MONEY LAUNDERER by Kenneth Rijock
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.
- 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.
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