FROM A
DIFFERENT ANGLE by Kenneth Rijock
Financial Crime Consultant, for World-Check
1.
The Chinese government in Macau has advised that operational control of Banco Delta Asia SARL is to be returned to its owner this weekend. The bank, which has been under government oversight since September 2005, is being returned without the filing of any criminal charges. MLROs and compliance officers please note that the US Treasury's determination that the bank is "of primary money laundering concern" remains in full force and effect.
2.
World-Check users located in the Caribbean can see me lecture in October at the Global Compliance Solutions Third Annual Anti-Money Laundering and Compliance Conference, at the Grand Cayman Marriott Beach Resort. My presentation will be on Monday, 8 October 2007, at 15:30s. The topic is "The Inside Story - a Former Money Launderer discusses his past and Emerging Threats facing Financial Services in 2007." Daniel Peak will also be on hand at the conference to assist anyone who may have questions about the use of World-Check in compliance customer identification programmes and due diligence enquiries.
3.
It has been reported that the move by the United States to tighten UN sanctions against Iran has been delayed until late November. Apparently opposition to the American drive to increase United Nations sanctions by Russia and other UN members was the reason for the slowdown in the imposition of sanctions.
4.
Two American attorneys have pled guilty to money laundering, and were sentenced to terms of imprisonment, supervision and fines in Miami last week. Marc Desiderio and Loel Seitel, who formerly practised law in Englewood Cliffs, New Jersey, Florida, and elsewhere, assisted marijuana traffickers by renting and purchasing real estate, and providing false information to government investigators who were investigating their clients. These clients were engaged in shipping marijuana obtained in California and Arizona, and transporting it for sale in the northeastern parts of the United States. One of their clients sustained a RICO conviction, and most likely he rendered substantial assistance to law enforcement that resulted in this case going to trial.
5.
OFAC has now listed fourteen of the Myanmar (Burma) government's ranking generals and governmental leaders as Specially Designated Nationals. Inasmuch as a number of European companies are presently involved in international trade with Burma, MLROs and compliance officers at these banks may find it prudent to enquire as to whether these PEPs hold accounts with your institution.
6.
Publicity surrounding a low-level organisation of blue-collar workers who "micro-laundered" cash for a Colombian narcotics group, showed that micro-structuring is alive and well in the United States. This is the common practice of "smurfing" (depositing) small amounts of criminal proceeds in multiple accounts. The recipient withdraws the funds via an automatic teller machine (ATM) in another country. The case that was in the news had a small two-person operation placing funds into over 100 accounts, and Colombian drug traffickers withdrew it from a cash machine at a bank that had no limit on withdrawals. One wonders what bright banker would associate his institution with a correspondent bank overseas that allows this practice.
7.
World-Check users in Malta, Cyprus and Greece will be happy to know that the World Tour 2007 is coming to their principal cities in November. Both yours truly and World-Check's Robert Mitchell will be presenting in those venues, and speaking on topics of major importance to compliance officers and money laundering reporting officers. The dates, times and locations of these lectures will be detailed in upcoming announcements on the World Tour page; keep a look out for it.
8.
Russian media have reported that other banks have lost their charters for AML and CFT violations. We list them below for the benefit of our readers, though there are unfortunately precious few details to report. Publicity surrounding Central Bank of Russia (CBR) charter revocations seems to have seriously declined in recent months.
9.
The question was raised by a compliance officer at an insurance company: why do I need a comprehensive due diligence database like World-Check? Having once served on the staff of a compliance department in a non-bank financial institution that sold insurance investment products, I can tell you from experience. Financial criminals routinely target any financial services firm that sells insurance, because the investment's prestige is of such a calibre that it is deemed extremely desirable. If you don't use a comprehensive due diligence database to vet your clients, financial criminals will be knocking on your door on a daily basis, using a wide variety of dodges and subterfuges to gain entry. How does one keep them out? A good due diligence programme that includes World-Check will go a long way to ensuring that you reduce the risk of money launderers successfully penetrating your firm.
10.
US President George Bush is rumoured to be considering the placement of additional sanctions against Myanmar, formerly known as Burma, which he may announce today at the United Nations. Compliance officers at international banks with clients who are still doing business with Burma are urged to monitor the situation closely.

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