For all those people who blissfully tell me that their search of the OFAC list is legally sufficient for their AML/CFT responsibilities, please allow me to enlighten you. The Financial Industry Regulatory Authority [FINRA], America's primary broker-dealer regulator, now offers an OFAC Search Tool* on its website,** to allow a search of OFAC's sanction programme listings. FINRA succinctly states, on the page, "Firms must check this list on an ongoing basis to ensure that potential customers and existing customers are not prohibited persons or entities, and are not from embargoed countries or regions, before transacting any business with them." 

In a response to the perceived Iranian missile threat, four unnamed countries in the Persian Gulf have accepted placement of Patriot anti-missile batteries, together with their US military support staff. In the offshore waters of the Gulf, US Navy Aegis anti-missile cruisers are permanently on station. Whether these moves are intended to reassure smaller Gulf states, which have been looking anxiously at the progress of unimpeded Iranian WMD and ballistic missile development, or to discourage a pre-emptive strike from Israel, is not known, but risk levels are definitely rising. The risk of armed conflict has risen, even though this is not publicly acknowledged.

The document destruction and obstruction case against former Miami Field Division DEA SAC Thomas Raffanello is set to go to trial on 1 February, in US District Court for the Southern District of Florida, Fort Lauderdale Division. The defendant, and another individual, are charged with destroying documents in the Stanford Bank case that were ordered preserved by a Federal Judge. Raffanello, who was reportedly in charge of Stanford's Global Security in its Florida office, has alleged that electronic copies of the documents destroyed were retained.           

As a part of the World-Check Central Europe Tour, yours truly will be the featured speaker, at the 18 March seminar of the Association Romande des Intermediaries Financiers* [ARIF], to be held in Geneva. The title of my presentation is "Anti-Corruption Tools and Anti-Money Laundering Techniques." The venue is the Hotel Royal Manotel, 41 Rue de Lausanne, Geneva.

Banks that service American defence companies should be aware that the Government of China, disturbed over impending US arms deliveries to Taiwan, has publicly stated that it intends to impose sanctions upon American defence companies that deliver arms and military equipment to Taiwan. Unfortunately, the exact nature of said sanctions has not been specified, which results in increased risk to not only your defence clients, but potentially to your bank as well. 

Last year, I reviewed the pre-publication draft of "Essential Strategies for Financial Services Compliance," by Annie Mills*, whom some of our UK readers may know. I found it to be an outstanding compliance resource, and have written the Forward appearing in the book, which I have taken the liberty of reprinting below. 

Readers in Europe please note that the World-Check Central Europe Tour will take place in mid-March. Details will appear shortly on the World-Check Seminars Page.* In addition to yours truly, there will be presentations by World-Check Europe Director Gianluigi Bianchi. Monitor the Seminars page for information that will be appearing in February, regarding presentation topics, dates, venues and start times.    

Readers who are interested in current US activities in the field of counter-terrorist financing may wish to read the remarks* of Asst. Treasury Secretary for terrorist Financing David Cohen, which were presented recently before the Council on Foreign Relations.

Former attorney Scott Rothstein has pled guilty in United States District Court in Fort Lauderdale, Florida to the Money Laundering, RICO, and Fraud charges pending against him*. His techniques, which were the subject of our recent analysis and commentary article, entitled "Ponzi Scheme Tradecraft revealed," (World-Check 4 December, 2009) resulted in losses to investors of $1.2bn .  In his guilty plea, the defendant agreed to a forfeiture in that sum. He is reportedly cooperating with law enforcement authorities. 

Remember this: money launderers read everything that you are supposed to read, and they often get to it before you. The recent announcement* by the US Department of the Treasury, that the United States and Chile have agreed to sign a comprehensive bilateral income tax treaty, was certainly not missed by the laundrymen. Though Chile is neither a drug producing nor important drug transit country, its location in South America, and its thriving economy, make it a potential target for laundered drug profits. One of the provisions of the new treaty specifically mentioned this week was "full exchange of information between the tax authorities of the United States and Chile."