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Taurus Compliance Consulting, LLC
Money laundering in the dark does not refer to back alley transactions or those conducted in parking garages without lights, but to transactions facilitated on complex trading avenues of un-displayed market liquidity more commonly known as "dark pools". Dark pools represent a source of liquidity in the electronic market place that is unknown to the average investor and have seemingly been given a âpassâ when it comes to the transparency required by other trading venues with respect to displayed liquidity.
These dark pools are set-up to serve as legitimate trading venues that offer benefits such as market stability and trading efficiency. Institutional traders, for example, can acquire or dispose of large blocks of shares without significant market impact. However, they also raise concerns. In particular large transactions are facilitated in a seemingly undetectable venue in millisecond timeframes. By their very nature and structure they completely lack any degree of transparency until after the trade has been executed, which does little for price discovery. Furthermore, the structure of a dark pool makes the current regulatory framework designed to detect and deter money laundering much more difficult.
The introduction of dark pools makes it all the more important to focus AML controls on the placement stage of money laundering where the illicit funds are first introduced into the financial system. This is the stage where the funds are most vulnerable to detection since they are still close to the illegal activity. Once the funds have gone dark the ability to detect the monies as having originated from illegal activity is greatly diminished.