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CONFESSIONS OF A
MONEY LAUNDERER by Kenneth Rijock
MONEY LAUNDERER by Kenneth Rijock
Financial Crime Consultant, for World-Check
Confession of a Money Launderer - Part 81
29 November 2008
As a compliance officer, I maintained a friendly, yet decidedly adversarial relationship with the new accounts staff. After a while, you learn who you can usually trust to give you accurate information that was not adulterated or created by sales as a means of securing compliance approval. You also know who those individuals are that are totally untrustworthy, and who will audaciously pervert the compliance process with manufactured personal data, which they believe will pass compliance scrutiny. The real problem people, in my humble opinion, are the staff who only from time to time. try to slip in a bad one, cobbled up to look acceptable. You just do not know, from one day to the next, exactly what they have sent over to compliance for vetting. Is this new client's information unchanged from what was originally submitted, or did they just make him look good? That's the human factor complicating what is already an occupational challenge; culling out the unacceptable risks amongst the new customers' files.
We return to some the critical subjects often subject to manipulation by new accounts or sales staff, often with tacit consent of a referring individual who brought in the business, and/or the client himself:
Next week: more tips.
- Banking references: Whilst letters of introduction from the client's bankers can be reliable indications that the client is a legitimate businessman, or is a member of a family with substantial inherited wealth, such letters of reference can also: (1) be altered or forged, using a personal computer and any number of applications easily acquired, (2) be a total fabrication, created by one who knows the names of officers at major banks, and ascertains who is absent or on vacation, by clever telephone calls, or personal visits to the bank, with his power of observation and casual enquiries, (3) be legitimate, but executed by an officer or director of a virtual (e.g. no brick-and-mortar physical facility) bank who has a mobile telephone, and a female to screen the calls and act like a switchboard operator, or (4) obtained from a corrupt bank officer in the payroll of the client or his money launderer. It is humbly suggested that all banking references be doubly confirmed, through telephone calls, where you obtain the telephone number, and initiate the call, and politely demand a follow-up e-mail verification, or even hard-copy letter faxed from a known bank number.
- Validity of listed occupation: Is the job title on his business card one that ordinarily connotes a level of supervision, with responsibility over subordinates, or some other level of specialised knowledge. In other words, Is it merely a titular title, signifying no active role? Organised crime figures frequently get themselves listed in corporate roles, but they do not even know where their office is as the site. Frequently, a company website might provide adequate assurances that the prospective client is really working there. Is he listed in the chain of command, and has he a listed telephone number? When you call, do they always say that he is "away" from the office, or "travelling"? Does he generally call you back later? These are red flags that may indicate a bogus job.
- Information on spouse where he or she is also to be a client or investor: Incomplete personal information on spouses does not necessarily mean that the wife (or husband) did not know how to fill out the application, or was absent, with the party present doing his best to complete the forms. Always World-Check the spouses too, for you may find out more often than you think that the spouse is a a problem, and that's why the other family member is opening the account, or placing the investment. Often, the photo identification for the spouse is either missing, or expired. Sometimes they say that the spouse does not have a driver's license, or any government-issued photo ID. Remember, most financial institutions require this to cash cheques, so under no circumstances are you to waive this requirement. If the client is extremely elderly, you ask for an expired driver's license or passport. Also, get confirmation that this is the spouse, and not the son or daughter. Where the spouse is high-risk or unacceptable, due to criminal history, clients have been known to attempt to slip in their grown absentee children. Are the ages of the two parties such that you might expect them to be husband and wife? Finally, is the spouse incarcerated, and is that why they are absent? For the answer in US Federal criminal cases, search the name in: http://www.bop.gov. and go to "inmate locator." This will also tell you about convicted felons now released into the community, and when they got out of prison.
Next week: more tips.
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
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