World-Check Comment & Analysis closes out the year, having commenced on 1 June,exactly six months ago, having published just over 400 articles, including a dozen chapters of " Confessions of a Money Launderer ." We promise more content for 2007, more installments of " Confessions, " and a new feature, to be announced shortly. Thank you for your interest.

For those who choose to ignore certain US AML standards because their institution is outside the United States got another gentle reminder of the method by which US regulators exert power outside their national frontiers recently. Habib Bank Limited, of Karachi, Pakistan, entered into a written compliance agreement with the FDIC and New York State regulators on major AML issues. What's the trick ? US regulators can enforce BSA/AML laws and regulations against the bank's US subsidiary, and make sure the parent entity overseas signs off on the agreement. Of course, there will have to be deficiencies found during AML audits of your US subsidiary, but do you think they will be difficult to find ?

Edson Do Nacimento, the son of football immortal Pele, has been granted conditional release from prison in Brazil after serving ten months on suspicion of money laundering charges.

Compliance officers conducting due diligence on Dubai companies will soon have an additional information tool. The Dubai Chamber of Commerce & Industry has decreed that membership is now mandatory for all companies carrying on commercial business in the emirate. Only licensed professionals are exempt. Enterprising compliance officers would be well advised to develop a point of contact at the chamber, to facilitate access to all the available information it can provide to the financial industry.

Watch the supporters behind the opposing sides in Somalia, as careless financial institutions could end up facing the wrath of US or EU regulators by transacting business for the wrong side. The problem is, some customers acceptable to America may be unacceptable for the European Union. Mogadishu is now in government hands, and compliance for funds transfers into the countries of the Horn of Africa just got harder.

On Monday, Slovenia officially adopts the Euro. Readers of World-Check Comment & Analysis have previously been cautioned that currency movement and funds transfers into that Eastern European nation may indicate that laundrymen are moving illicit funds. Have you seen any this month ?

Mikhail Borisovich Khordorkovsky, formerly the wealthiest man in Russia, has been notified by the Russian Prosecutor's office that it is investigating him on suspicion of money laundering. Khordokovsky is currently serving a 9-year sentence for fraud and tax evasion in a case that many legal experts say was politically motivated.

The earthquake that occurred this week off Taiwan has severely disrupted telephone and internet service in that country and in Hong Kong, due to the damage inflicted upon undersea telecom cables in the region. Compliance officers should alert their staff that financial criminals may prey upon banks and NBFIs who are without access to their information and communication systems.

Apparently AML enforcement continues unabated in Russia, even during the holidays. The Central Bank of Russia revoked the charters of two more commercial banks for violations of the anti-money laundering and anti-terrorist financing laws and regulations. Both institutions are located in Moscow.

The FDIC, FinCEN and the State of Florida Office of Financial Regulation imposed a Consent Order upon South Florida-based Beach Bank, and fined the bank $ 800,000 for AML/BSA violations. The bank's assets, not including its charter, are being sold to another financial institution. Many of the specific AML violations contained in the FinCEN and FDIC orders were egregious, totalling over $1bn in transactions that the bank either failed to report, or did not report timely.