The Office of Foreign Assets Control [OFAC] has effectively loosened the terms of payment for US agricultural products destined for the Republic of Cuba. Farms sales of US goods are exempt from the embargo [Cuban Assets Control Regulations] administered by OFAC. A Final Rule*, published this week in the Federal Register, dealing with "Payment of Cash in Advance," is summarised here for the benefit of compliance officers at financial institutions whose clients export agricultural products to Cuba. 

it would appear that bulk cash smuggling into Mexico from Southern California is on the increase in 2010. Immigration & Customs Enforcement [ICE] has reported that they apprehended nineteen suspects in the act just since October 2009. Since many narcotics trafficking organisations find other methods of moving drug profits into the border states, to reduce the risk of seizure whilst in transit from northern areas of the US, expect that front companies will take delivery of large sums, via cheques or wire transfers, and then withdraw the cash for the onward final leg into Mexico. 

The unrest in a Nigeria still unable to resolve its problems manifested itself in a major demonstration by elements opposed to the existing government, who demanded that the cabinet be sacked. The vice president, attempting to fill the shoes of the ailing and invisible president, has himself made changes in senior officers, but the government appears to have lost the peoples' confidence. Add to that the ethnic and religious violence that continues to take place in the area where the two principal religions intersect, and you have a recipe for disaster. Runaway corruption, at the highest levels, continues unabated, and prudent risk managers, seeking to protect their financial institutions, really have no choice but to increase country risk for Nigeria.

The Office of Foreign Assets Control [OFAC] has published its updated "List of Authorised Providers of Air, Travel and Remittance Forwarding Services to Cuba." If your client base includes any of these categories, you should review it at this time,  

Prominent Florida forensic accountant Lewis Freeman, a major figure in many of the important Florida fraud cases of the past fifteen years, now himself indicted for fraud and embezzlement, this week entered a plea of guilty to a count of conspiracy to commit mail fraud. Freeman, himself an attorney, was often appointed by members of the judiciary to act as a receiver, and authorised to recover funds taken by fraudsters from local investors. He was charged with embezzling from those very accounts. 

Treasury has announced that the latest three Civil Penalty and Enforcement Information press releases, for February and March 2010, have been published* to the OFAC website. The magnitude of the civil fines, some of which have been accompanied by criminal penalties,** should indicate to you the zero tolerance approach that US law enforcement takes with violators of the existing sanctions against Iran. if you have any bank clients who, directly or indirectly, may be dealing with Iran, whether through Dubai or otherwise, you need to look at this. 

Can a government official "successfully" take a bribe without receiving money or a gift, and thereby minimise his chances of being exposed to an FCPA violation, because there's no paper trail ?  He certainly can, at the place where the Foreign Corrupt Practices Act (and the proposed UK Bribery Bill) meets trade-based money laundering. Professor John Zadanowicz, from Florida international University, who first scientifically proved the existence of widespread trade-based money laundering two decades ago, explains it all. 

The Department of the Treasury, in order to encourage the use of the Internet, has issued new regulations regarding the issuance of licenses for software, and other materials, that allow US persons to export such items to Cuba, Iran and Sudan. These exceptions to existing regulations are intended to stimulate the free flow of information in those countries. Internet use, including e-mail and chat, social networking, photograph and motion picture sharing, web browsing, and blogging, are all specifically included in the new regulation.

In case you missed the announcement, the United States Treasury will unveil the redesigned US $100 note, at a ceremony in the department's Cash Room, on 21 April. Why is this information tidbit important to compliance officers ? Career criminals (read: narcotics traffickers, arms dealers, traffickers in counterfeit goods, etc.) generally have a portion of their wealth in liquid, easily transportable form. This is because the nature of their dark business is cash on delivery, and also because they always store large amounts of cash for unexpected events, like flight to avoid prosecution, and for bribery, as well as routine aircraft, vessel and automobile purchases. They also have what you might call a rainy day fund. What currency do you think these assets are composed of ? Benjamin Franklins, (US $100 notes) of course.

Do you want to know what it is like to be an unsuspecting employee at an NBFI involved in a massive Ponzi scheme ? Having done exactly that, I have covered the subject in the latest edition of Confessions of a Money Launderer. For those who did not see my lecture on Ponzi schemes at the recent Florida International Bankers Conference, you can find a summary of the material presented at the latest Confessions chapter. The tactics and strategies employed by Ponzi schemers, as i saw them up close and personal, and the "red flags" you should look for, are all in there.