MONEY LAUNDERER by Kenneth Rijock
When I worked as a compliance officer, my short list of "red flags" consisted of the techniques that I personally used, or had observed other money launderers employing with a high degree of success. It was, at first, quite strange to see those tricks and clever gambits from the other side of the playing field, so to speak. I know that the financial criminals that I identified, and prevented from attaining client status probably never realised that a person who was formerly one of their own was reviewing their techniques, simply because I never considered it when I was working in that illicit industry. Whilst I never underestimated the abilities of compliance officers as a practising money launderer, I never conceived of the concept of a former laundryman working on the side of the banks. if I had known such a thing existed, I would have been forced to make major modifications in my strategies and tactics, abandoning the more simplistic tricks in favour of new methods. Not just old wine in new bottles, but totally new tradecraft.
- Intentional misspelling of the corporate name. When you see this more than once in company filing documents, it is not secretarial error, but a nice way to play the laundering game. Many times, an inattentive bank staff officer will assume it is a typo; Not so, it often allows one to form a corporation with a deceptively similar name to that of an established legitimate company of substance. Some officers will automatically correct the perceived mistake. Remember, the more confusion, the harder it is for the targeted bank to learn the truth. I saw highly educated businessmen deliberately misplacing a letter or two. The beauty of this technique is that you might even be able to engage in corporate identity theft under the right circumstances, and obtain credit, never to repay the debt. The misspelling ploy is even sometimes intended to give the compliance officer the impression that the company is composed of bumbling idiots that make mistakes. Will you not think that apparently inept businessmen are harmless?
- The use of a Power of Attorney (known as a Poder, in Spanish) from a corporation, given to an agent or attorney. The attorney-in-fact then executes all the documents, and you never really learn whether the stated shareholders are fronts, or even really exist. The problem is theat the person holding the document has total power, whilst not in the position and responsibility of director or shareholder status. In truth and in fact, a company could be quietly set up, and prominent citizens named as shareholders, without their knowledge and permission. The entire thing could be a well-built sham, created to leave no trails after the crimes are committed, with no consent or ownership status of the prominent directors/shareholders.
- The appearance of what appears to be a wholly-owned subsidiary of a substantial foreign company as a new client. The customer relationship officers, seing huge commissions, raises, or bonuses, often fail to check out whether there actually is joint ownership. You do not confuse the public if you are legitimate, but if you are dodgy, you pick a company that does not do business in a certain jurisdiction, and dive right in with your scam about the firm expanding into a heretofore virgin region. Query: Does the legitimate firms's website not mention the new "subsidiary?" If so, you may be looking at fraudsters, not mere money launderers.
- One of the shareholders of a company is itself a corporation, and those corporate documents have not been produced, due to some excuse or another. You will encounter a delaying technique when you insist on the second company 's details, and you are often told that they will be delivered right after the account has been opened. Nothing could be further from the truth. If you do not get verifiable, and complete, company documents from the corporation that owns the first company, pass on the account.
- Spelling differences with the names of the shareholders/officers/directors, from one document to another, Remember, financial criminals like to alter one letter of their name from time to time, to frustrate law enforcement computerised searches.
Next week: more tips, tricks and games they play.
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