Aleksei Frenkel, an executive at Russia’s VIP Holding Bank, was sentenced to 19 years in prison late last year. His crime? Hiring three Ukrainian taxi drivers to kill Andrei Kozlov, the First Deputy Chairman of the Bank of Russia, the country’s central bank, and the country’s highest-ranking regulator of consumer banks. Kozlov had sanctioned Frenkel’s bank for money laundering missteps. This case proves how difficult and, in this instance, dangerous it can be to shine the light of regulation into a fragmented, closed and chaotic banking system.

While there remains doubt as to Frenkel’s actual guilt or innocence (a lead provided by the Austrians leading to a money laundering scheme Kozlov was shutting down was apparently disregarded by Russian authorities), the story does reinforce the need for including geographic factors when risk scoring your customers. Are they located in countries high in corruption (as rated by Transparency International for example)? Do they do business in locales with significant levels of financial crimes, organized crime or narcotics traffickers? Can local officials be bribed or intimidated to look the other way? Any of those factors might make your institution more vulnerable to being a pawn in a money laundering scheme. Having the ability to consider such factors in your AML and KYC processes could help you level the playing field in a game where the players are anything but equals across the board.