When I was a compliance consultant, the new accounts staff at times seemed to be as committed to deceiving me into accepting unsuitable new customers, as I was in rejecting them. Was I just being paranoid, or were they really looking to fool me? I cannot say, because just when I wanted drop a claim of obstruction on one, he would come through with all the documents I had originally requested. Zealous sales practices I can tolerate, but when New Accounts/Sales tries to finesse the truth, I draw the line. The usual methods involve the use of business entities; if one is not careful, unwanted officers, directors, and even shareholders can make it past the gateway. You do not want to hear, two years later, that a law enforcement subpoena was served upon your company, naming an individual who is a client, or that you violated OFAC sanctions, or that documents were seized from an individual who has a minor relationship with your firm, following his arrest for major crimes. Catch them at the portal, please. Shall we return to business organisations, then?

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