FROM A
DIFFERENT ANGLE by Kenneth Rijock
DIFFERENT ANGLE by Kenneth Rijock
Financial Crime Consultant, for World-Check
1.
30 March 2007
OFAC has today issued a number of SDN designations against individuals and entities located in the Democratic Republic of the Congo and Uganda. They are listed in this article for your immediate review, should you be banking nationals or organisations from these countries. Compliance officers familiar with Victor Bout should note that he is reported to be the owner of those listed business entities marked with an asterisk. UK MLROs please note that the Bank of England soon thereafter issued financial sanctions against those same individuals and entities. (See BOE Financial Sanctions List).
2.
30 March 2007
The Office of Foreign Assets Control, or OFAC, has today given Iran's Defence Industries Organisation an SDN designation, for Non-Proliferation Treaty violations, regarding Weapons of Mass Destruction. DIO is a conglomerate, containing several state-owned/state-run companies that provide Iran with military manufacturing capability, and also supply technical assistance.
3.
29 March 2007
The US Treasury's Office of Foreign Asset Control, or OFAC, has added a long list of new individuals and companies from Latin America as Specially Designated Narcotics Traffickers, or SDNTs. MLROs and compliance officers who have any clients from that region should immediately World-Check those clients.
4.
28 March 2007
Whilst performing due diligence KYC research on prospective customers, try a couple of these offbeat yet effective websites to locate potential family members or close associates of PEPs.
5.
28 March 2007
Recent awareness about "slush funds," special accounts of government agencies, NGOs, nonprofits that are used to pay for unauthorised and personal expenses of their officers, to quietly feather the nest of certain individuals whose assistance is deemed necessary, or for some other unlawful, illegal, or improper purpose, should serve to remind us that even the most conservative, traditional client may have a "special" account at your bank into which operating funds are improperly diverted and where many of the payments constitute such varied criminal acts as bribery, embezzlement, kickbacks and money laundering.
6.
28 March 2007
The Deputy Secretary of the Treasury, Robert Kimmitt, has issued a statement warning the global financial community against manipulative actions by the Iranian Bank Sepah and Bank Sepah International, whose UN sanction designation was reconfirmed by United Nations Security Council Resolution 1747, for financing in support of Iran's development of ballistic missile systems, which are reportedly intended as future delivery systems for products of Iran's nuclear weapons (WMD) programme.
7.
27 March 2007
The New York State Department of Banking and the Federal Reserve Bank of New York, and the New York branch of the Italian bank Intesa Sanpaolo S.p.A. have signed a Written Agreement that addresses BSA and anti-money laundering compliance policies & procedures.Though no monetary fines or penalties were levied, the consent agreement details compliance and risk-management deficiencies, and programmes that will remedy these shortcomings.
8.
27 March 2007
Compliance officers in industries that take shortcuts by solely using the OFAC list to sort out terrorists amongst potential clients, risk being sued by the very individuals that they turn down when false positives are used to deny credit, decline business, or terminate relationships. Statements recently made by lawyers' groups have indicated that they are will conduct litigation against companies who have damaged their clients by such actions. If there was ever a reason for compliance officers to go to management and seek to minimise risk by the acquisition of a KYC database, this is it. Imagine the reputation damage your company would incur if named in a newspaper article as the bad actor in declining an account relationship or a sale, where a consumer was clearly not the terrorist named in the OFAC list, and he was denied a mortgage due to an Arabic middle name that resembled some terrorist's alias.
9.
26 March 2007
The United Nations Security Council has passed a resolution that includes a total ban on Iranian arms exports, together with a large number of additional sanctions, including a freeze on the assets of 28 individuals and organisations that are allegedly involved in that country's Nuclear weapons and missile delivery systems programmes.
10.
23 March 2007
The United States Attorney for the Southern District of Florida has filed a motion to reduce the 70-month sentence meted out to Indian casino lobbyist Jack Abramoff. The stated grounds are the rendering of substantial assistance to the government in the investigation and prosecution of other targets in the Washington corruption probe. This assistance helped convict a former US Congressman. The government has asked for a stay of the court's ruling until the defendant completes his cooperation, meaning that he still must assist in the prosecution of other targets in the corruption scandal.
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