MONEY LAUNDERER by Kenneth Rijock
One of the most vexing problems that I encountered as a compliance officer is that of the arrogant and difficult client. We have all heard the horror stories; the billionaire client that new accounts cannot find, due to his constant globe-traveling nature; the distant customer who refers all queries for information to his even-more-distant law firm, which is located on the other side of the world; the looming client-set deadline for approval of the account, after which the wealthy client has threatened to go to our closest competitor; the affluent, but absent, individual whose new business would be a quantum leap in additional revenue for the bank, but nobody has met him yet. Whilst we do not focus on human relations issues in this series, it is important for compliance staff to recognise that some negative personality traits may just be clever ploys intended to deny critical information to the bank. One must exhibit patience with difficult clients, all the time never losing focus on the objective; vetting the client, irrespective of the hurdles placed in front of you. Is it really a difficult, demanding new client who brushes off your demands for additional personal information, or a criminal advised by a manipulative money launderer/fraudster? Perhaps a list of common techniques employed by the latter may open your eyes to their presence.
- With the prospective client who sets impossibly short deadlines (like today) for his compliance department approval, make very sure that your (written) policies & procedures internal AML guide specifies that client identification processes are not complete until reviewed and signed off by the Director of Compliance. Show the client this page (only), should he or she demand expedited service. This gives you a cushion during which you can complete the enhanced due diligence that kicked in the moment the client demanded immediate approval.
- For the affluent client who declines to provide documents of any sort (like the entire Trust Agreement, not just the "relevant pages"), due to professed privacy reasons, advise that all named individuals must be screened for OFAC-designated status, and for that reason the entire document is absolutely necessary.
- The client who delegates it all to his law firm, which never answers your enquiries, advise the client that he or she must now designate a new legal representative, as his named counsel has failed to communicate with you, copying the name partners of the law firm. The partners, fearing a malpractice suit, will reply forthwith, and may chastise the assigned attorney.
- When the client, professing the press of business, fails to show up for a mandatory face-to-face meeting, send someone to his business, unannounced, to meet him, on his turf. This may expose any owners of front companies seeking account relationships, and it will certainly result in a candid snapshot of the client and his business.
In short,do not accept affluence as an excuse to fail to produce needed minimum documents, and do not be intimidated by wealth or arrogance. Discharge your duties properly, even when the new accounts staff says
he's rich but demanding.
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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