FROM A
DIFFERENT ANGLE by Kenneth Rijock
Financial Crime Consultant, for World-Check
Our focus is risk assessment, not politics
30 November 2007

This week I received a letter from a reader who was plainly unhappy with my coverage of money laundering in the Bolivarian Republic of Venezuela. He asked me to refrain from politics in my analysis articles. That is a fair question, and it deserves a straight answer. "From a Different Angle" is a comment & analysis feature that attempts to cover the emerging threats facing compliance officers and money laundering reporting officers. Our stated purpose is to aid our readers in risk assessment and management. There is not, and never will be, a political agenda, on these pages. We all live in a post- 9/11 world, with extreme, and even fatal, consequences for any institutions that fail to ascertain threats, and act accordingly. But on to a specific answer to his question.

My compliance position on Venezuela is quite clear; for the following reasons, financial transactions with individuals and entities from that country range from high-risk to an unacceptable level of risk:
  • Evidence that the laundering of Colombian narcotics profits is not only widespread inside the country, and without any meaningful attempts by the Venezuelan government to control it, but it even appears to have the support and assistance of major figures in the government. The Antonini/del Nogal scandal is but the tip of the iceberg.
  • Extensive financial commerce with the Islamic Republic of Iran, including but not limited to, transactions with Iranian financial institutions that are sanctioned by OFAC. One of Venezuela's government-owned banks actually has a branch in Tehran. How does on protect against indirect transfers from Iran?
  • The presence of Hizballah, Al-Qaeda, ETA, and operatives from other designated terrorist organisations inside Venezuela. There is even a local official presence, Hizballah Venezuela, that openly solicits members.
  • The overtly excessive material life styles of young members of the so-called Bolivarian elite, who are PEPs and their close associates, whose spending far exceeds their stated income. Theft of government funds, bribes, pay-offs, kick-backs and other rampant corruption is out of control in that country.
There are many more red flags of high-risk activities, but the ones listed above are more than sufficient, in my humble opinion, to warrant Enhanced Due Diligence and Source of Funds enquiries on all substantial transactions involving Venezuela, prior to making a decision on acceptance of the client. To do any less constitutes compliance malpractice in today's troubled world.





The facts and opinions stated in this article are those of the author and not those of World-Check. World-Check does not warrant the accuracy of any facts and opinions stated in this article, does not endorse them, and accepts no responsibility for them.

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