Professional Money Laundering is a subset of third party Money Laundering – the laundering of proceeds by a person who was not involved in the commission of the predicate offence (a component of a more serious criminal offence). The Financial Action Task Force (FATF) defines ‘professional’ money launderers (PMLs) as those individuals, organisations and networks that are involved in third party laundering for a fee or commission.
 
ATF recognises the distinction between ‘Criminal’ actors, which are organised crime groups and ‘Complicit’ actors, who are knowingly involved or deliberately negligent towards the outcome of the money laundering process.
 
The principal clients of PMLs are drug dealers, fraudsters, human traffickers or any other criminal with a need to move or conceal ill-gotten gains.
 
 

Who are they?

 
PMLs are rarely involved in illegal activities, which generate dirty money. They are generally not concerned with the origins of the money that is moved but are aware that the money they moved is not legitimate.
 
They are not complicit actors but criminal actors profiting from money laundering activities and can survive law enforcement interdiction against any of its criminal or organised crime group clients, while still standing ready to support the next criminal clientele.
 
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