Newswire:
World-Check releases White Paper on Piracy
|
World-Check releases FCPA White Paper
|
World-Check expert seminars attract 600 delegates in 13 cities worldwide
|
World-Check renews partnership with the UK's Child Exploitation and Online Protection Centre
|
More Newswires...
CONFESSIONS OF A
MONEY LAUNDERER by Kenneth Rijock
MONEY LAUNDERER by Kenneth Rijock
Financial Crime Consultant, for World-Check
Confessions of a Money Launderer - Part 76
27 October 2008
We return to my experiences at the compliance desk. For me as a compliance officer, it was all about efficiency, for the never-ending pile of files that were delivered to my desk daily had to be completed, and returned for processing after approval, unless there were issues with the prospective client, and then everything stopped, whilst I made my case for declining the client and his business. New accounts staff/client relationship managers would frequently call me up, or even drop in unannounced, to enquire as to the status of a particularly lucrative potential client's file. Just as many businessmen dislike lawyers, claiming that they always kill a transaction, sales staff often heaped anger upon the compliance staff, complaining that they rejected otherwise acceptable clients. I call it shoot the messenger.
More on how I conducted due diligence and customer identification on various entities.
Partnerships didn't come by every day, but some new clients apparently folded their investments into existing entities, or relied upon somebody's legal or tax advice.
Regarding limited Liability Companies, commonly known as LLCs:
Sometimes, the clients would seek to invest through an unincorporated association:
Next week: more compliance tricks that I employed.
Partnerships didn't come by every day, but some new clients apparently folded their investments into existing entities, or relied upon somebody's legal or tax advice.
- First, The articles of partnership, with any amendments, must be reviewed, so as to identify all interested partners, all of whom must be vetted through World-Check, and with a thorough search in the jurisdictions where they reside and work. One can easily hide inside a partnership document, most of which are neither recorded in public records, nor filed with government agencies. It is up to the compliance officer to check all the partners, lest there be anyone who is unacceptable on the list.
- Some financial service providers attempt to send redacted documents, or summaries, or extracts, of the partnership documents. This is an obvious red flag; without complete documents, no processing should occur. Always reject the oft-given privacy argument, for the entire document will most likely contain something they do not want you to see.
- Second, with Limited Partnerships, you will find at times that the General Partner is cleverly listed as yet another partnership. This is a primitive attempt at concealment, though you will be assured by someone representing the client that it is merely for tax purposes. Again, demand that second partnership document.
- Third, I used to run the names of the minor partners through the Secretary of State corporations division database in the state where they resided, looking for associations or links to organised crime companies or figures, or known fraudsters. Remember, not every criminal or fraudster has an arrest record, but they do leave debris in the legal system. I didn't think this was excessive, and I managed to catch a number of individuals associated with criminal organisations that way.
Regarding limited Liability Companies, commonly known as LLCs:
- Whilst similar to corporations, having members instead of shareholders, note well that there may be a non-member manager running the company under an operating agreement. Always vett the manager and all members, irrespective of their percentage of ownership.
Sometimes, the clients would seek to invest through an unincorporated association:
- This can be a problem, unless there is a verified membership list to work with.
- Does the association have some definite, benevolent, fraternal or social purpose to justify its existence?
- They generally have some sort of organisational charter, which you must review to ascertain whether group approval is required to make an investment, or open an account.
Next week: more compliance tricks that I employed.
The facts and opinions stated in this article are those of the author and not those of World-Check. World-Check does not warrant the accuracy of any facts and opinions stated in this article, does not endorse them, and accepts no responsibility for them.
Read more in this exciting series
8 March 2010
8 February 2010
24 January 2010
6 December 2009
27 September 2009
9 August 2009
3 August 2009
30 March 2009
9 March 2009
2 March 2009
22 February 2009
18 February 2009
26 January 2009
18 January 2009
11 January 2009
5 January 2009
29 November 2008
24 November 2008
17 November 2008
8 November 2008
3 November 2008
27 October 2008
20 October 2008
13 October 2008
4 October 2008
28 September 2008
20 September 2008
15 September 2008
15 June 2008
8 June 2008
1 June 2008
26 May 2008
19 May 2008
12 May 2008
4 May 2008
27 April 2008
20 April 2008
13 April 2008
31 March 2008
18 March 2008
4 March 2008
25 February 2008
16 February 2008
10 February 2008
3 February 2008
27 January 2008
20 January 2008
14 January 2008
6 January 2008
16 December 2007
9 December 2007
1 December 2007
25 November 2007
18 November 2007
11 November 2007
3 November 2007
27 October 2007
21 October 2007
14 October 2007
7 October 2007
1 October 2007
23 September 2007
16 September 2007
3 June 2007
27 May 2007
21 May 2007
6 May 2007
30 April 2007
22 April 2007
15 April 2007
8 April 2007
2 April 2007
24 March 2007
19 March 2007
12 March 2007
5 March 2007
25 February 2007
19 February 2007
12 February 2007
4 February 2007
28 January 2007
22 January 2007
15 January 2007
7 January 2007
2 January 2007
16 December 2006
10 December 2006
3 December 2006
27 November 2006
19 November 2006
11 November 2006
5 November 2006
29 October 2006
22 October 2006
16 October 2006
9 October 2006
2 October 2006
Print Confession
Email Confession
More Confessions
Subscribe to Newsletter
PRODUCT INFORMATION
COMPLIANCE OVERVIEW
NEWSWIRE
World-Check releases White Paper on Piracy
World-Check releases 'Piracy in the Horn of Africa' a White Paper by Rear Admiral Chris Parry CBE. With antecedents that reach back to classical times, piracy has sprung up and thrived in vari...more
World-Check releases White Paper on the Forei...
Titled “The FCPA and why it matters” this paper provides insight for multinational organisations into the US Foreign Corrupt Practices Act (FCPA) and highlights the basis for a sound compl...more
World-Check expert seminars attract 600 deleg...
Since July 2009 World-Check, the leading provider of end-to-end risk management services, has presented expert seminars in Monaco, Frankfurt, Madrid, Lisbon, Stockholm, Helsinki, Oslo, Copenhagen, M...more
World-Check renews partnership with the UK's ...
Since November 2008, the World-Check database has been used in over 130 enquiries by the CEOP's financial investigators to ascertian background intelligence on child abuse cases. To read the full ...more
Jersey convicted narcotics trafficker profile...
Read the full press release to see why it makes sense to use the World-Check se...more
Make this my homepage
Bookmark
