t be put off, do not give the benefit of the doubt and adhere to processes which have proven track records of success.
In conclusion, do not let the fraudster’s problems become yours. In the event he/she cannot or will not provide the data you seek; the problem is not yours. To reconcile this, put yourself in the shoes of the legitimate customer being asked to provide data, which is accessible to you and ask yourself, “is this reasonable?” In the event the answer is yes, the fraudster/money launderer should also act reasonably and provide the data.
Thus, take control and stay in charge. Fraudsters like to talk rather than listen, because they are constantly selling their version of ‘their truth’. They seek to dominate conversations and intimidate you, don’t let them bully you, act with confidence, because you and your bank/firm are bigger and stronger than the fraudster.