We note this week that a hacker group has, once again, reportedly stolen a well-known (and often relied upon) database used by compliance officers to detect unsuitable individuals and companies at account opening, and is demanding a large payment to refrain from releasing it on the Internet. Having spent many years working for two of those companies during much less complicated AML/CFT times, I understand their widespread utility as a major compliance tool. Unfortunately, the advance of technology, and greed and corruption on the part of many amoral government officials in the developing wor ..read more

What you are reading is recent from the SCMP, pushing economic development and urging HK readers to ignore new laws infringing upon human rights. It smacks of 1984  and Big Brother. I think it's time to take ANY news out of Hong Kong with a healthy dose of caution, especially financial news. Remember, reporting from within HK, on Chinese companies, could get you a long term in a Mainland Chinese PRC prison; I kid you not. Look at the latest two national security laws now in place. And they are definitely not "home-grown" national security laws. These are straight from Beijing's aut ..read more

MSR MEDIA, a major American motion picture production company that was approved by St. Kitts & Nevis' Alternative Investment Program under the country's Citizenship by Investment (CBI) scheme, has published a Legal Notice of its intent to initiate civil litigation in the US, against several present and former Caribbean government officials, and others, for "potential violations of United States laws, including fraud, money laundering, tax evasion and corruption." Speaking through its Producer, PHILIPPE MARTINEZ, the St. Kitts-based company has alleged that a massive program of organized ..read more

Immediate Release April 15, 2024 WASHINGTON—Today, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN), in close coordination with the Department of State’s Diplomatic Security Service (DSS), issued a Notice to financial institutions on fraud schemes related to the use of counterfeit U.S. passport cards. The Notice provides an overview of typologies associated with U.S. passport card fraud, highlights select red flags to assist financial institutions in identifying and reporting suspicious activity, and reminds financial institutions of their ..read more

I was trying to learn who the beneficial owners of several shell corporations formed by Mossack & Fonseca were, many years ago, when I stumbled upon this clever method of operation. They formed front companies in a number of the English-speaking tax havens in the East Caribbean, rather than their native Panama, where they might be uncovered by an enhanced due diligence sleuth. They intentionally deleted the names of the specific jurisdictions from external correspondence with banks, leaving that information to be the subject of guesswork on my past. M & F staff were quite good at the ..read more

Longtime readers of my financial crime articles may recall that I named and shamed many of the M & F partners and staff attorneys, who left the firm when the scandal broke, to work elsewhere in Panama City, intentionally omitting their previous employment at the target of the "Panama Papers." We did so to insure that any potential future clients, and those American lawyers needing to retain local counsel there, had all the facts before associating with lawyers who might later be arrested. Now, as you can see, arrests did come to pass. We note that there is a presumption of innocence wit ..read more

This statement, made by a Federal prosecutor at an ongoing money laundering and conspiracy trial of a former senior Ecuadorian government official accused of taking ten million in bribes and kickbacks, in the first American Odebrecht case, says it all about the systemic problems South Florida faces from laundrymen who clean dirty money through the area's banks and real estate agencies. Other American cities have similar problems, although not to the extent that we see it here. Part of the problem, the facilitation of money laundering through real estate investments, it is hoped will be m ..read more

One of the biggest problems that money launderers face, regarding their criminal clients, is failure to follow their instructions. Wealthy criminal clients often become extremely arrogant, due to their newfound assets, and often question their laundryman's decisions, even if they have little or no background in finance or the dark realities of working in opaque tax havens, where the players often choose to take advantage of criminals, because they cannot go to the authorities. In my personal case, one group of drug smuggling clients having made many millions in illicit profits, ignored my ..read more

If you are attending the event, I hope to see you there. I will be covering the advanced money laundering techniques that community bankers can expect to face in 2024 ..read more

We are in the middle of a TBML crisis; the perfect storm of choke point transportation issues with the Suez/Red Sea/Gulf of Aden, Panama Canal, Black Sea and Baltimore bridge accident have rendered the generally reliable red flags through which compliance officers working in transaction monitoring identify TBML in progress useless. So long as the global situation remains in constant transition, legacy compliance procedures are ineffective. So, what to do? It is humbly suggested that compliance officers broaden their knowledge base in the shipping, insurance and transportation sectors, so that ..read more