178 Billion in Fines

178 Billion in Fines 2014 has set a record for fines. According to an article in the Bank Rate 2014 has been the most expensive year on records for fines levied against banks and financial instructions around the … Read More

AML and OFAC Applies to State Governments

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

Simple Lesson on Bribery

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

PEPs

PEPs PEPs, or Publically 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

Policy Manuals

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

AML and The Securities Industry

AML and The Securities Industry The securities industry is in for a very rude and expensive awaking. The securities markets, commodities markets, and hedge funds are being used to launder money. No, they are not … Read More

A Question Of Due Diligence

A Question Of Due Diligence The crime of money laundering continues to be a growing area of concern in the United States. Law enforcement agencies and the financial sector devote considerable time and resources to … Read More

Practice at Laundering Money

This was fun - oh my gosh this was fun! Every so often we challenge each other in the office to see how good our skills can be in the dark arts. This month challenge was to launder money. Since there was no … Read More

The Confusion of CTR Exemptions

Many institutions that handle large sums of money cause a good deal of problems for those who are required to file CTR - Currency Transaction Report. The idea is that these institutions handle so many large … Read More

Negotiation and Access to Information

The general consensus is that people do not like conflict and thus conflict resolution is “hard” because of this distaste. The “This is my financial answer on offers” is the beginning to the process of … Read More

Myanmar

In the April edition of the Aegis Journal we discussed a client who we felt was more or less “uncoachable”. But yet, in his defense, we can see many more things going on than meet the eye. The origins of … Read More

FATF 2012 AML Recommendations

On 16 February 2012, the Financial Action Task Force (FATF), the global standard setting body for anti-money laundering and combating the financing of terrorism (AML/CFT) , published the following public documents, … Read More

How to Write a Policy Manual

In the last several seminars we have conducted, as well as clients we have visited, a consistent constant question has arisen, How to write an effective policy manual? Well the first thing is to be honest with … Read More