William Tolin Gay (Of Counsel-Los Angeles) authored “Introduction to Money Laundering: What It Is, How to Spot It,” appearing in the April 8, 2026, edition of the Daily Journal. The article provides an overview of money laundering: “the process of disguising illicit funds to make them appear legitimate.” Bill outlines the classic three-stage framework for money laundering – placement, layering, and integration – and emphasizes that these stages can occur through financial institutions, shell companies, real estate transactions, and other seemingly lawful channels. He discusses the components of the layering stage, “the separation of illicit proceeds from their source by creating complex financial transactions,” providing examples of specific areas susceptible to money laundering schemes. Also examined are regulatory scrutiny under U.S. anti-money laundering laws, such as the Bank Secrecy Act (BSA) and the Money Laundering Control Act (MLCA); the role of international cooperation in combating money laundering; and how lawyers can avoid legal and reputational risk by implementing strategic compliance measures related to their client trust accounts.
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