The departure of both William Fox and Robert Werner from the Director position at FinCEN, for lucrative jobs in the private sector, is indicative of a major problem. We simply cannot afford to lose qualified leaders in the ongoing battles against financial crime and terrorist financing. Perhaps we need to take sufficient steps to ensure that the Financial Crimes Enforcement Network has long-term leadership.

I recently saw a brochure where the writer, who from his choice of words was clearly a marketer, and had not ever been a compliance officer, stated that the minimum of 25% ownership in a company was "increasingly being accepted" as the cut-off above which customer due diligence is necessary. The compliance officer who arbitrarily sets up a floor below which he or she will not check minority shareholders is operating in dangerous waters. Here's why.

For Peter Lombardi, formerly the President of life settlement fraudster Mutual Benefits Corp., bad things come in threes. First, he settled with the SEC in a civil action, and paid out $6m. Second, he pled guilty in US District Court to securities fraud, and was sentenced to 20 years in Federal prison and ordered to pay Restitution in the amount of $839m. In the latest instance of justice being served, he has settled a class action suit brought against him for a reported $ 1.5m. He will now most likely have to sell all his remaining assets to raise sufficient funds. Will he have any assets left? It is doubtful, but if so, there are other defrauded investors who also have civil actions pending, and they certainly would like a piece of him.

A United States District Court Magistrate Judge has set down for hearing on 28 August a governmental request to extradite General Manuel Noriega to France to be tried on money laundering charges there. Noriega is scheduled to be released from US custody in September, having then served two-thirds of his twenty-year sentence. The general's attorneys have taken the position that he must be returned to the country where he was captured during hostilities, Panama, pursuant to the Geneva Convention on Prisoners of War, because the court, speaking through US District Judge William Hoeveler, declared him a POW in 1992.

The American Embassy in Nigeria has reportedly issued major restrictions upon the issuance of US visas to Nigerian governors. Nigerian media has stated that the president of the country has approved the new US measures. The beauty of it is that it is not just the US, but also Nigerian officials who will determine whether a governor is too corrupt to be allowed to visit in the United States, where he could seek to hide assets illegally obtained.

When your financial institution or NBFI is named in the newspapers as banker to a criminal defendant or fraudster, or when the bank is identified in a civil court filing or an indictment as having unwittingly facilitated money laundering, reputation damage is inevitable. Whilst it is difficult or impossible to quantify just how many customers move their accounts elsewhere as a result, or whether a large number of prospective clients choose to go to your competition, it happens. The risk of such untoward events occurring can be minimised, however, through a regular programme of KYC follow-up. These procedures can prevent many of those public relations nightmares.

With the continued closing of the Rafah Crossing between Egypt and Gaza, Hamas must now find another way to practise bulk cash smuggling. Since it has this week promised to pay the salaries of not only its own security service, the Executive Force, but also local government staff, it must have found a way to acquire US dollars and, more importantly, a new way to move them into the Territory of Gaza, over which it now exercises total control. How is it doing it?

Casa de Cambio Puebla, SA, a major Mexican money service business has filed suit in United States District Court, a Petition for Return of Seized Funds, more than $11m in seized and frozen funds of the MSB, held in London & Miami*. The seizure warrant was served on 16 May, 2007 in Miami, but the US government has not filed a civil forfeiture action, and the MSB alleges that the US Attorney's office refuses to release any information, saying that, since the affidavit is sealed by the Court, it cannot make any disclosures. The Petition was then filed to resolve this matter.

The first indictment has been issued for violations of the 1999 Kingpin Act; Fernando Zevallos, who is currently serving a 20-year sentence in his native Peru for drug trafficking and money laundering. Zevallos, who was designated a Significant Foreign Narcotics Trafficker Kingpin, or SDNTK, in 2004, has been a target of US law enforcement for many years. He and his wife owned and operated a major Peruvian airline, Aero Continente SA, which he allegedly utilised to launder drug profits.

The US and EU may respond to Eritrea's massive shipments of arms to Islamic militants in Somalia by imposing sanctions. Several covert weapons deliveries to Mogadishu, which reportedly included surface-to-air missiles, are contributing to a major increase in violence in that troubled country in the Horn of Africa. It is believed that these weapons shipments have been received by Al-Shabab, a military element believed to be controlled by the radical Islamic Courts Union.