MONEY LAUNDERER by Kenneth Rijock
So, what else did I show the students in the investigations classes? Here are a final few that may one day allow you to extract an incriminating gem which will cause you to decline an otherwise promising client who is, in truth and in fact, a fraudster. When that happens, you know that you have properly discharged your compliance role. Though reference each day to all the Internet resources I have discussed during the past three weeks is not necessary, I hope that I have been able to broaden your Internet horizons a bit with these four lists of resources.
The final four resources for your information and potential use:
- Electronic bulletin boards that discuss financial crime: Several of these forums, whether they invite postings, or are a soapbox for the webmaster to catalogue, "naming & shaming," various global financial criminals, fraudsters, and sundry other suspects, detail data on allegedly guilty individuals and entities.This is not a blanket recommendation, for the data is often unsourced, rarely names places, dates and cases, but there is a place for it in your bag of compliance tricks. Just remember to take the information with a grain of salt. It can open your eyes to obscure civil frauds not otherwise reported anywhere, or to traveling, transglobal criminals. Use with discretion.
- Websites that report political contributions: Even financial criminals send money in to influence government leaders running for reelection, or political parties. Why? Well, they may want to apply for a government-backed loan in the future, or want to call in a favour sometime. Or appear more establishment than they really are. these websites allow you to verify the amount of their contributions, when & where. It is a little bit of one's seemingly private life that you can discover in assembling a profile of a new customer.
- US regulator websites: Since easily-accessed OCC, FDIC, FinCEN, OTS and Treasury websites have search features, it is important that you vett obscure financial institutions when they are the only reference proffered by a prospective client. The bank may have had a number of Cease and Desist ordered that indicate serious AML/CIP deficiencies. Perhaps the customer is not so clean, and they failed to uncover that little fact. The "bank" may not even be a licensed institution, but one which is a bogus poser, or with a deceptively-similar name that turns out to be a shell bank offshore, with no physical bricks-and-mortar location.
- Administrative Agency ruling and opinions: Is the client the owner or general manager of a business that is tightly regulated by a state or federal agency? Then check out whether he or she has been sanctioned or penalised by agency actions that adjudicate disputes. You may find your client is not as nice as he seems.
Hope you found something to add to your compliance toolbox.
Next week: we return to more stories of my experiences.
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