Issues For Custodians Proper funds, trustees, and escrow companies all use the services of a custodian. A custodian is an independent entity that holds on to an asset, or the title to an asset, on behalf of the … Read More

Due Diligence – Insider Trading For me, the gimlet eyed investigator, it is getting to the point that one cannot trade on any information that is either not already public, or that comes from an ephemeral fiscal … Read More

Crowd Funding The rise of private equity investing and how it’s been facilitated by the growing number of crowd funding platform websites present a series of complications. The complications present themselves … Read More

Due Diligence in China For many years FE&E, Inc had an office in China.  We got to see the rise of the entrepreneurial China. We also got to see the future currents and I am sorry to say – we have been more … Read More

Mind Your Monkeys We escorted a group of Russian business men on a meeting / vacation trip to Bali. We had our local people scout the hotel and the resorts areas. Runs were made to and from the airport as well as … Read More

Uber The recent slap down of Uber in Germany was prompted by the taxi monopoly.  The monopoly granted to the taxi drivers by the regulators is threatened by this application of ride sharing.  The Uber application … Read More

Banks Have No Money for Small Businesses It is simple, with a recently announced 100 billion liquidity short fall for US and thus banks are not going to be lending to small businesses.  This is on top of the … Read More

Exempt Entities There are a number of exempt entities from the BSA and AML requirements. Chief amongst these are government and quasi-government accounts. This is a surprise to many, but not to the criminals.  … Read More

Bunch-O-Water Balloons All I have to say after many, many hours spent filling water balloons – used of course to ambush our children, friends, neighbors – and any others that happened to be in range, and may be … Read More

Due Diligence: Our Client Has Been Sanctioned It happened. As silly as it may seem it really did happen. One of our cherished client trust companies was working for a client that got sanctioned. That is when we got … Read More

BNP Paribas, The Success of Due Diligence And The Failure Of Management I have just returned from a trip through Europe, the Middle East and Asia. As I traveled, the saga and ultimate fine with BNP Paribas … Read More

LinkedIn Premium as a Data Tool LinkedIn is an undisputed success. It is a great tool for reaching out to professionals. I would even say that if you are not on LinkedIn and participating in some of your … Read More

Traveling In the United States When setting up to travel within the United States I look at all of the cities and states we will be visiting and call up and speak to the different departments. They have been … Read More

A Fiber Optic Cable Was Cut It was a short trip through Northern California. During the three days my cell phone did not work and twice in two different cities the restaurant took our credit card and used a pencil … Read More

BART and San Francisco Bay Area Ferries BART is a very good transit system with very outdated payment technology.  The machines that accept cards can only sell up to 5 transit cards.  To buy a card you have to … Read More

Russian Sanctions, A Panel Discussion Link to posted discussion http://www.blogtalkradio.com/bekkercompliancechat/2014/07/30/useu-sanctions-v-russia-global-impact-on-the-financial-services-industry This is a link … Read More

AirBNB.com Airbnb.com is a service dedicated to finding alternative dwelling rentals for the traveler and adventurer who does not what to spend money on a hotel or is looking for a different, more authentic … Read More

Due Diligence: Red Flags On Investment Schemes Everyone has their own biases when investing and I am certainly not immune. One bias that has nothing to do with any factual support is anyone wearing Qiana shirts. … Read More

Locating Yachts So, you are looking for a Yacht? For the uninitiated it can be a very difficult process, but much can be done to hunt down a Yacht, knowing its history and its possible whereabouts. Hull Number … Read More

The iPhone Hacks The iCloud Any read of Aegis has seen our comments about security and the cloud – THERE IS NO SECURITY IN THE CLOUD. Yet again, we are confounded by another attack on cloud computing. Via the … Read More

My Oligarch Has Been Sanctioned It happened despite as silly as it may seem it really did happen. One of our cherished and best of our Graymen was working for a client that was sanctioned. When one runs an … Read More

Cell Phone Vulnerabilities What Cell Phone OS is most vulnerable -­‐ From Phys.org (edited) Good news! Android OS has around 80% of the total market share. This is in part due to price and the range of devices … Read More

6 Countries, 4 presentations, 28 days New York, NY – 2 days of AML training. It was a good class, but some still do not seem to understand how a broker dealer – that accepts no cash can be used for money … Read More

Iraqi Dinar I have watched this rube of an investment idea for years. The heart of the rube assumptions is that the Iraqi dinar will be revalued upward. At 1,168 to the US dollar – it more or less makes sense to … Read More

Air Travel Is it better than a long caravan or sea voyage? – yes. Are some flights better than others? – oh, heck yes. Are some seating configurations better than others? – uh huh. The good thing about … Read More

Due Diligence – The High Net Worth Individual’s Circus High Net Worth Individuals (HNWIs) do not play by the rules, or at least the rules the rest of us have to play by. It is both part of their success and part … Read More

Wisdom of Crowds For us old folks – yeah, those of us over 50.  We knew how to do our due diligence.  We just asked everyone in our community about the realtors, the butcher, the lawyer, the stock broker and we … Read More

Online Business Strategy and Media Buying How would you like to have a guaranteed promotional strategy for your business?  Would you like to know exactly how much every dollar you spend in advertising will … Read More

The Big Event It has been many months since this event and enough time and distance has passed so that by writing about this now no confidence or security will be breached. Several months ago a very famous Latin … Read More

SpyWarn – App The SpyWarn app from Kevin Murray and Associates is $2.99 and is a gem of an app.  Not sure if that virus software you installed on your phone is catching everything?  Well it’s not! Professionals … Read More

Those who do not go away Few of you may actually know what I am talking about, but those who have suffered from these people know the rest of this story without reading it. None of us are Saints. If the truth be … Read More

BNP Paribas BNP Paribas is going to get a mighty big fine.  The street estimates are in the range of 5 to 10 billion dollars.  The bankers are riled up about unfair treatment and are haranguing François Hollande … Read More

American Pastoral, by Phillip Roth Ok, so it won the prestigious Pulitzer Prize.  It really is a work of art and it caused a real dialogue between the reader and the author. The prose crafts pictures in the … Read More

Projections I am inherently distrustful of projections. For too many years as an investment banker I reviewed business plans and their projections. If you asked any of the authors of the projections- no matter what … Read More

Warehouse Receipts What is a warehouse receipt?  It is a title of goods stored by a warehouse.  This title, or warehouse receipt, can be in a bearer form or it can be issued to in entity specific form. From the … Read More

Language Fluency When traveling, it is insufficient to have a team member  just ‘get by’ in speaking the foreign language of the country in which you are travelling; you need to have at least one team member … Read More

El Niño The National Oceanic and Atmospheric Administration’s (NOAA) National Weather Service Climate Prediction Center has issued a forecast that an El Niño Event is likely to occur. El Niño is defined by … Read More

MTN Trading Programs There have been frauds since they first surfaced. But they, like  pesky Nigerian inheritance scams and lotto winnings, just do not seem to go away. An example from Treasury.Gov as an opening … Read More

Poaching, the Animal Trade and Money Laundering The video is an effort to share with our readers a bit more about the illegal trade in poached animals in East Africa and how the money from the poaching is … Read More

The Wolf of Wall Street Our view is a bit different from the side of frauds.  One only has to see the destruction that fraud wrecks upon their victims to find what was done to be utterly reprehensible.  The … Read More

Due Diligence: Digital Currency Linden Dollars, Liberty Dollars, e-Gold, Bitcoins are all Fiat Currencies issued by entities with some form of limiting mechanism so that they just don’t keep issuing bazillions of … Read More

NGO’s and Charities NGO’s and Charities have slowly evolved, under the radar, to become significant channels for laundering money. Charities alone in the US received 320 billion dollars. About 2% to 3% of US … Read More

Carl, the Loud Investment Banker Location: Birmingham, Alabama airport.  Point of reference: Carl is a very loud investment banker taking on his cell phone.  Carl was making a long call and walking up and down … Read More

2 Teams at Once The following story is  from one of our scouts is a quick but interesting tale about how well-thought our plans go afoul despite precise planning and good intentions. Our scout was at a famous … Read More

Widows XP – Soon To Be A Legacy On April 8th 2014 Microsoft will end support for Windows XP.  An event of planned obsolescence, yet many computers still run XP as it really was one of MS’s best operating … Read More

Education I just spent some quality time at a major university law school and at an accelerated high school discussing ethics, corruption and fraud.  The reception I received was stunning.  From graduate … Read More

AML and OFAC Applies to State Governments I had a short conversation, off the record, with several investigators that work for state unemployment agencies. The common complaint was the inertia with regards to … Read More

Victorinox Luggage Rarely do we pen a complaint on an item a book or a service, but here is a case worth bringing up. The Victorinox Spectra 26, Hardside Spinner, in Blue. Price was about $210.00. The bag, which … Read More

Due Diligence – Flight Capital Part of due diligence is anticipatory in nature, what risks do you see in your organization, industry, or market space that you can either – assume, transfer, hedge or accept. But … Read More

Web Domains as Property The subject of ownership with regards to web domains remains a controversial topic. In this article, we take a look at two  cases. In Virginia in Umbro Int’l V Can., Inc. The Supreme … Read More

TiO2 and China The story of Pangang Group, of China, a State Owned Enterprise in China, Walter Liew and Robert Maegerle of California ended in March with the two individuals being convicted of espionage.  It also … Read More

Winter sports with your VIP Believe it or not, a Russian Oligarch arrived in Switzerland (Klosters) with 10 bodyguards and not one of them could ski.  The trip was planned for weeks, the executive protection team … Read More

Losing Control of Your Car A while ago we wrote about how a BMW could be hacked, but access to a vehicles computer systems is getting more – how do we say? – available. For $25 one can build the “CAN Hacking … Read More

Stupid Broker – Weapons Grade On a long plane ride from New York to Dallas, a gentleman sat next to me and began a conversation.  He eventually disclosed that he was a 30-year financial broker with a major firm.  … Read More

Simple Lesson on Bribery So, we campaign loudly against bribery.  Yet some say – ah yes, but when does a gift between friends become a bride?  The answer is when the bribe motivates the choice maker to subvert … Read More

CBonds.info We were recently tasked to track down some very unusual bonds from some developing nations including a few with in the CIS States.  In doing so we ran across a service called CBonds. From their web … Read More

Due Diligence: Cash and Remediation There is a saying on a poster in our office “Come the revolution things will be different, no better just different;” no doubt one of the more optimistic sayings from Murphy … Read More

Authority to Bind It is too often a question that is not asked or answered.  How does one have the authority to bind a company, a partnership, a country or even a group of victims? A few recent events come to … Read More

Who Was That Man? This is short simple and the point.  Do you have any idea who you are doing business with?  Do you have any idea of their background or credentials These are a couple of quick stories from very … Read More

Wrong Place Wrong Time It happens to all of us at one time or another, we find ourselves at the wrong place and the wrong time.  We plan, we send out advance teams and we work our diligent best to insure that our … Read More

Turn It Off I had lunch with a Technical Security Countermeasures expert and he told me a short story.   On a recent flight delay in the US north east – running a number of hours 30 or 40 he got bored.  He had … Read More

The Business of Marijuana Some fascinating people have introduced me to the Marijuana business.  A grower, a financier, a security specialist…  I am intrigued. As for the product, I am not a user.  But I am … Read More

Continuous Risk Management for Financial Institutions CRM (Continuous Risk Management) is a discipline that runs through a step-by-step cycle of ‘Identify, Analyze, Plan, Track, Control’ – back to Identify … Read More

Boeing 787 Dreamliner Your editor had a chance to fly on one of Qatar Airlines 787 from London to Doha just a while ago.  As always I requested a window seat not above the wings; to see what is going on.  I am … Read More

The Art Market – It’s a Rigged Bet Oh did I get in trouble. I received all sorts of calls and emails after a short quote in the Wall Street Journal. “Art funds always lose money…investors always lose in an … Read More

Due Diligence – Social Media There was an article I saw recently about how over 30 per cent or more of college admissions departments are now looking at posts on social media websites such as Facebook, Pinterest, … Read More

Market Tells A “tell” is a sign or a signal, intentional or not of an outcome.  In gambling players watch each other for tells; signs of the strength or weakness of a hand.  For example, my old roommate was … Read More

Venture Capital I, one of your editors, often invest my time and work with small ventures.  Start up companies with no revenue or just starting to make revenue in exchange for some deeply discounted stock or stock … Read More

Palermo I had to unstick a bad deployment from a group of Executive Protection Specialists. A group of Canadians deployed to Palermo to protect their charge that was recently on a fall vacation in the ancient … Read More

Stock and Bond Certificates The law has acknowledged bits of tablecloth and the back of napkins as both suitable for contracts as well as proof of ownership in an enterprise.  However, these forms of construction … Read More

Cash and Revolutions There is a saying on the poster in our office “Come the revolution things will be different, no better just different.”  No doubt one of the more optimistic sayings from Murphy and his … Read More

Memberships A new form of money laundering is upon us.  A small drug operation was busted where all of the payments for the drugs were via credit card and PayPal. The operation was small scale – but very slick. … Read More

Crystal Deodorant We had an interesting research project on deodorants and in specific the relatively new crystal deodorants that originated in Thailand. We learned that our western cleanliness lends to the need of … Read More

I worked in China a number of years ago and while it was corrupt then – it has, in my opinion, become markedly worse. I was asked: can one actually do business in China of any size and not run into trouble amidst … Read More

PEPs PEPs, or Publicly Exposed Persons, require enhanced due diligence, NOT because they are more likely to be money launders as many overwrought risk managers and silly compliance people seem to think.  … Read More

The NSA Flap… Do I believe the NSA listens to just about all electronic communication it can get its jumpers on? – Sure, I do.  Am I upset? – Not really as it was to be expected, having read all of V. James … Read More

Dirty Books The article below prompted me to ask a few questions of my more medially trained staff and members.  First – the “gross factor” is over the top – however it did make me rethink a few things… … Read More

FLIR, Infrared Cameras Check out this great website (link below), offering a variety of FLIR , Infrared cameras: … Read More

Play to a Draw How many times have you been told you have to “Play to Win”?  I have no idea either.  Few people play to lose unless they are forfeiting an engagement to saddle the victor with cost of a … Read More

Policy Manuals Here are a couple of thoughts regarding policy manuals in general All policy manuals are  really just  documents copied from somewhere else.  The copies bring with them all of the biases and … Read More

Mugabe’s War Machine, by Paul Moorcraft and Knox Chitiyo ISBN-13: 978-1848844100 p from $18.00 to $35.00 USD Cited from the Amazon Summary: Mugabe’s dictatorship had survived due to the vicious military … Read More

Due Diligence Fails We have seen many of them; abject total monstrous failures of due diligence that make the headlines. War heroes running newspapers who never served in the armed forces, presidents of companies … Read More

Put down the Checklist and get thinking again… One of your editor’s rants on checklists is people who simply work through the list and stop thinking about the particulars of the situation at hand.   In the … Read More

Don’t Ever Write This Down! Don’t write down plans, don’t use the same password for every account,  don’t share your personal information with people who may hack into your accounts, and don’t carry your … Read More

Executive Protection within the Domestic Estate Some tips on setting up security in the home. It is well-advised to be safe when traveling  or dining out, but we often let our guard down when we are at home, … Read More

Vietnamese Root Kit This Vietnamese Root Kit, which is also known as the M-Root Kit Mobile Hacking Tool, was developed in  Vietnam.  It is a nasty bit of work as it allows even  marginally sophisticated hackers … Read More

Investigations in Myanmar We have had investigations in far more difficult circumstances but certainly not in a more challenging country. The first challenge we encountered was the language. Years of isolation kept … Read More

The Trap Of Perverse Incentives An audit was performed on a regional bank in Asia who was doing a great job on big issues.  Compliance was a priority – blocking certain wires and closing a few accounts here and … Read More

Jean-Marie Gustave Le Clézio – Author Our author of choice is Le Clézio, who in our opinion is a very accomplished author. We have read; Desert, Fever, Mondo and Other Short Stories and look forward to reading … Read More

De- Centralised Due Diligence Most nations’ financial regulations copy those drafted in the US and the EU. These regulations have been promulgated by the Bank for International Settlements (bis.org) through a … Read More

NYSE Listing Exposes Foreign Firms to Liability For Corrupt Practices From a recent filing in US Courts: Broux v. PetroChina Co. Ltd., 13-cv-06180, U.S. District Court, Southern District of New York.   PetroChina … Read More

How Rampant Bribery Is Corrupting U.S. Immigration Integrity? We recently came across an article, entitled HOW RAMPANT BRIBERY IS CORRUPTING U.S. IMMIGRATION INTEGRITY. This article described two recent cases of … Read More

Corruption vs. Our Tasks When I was asked to look at corruption and Executive Protectors (EPs), I was thinking about the EP being corrupt and selling information (and, yes, this does happen).  But what hit me was … Read More

Money For Corruption and Homes Scott Free Money from corrupt players in Latin America, China and the Middle East are flooding into the US real estate market. Now to be sure, while a lot of the purchases of real … Read More

Coin Dealer Hung Out On A Shingle For Home Loan Fraud? Recently one of our consultants was asked to opine on the subject of Customer Due Diligence concerning a financial transaction that was, well, ultimately … Read More

Corporate Excuses to Avoid Compliance and Ethics Programs by Michael Volkov Change is difficult. I understand that. Business leaders know the importance of change, adaptation and innovation. However, when it comes … Read More

Double Paradox: Rapid Growth and Rising Corruption in China Double Paradox: Rapid Growth and Rising Corruption in China by Andrew Wedeman  ISBN 978-0801477768 about 20 dollars. Dr. Wedeman has done a fine job with … Read More

Due Diligence – Examples in Ibiza So what does a financial investigator do when on a short holiday in Ibiza? Well, he gets bored on the beach after about an hour. He also gets annoyed, as every three to four … Read More

Due Diligence by Design As for managers running a business – we at ÆGIS understand the challenges and difficulties involved…   In addition to the myriad of “normal” business challenges to building, … Read More

OPSEC and New Product Development by Daniel W. Phillips, OCP, PSP A key and sometimes-overlooked factor in the successful development and launch of a new product or technology is protecting it from prying eyes in … Read More