Archives

UK Beneficial Ownership We have been sharing with our readers for 5 years that a time will come when beneficial ownership – back to human beings, will be required. The UK has taken the first step [...]

GONGO – Government Owned NGOs. Money laundering is shifting from little nits deposited into accounts to larger and larger sums moving under the colors of governments. The biggest offenders have [...]

DOJ Warning of FCPA Legacy Liability The Department of Justice – Opinion Procedure Release 14-02 (the “Opinion”)[1] The Opinion stands for the proposition that the DOJ will not penalize a [...]

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 [...]

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 [...]

Russian Sanctions, A Panel Discussion Link to posted discussion [...]

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 [...]

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 [...]

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 [...]

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 [...]