CONFESSIONS OF A
MONEY LAUNDERER by Kenneth Rijock
Financial Crime Consultant, for World-Check
Confession of a Money Launderer - Part 80
24 November 2008

Whilst a compliance officer, I witnessed a wide variety of cute tricks, intentional disinformation, and even bold untruths contained in the applications from the prospective clients. The problem was, you never know how much of the client information was subsequently altered or doctored by the sales staff, either remotely, or in-house, so that they will pass muster with compliance. Your compliance training allows you to recognise information that is clearly inconsistent with the client's total picture, but the real challenge is to spot personal information that seems odd to your trained eye, and, using your analytical abilities, prove or disprove its truth and accuracy. That is where compliance advances beyond a learned skillset, and approaches a professional calling. Your ability to tie together a couple of seemingly authentic and ordinary answers to the clients' application and, after dissecting them, to either approve or decline the customer, is nothing less than an art, in my humble opinion. It must be learned over a period of time on the job, and cannot be taught. In law school, we are taught what is called issue perception, the ability to glean and extract the primary issues from a lengthy appellate decision. In compliance, there simply is no way to impart this focused analytical ability. You acquire it after reviewing many, many files; learning from your mistakes, and becoming sensitised to the nuances of new account personal information.

We shall analyse at some typical new account compliance issues, and the mindset and techniques one uses to expose them, when there is a lot of new money at stake, or enhanced due diligence is called for to vett the client:

  • Telephone numbers: The new clients must supply them, generally their work and office numbers. You want hard-line, fixed numbers. Most compliance officers can immediately tie the international country and city code, or area code, to the given address, but you need to also confirm that the number(s) supplied are not mobile (cellular) numbers, which may be easily obtained globally by non-residents. Many countries (including the US) feature websites with databases that allow one to verify that the exchange prefix is indeed a mobile number. Hiding one's true country, province or state of residence, because one lives in a high-risk jurisdiction, is a common ruise. Always confirm that you have fixed numbers for the client, especially since prepaid mobile numbers are generally untraceable, a fact not lost on financial criminals.
  • Correct legal name: using your middle name, or changing a letter, or adding something, might be a way that the client evaded taxes, a nasty divorce settlement, or law enforcement. Unfortunately, the use of drivers' licenses as primary identification provides an opportunity for the resourceful corrupt PEP, financial criminal, or otherwise unacceptable risk to give you a distorted name, or even an alias. Do you ask for the modern form of passport, with the machine-readable strip that can be checked by Passport-Check? And do you troll for the client's name on the search engines, looking for an Internet footprint that is often good evidence that this person really exists? How about another government-issued form of photo identification? Check the public records Internet database to find his economic or real estate footprint under that name also.
  • Occupation: If the client appears to be a prominent businessman or professional, he will show up on his company's website, or with an occupational or professional license, either of which can be verified quickly on the convenient Internet sites available for that purpose. He may also appear in newspaper or magazine articles. Remember to also search in his native language if it is other than your own. I have been known to send e-mails, or even ring up the company Human Resources office, to verify his status. With high net-worth clients, of substantial means, who do not hold ordinary jobs, check the charity and society pages of his local newspaper websites. Wealthy people contribute to good causes, and also attend sociery functions. he or she should be in there. That was how a senior compliance officer I knew made sure the new account was not just a well-dressed narcotrafficker; if real, he would belong to the appropriate private clubs that new money cannot enter.
  • Addresses: Most addresses can be verified through a wide variety of Internet resouces, especially real property/Public Records libraries websites, operated by local, county, state or provincial government agencies. I also have foound that it doesn't hurt to type in the address to the world wide web to see what emerges, as verification can come in unusual ways. I recently typed in my childhood address, out of curiosity, and found that the current resident of that house has obtained a government patent. There are often current or obsolete real estate sales listings, or news articles, which may assist you in your quest.


Next week: more tricks of the trade.



























 


 

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

Confessions of a Money Launderer - Part 96
Confessions of a Money Launderer - Part 95
Confessions of a Money Launderer - Part 94
Confessions of a Money Launderer - Part 93
Confessions of a Money Launderer - Part 92
Confessions of a Money Launderer - Part 91
Confessions of a Money Launderer - Part Ninety
Confessions of a Money Launderer - Part 89
Confessions of a Money Launderer - Part 88
Confessions of a Money Launderer - Part 87
Confessions of a Money Launderer - Part 86
New chapter out Tonight
Confessions of a Money Launderer - Part 85
Confessions of a Money Launderer - Part 84
Confession of a Money Launderer - Part 83
Confessions of a Money Launderer - Part 82
Confessions is on holiday until 5 January, but read earlier chapters here
Confession of a Money Launderer - Part 81
Confession of a Money Launderer - Part 80
Confession of a Money Launderer - Part 79
Confessions of a Money Launderer - Part 78
Confessions of a Money Launderer - Part 77
Confessions of a Money Launderer - Part 76
Confessions of a Money Launderer - Part 75
Confessions of a Money Launderer - Part 74
Confessions of a Money Launderer - Part 73
Confessions of a Money Launderer - Part 72
Confessions of a Money launderer - Part 71
Confessions of a Money Launderer - Part 70
Confessions of a Money Launderer - Part 69
Confessions of a Money Launderer - Part 68
Confessions of a Money Launderer - Part 67
Confessions of a Money Launderer - Part 66
Confessions of a Money Launderer - Part 65
Confessions of a Money Launderer - Part 64
Confessions of a Money Launderer - Part 63
Confessions of a Money Launderer - Part 62
Confessions of a Money Launderer - Part 61
Confessions of a Money Launderer - Part 60
Confessions of a Money Launderer - Part 59
Confessions of a Money Launderer - Part 58
Confessions of a Money Launderer - Part 57
Confessions of a Money Launderer - Part 56
Confessions of a Money Launderer - Part 55
Confessions of a Money Launderer - Part 54
Confessions of a Money Launderer - Part 53
Confessions of a Money Launderer - Part 52
Confessions of a Money Launderer - Part 51
Confessions of a Money Launderer - Part 50
Confessions of a Money Launderer - Part 49
Confessions of a Money Launderer - Part 48
Confessions of a Money Launderer - Part 47
Confessions of a Money Launderer - Part 46
Confessions of a Money Launderer - Part 45
Confessions of a Money Launderer - Part 44
Confessions of a Money Launderer - Part 43
Confessions of a Money Launderer - Part 42
Confessions of a Money Launderer - Part 41
Confessions of a Money Launderer - Part 40
Confessions of a Money Launderer - Part 39
Confessions of a Money Launderer - Part 38
Confessions of a Money Launderer - Part 37
Confessions of a Money launderer - Part 36
Confessions of a Money Launderer - Part 35
Confessions of a Money launderer - Part 34
Confessions of a Money Launderer - Part 33
Confessions of a Money launderer - Part 32
Confessions of a Money launderer - Part 31
Confessions of a Money launderer - Part 30
Confessions of a Money Launderer - Part 29
Confessions of a Money Launderer - Part 28
Confessions of a Money Launderer - Part 27
Confessions of a Money Launderer - Part 26
Confessions of a Money Launderer - Part 25
Confessions of a Money Launderer - Part 24
Confessions of a Money Launderer - Part 23
Confessions of a Money Launderer - part 22
Confessions of a Money Launderer - Part 21
Confessions of a Money Launderer - Part 20
Confessions of a Money Launderer - Part 19
Confessions of a Money Launderer - Part 18
Confessions of a Money Launderer - Part 17
Confessions of a Money Launderer - Part 16
Confessions of a Money Launderer - Part 15
Confessions of a Money Launderer - Part 14
Confessions of a Money Launderer - Part 13
Confessions of a Money Launderer - Part 12
Confessions of a Money Launderer - Part 11
Confessions of a Money Launderer - Part 10
Confessions of a Money Launderer - Part 9
Confessions of a Money Launderer - Part 8
Confessions of a Money Launderer - Part 7
Confessions of a Money Launderer - Part 6
Confessions of a Money Launderer - Part 5
Confessions of a Money Launderer - Part 4
Confessions of a Money Launderer - Part 3
Confessions of a Money Launderer - Part 2
Confessions of a Money Launderer - Part 1
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