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World-Check 5 years ahead of OFAC designation
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FROM A
DIFFERENT ANGLE by Kenneth Rijock
DIFFERENT ANGLE by Kenneth Rijock
Financial Crime Consultant, for World-Check
1.
30 December 2008
The Committee of Experts on the Evaluation of Anti-Money Laundering Measures and the Financing of Terrorism, MONEYVAL, has adopted its Third Round Detailed Assessment report on Azerbaijan's AML/CFT. The organisation report renders the opinion that the country's new AML/CFT laws, passed on 31 October, 2008, do not "comply in a comprehensive manner with key international standards."
2.
30 December 2008
Reliable media reports have stated that Israeli jets have bombed and destroyed the numerous tunnels used by Hamas to bulk-cash smuggle US Dollars into the Palestinian Territory of Gaza. Since those were the primary method of covertly transporting dollars into Gaza (a lesser method being Palestinian diplomats coming through from Egypt), how will they now move the cash? Since Israel will most certainly continue* to restrict, or even block, shipments of its own currency (NIS) into Gaza, look for some new methods to emerge on dollar smuggling.
3.
28 December 2008
Financial institutions that continue to conduct business with those companies recently sanctioned by OFAC for providing financial support to the Mugabe regime in Zimbabwe would be well advised to consider the potential adverse consequences of their actions. These banks could suffer the loss of their critical US correspondent banking relationships, or even their own designations by OFAC, as the result of this conduct.
4.
28 December 2008
Eastern National Bank, whose principal place of business is in Miami, has entered into a stipulation with the Office of the Comptroller of the Currency (OCC) to pay a Civil Money Penalty of $200,000. Reportedly for BSA violations, the text of the stipulation appears at:
5.
27 December 2008
The Office of Financial Assets Control, OFAC, has removed designations from certain Cali, Colombia-based companies and individuals. Financial institutions with Colombian clients should review the OFAC press release.
6.
27 December 2008
The US District Court in Miami has entered an "Order Granting Defendant Kuehne's Motion to Dismiss Count One," the money laundering count, from the pending indictment against criminal defence attorney Benedict Kuehne. The Court held that "Congress has specifically exempted from the money laundering statute transactions necessary to preserve a person's right to representation as guaranteed by the Sixth Amendment to the Constitution.
7.
25 December 2008
All the best to all of you at this Holiday season. You will continue to see important content daily, at "From a Different Angle" in 2009, as well as the exciting story unfolding weekly in "Confessions of a Money Launderer." Our new Tradecraft series will continue to cover the tactics and strategies employed by money launderers and financial criminals, as well as our policy of appending hyperlinks to to original sources, court case numbers, and regulatory resources to our material.
8.
22 December 2008
The latest Financial Sector Review on the West Bank & Gaza, published this week by the World Bank, appears to conclude that the current Israeli policy of witholding NIS (Israeli Shekels) from Hamas-ruled Gaza, to bring economic pressure upon the government, may result in the smuggled-in US Dollar becoming the principal currency. This will increase the threat level of international banks in the region, who will face an increased risk of possible terrorism financing charges, from US law enforcement or regulators, if they supply dollars that transit the tunnels from Egypt, and end up in Gaza.
9.
21 December 2008
Readers who have been following my articles on the scandal involving unregulated high-yield investments in Jamaica,* and who now have seen the same thing has happened in Colombia, note it has now hit the United States. Members of the Haitian expatriate community in Florida report that they have also been victimised by the promises of extraordinary returns upon their money, only to lose their entire principal to fraudsters. We will be following this story for our readers. If any bank clients seek to withdraw their entire savings for some sort of unusual investment, and this news reaches your compliance department, read the Jamaican stories immediately.
10.
19 December 2008
Money launderers engage in a number of clever manoeuvres with respect to the company names that they create to confuse and deceive financial professionals and institutions. Today we analyse some of the most commonly-employed tactics, so that should you spy one, the scope of your due diligence enquiry will be automatically ramped up to enhanced due diligence.
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