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Did Your New Refrigerator Help Fund Terrorism? Trade-Based Money Laundering Exploits Demand for Consumer Goods
Of the three primary methods that transnational criminal and terrorist organizations utilize to launder the proceeds of illicit activity and finance terrorism, trade-based money laundering is arguably the most challenging. Most people associate money laundering with the misuse of financial institutions or the bulk movement of hard currency using smuggling techniques, but trade-based money launderingContinue reading “Did Your New Refrigerator Help Fund Terrorism? Trade-Based Money Laundering Exploits Demand for Consumer Goods”
The Interrelationship Between Major Investigations and Crisis Communications
In 2020 and continuing into 2021, the term crisis communications seems almost redundant. We are bombarded every day with information about the pandemic death toll and infection rates, the largest cyber-attack in history, the financial crisis, efforts to overturn a presidential election and an attack on the US Capitol building while Congress was in session.Continue reading “The Interrelationship Between Major Investigations and Crisis Communications”
Derisking and Outdated CTR Thresholds: AMLA 2020 Seeks to Address Persistent AML Challenges
The Anti-Money Laundering Act of 2020 is the most comprehensive set of reforms to U.S. anti-money laundering laws since the passage of the USA PATRIOT Act in 2001. The Act contains some important changes and enhancements that should have an immediate and long-lasting impact on anti-money laundering. Gibson Dunn litigation partner and anti-money laundering expertContinue reading “Derisking and Outdated CTR Thresholds: AMLA 2020 Seeks to Address Persistent AML Challenges”
Thwarting Mobsters, Drug Lords and Terrorists – Anti-Money Laundering Continues to Adapt
The Anti Money Laundering Act of 2020 (AMLA 2020) is the most comprehensive set of reforms to US anti-money laundering laws since the passage of the USA PATRIOT Act in 2001. The Act has some important changes and enhancements that should have an immediate and long-lasting impact on anti-money laundering. I recently spoke to anti-moneyContinue reading “Thwarting Mobsters, Drug Lords and Terrorists – Anti-Money Laundering Continues to Adapt”
The Strange Bedfellows of Cyber Defense
Cybersecurity risks seem to be expanding exponentially. Business Email Compromise schemes are among the fastest-growing financial crimes. Ransomware attacks are crippling hospital systems, disrupting manufacturing and retail operations and supply chains and threatening our critical infrastructure. Personal identifying information is being harvested millions of records at a time from credit bureaus, government agencies, financial servicesContinue reading “The Strange Bedfellows of Cyber Defense”
The Case of the Missing Private Banker: When Bank Fraud Takes a Dark Turn
In 1998, I was only two years into my post-FBI career when I was part of a team dispatched to BankBoston’s private banking office headquartered in New York. It was not immediately apparent that a crime had been committed. An audit had revealed some irregularities in connection with some private banking accounts. We were sittingContinue reading “The Case of the Missing Private Banker: When Bank Fraud Takes a Dark Turn”
Cross Border Investigations and Ethical Culture
In organizations with a strong ethical culture, cross border investigations tend to go easier than in dysfunctional organizations. Whether your organization is amongst the World’s most ethical or riddled with dysfunction, cross-border investigations are challenging either way. Global organizations are a microcosm of the countries and cultures in which they operate, and understanding customs, language,Continue reading “Cross Border Investigations and Ethical Culture”
Banking Superheroes: A Look Inside the Financial Investigations Unit
Financial Investigations Units are the unsung heroes inside banks and brokerages. They protect institutions and their customers from the things that go bump in the night. Most financial services companies above a certain size have one or more financial investigations units (FIUs) to investigate the various threats against the institution or its customers. Missions varyContinue reading “Banking Superheroes: A Look Inside the Financial Investigations Unit”
Beware of the Boiler Room: Pump & Dump Schemes Explained
The term pump and dump is not a widely known term outside of securities enforcement, but some of the names are more familiar. Stratton Oakmont and Jordan Belfort of The Wolf of Wall Street fame, Benjamin Conde and Power Traders, Rooney Pace, AR Baron and the granddaddy of them all, Bob Brennan and First JerseyContinue reading “Beware of the Boiler Room: Pump & Dump Schemes Explained”
Corruption at the United Nations? Of Course There is.
The United Nations is a unique organization made up of 193 member nations which is a combination of wealthy donor countries and impoverished beneficiary countries. The UN obtains its financial backing from donor countries and funds various initiatives and projects to alleviate suffering from terrorism and genocide and improve the quality of life in theContinue reading “Corruption at the United Nations? Of Course There is.”
Investigating the Investigators
In the forensic accounting world, there’s a little-known area commonly referred to as “shadow investigations”. A shadow investigation is when accounting firms oversee internal investigations being performed by outside counsel and their forensic investigations counterparts. The primary objective is to ensure that the investigative scope is likely to provide sufficient information for the audit partnerContinue reading “Investigating the Investigators”
Is the Secrecy of the Fine Art World a Relic of the Past?
On July 27, 2020, the US Senate Permanent Subcommittee on Investigations released a report entitled The Art Industry and US Policies that Undermine Sanctions. This report was the result of a two-year investigation into the art industry and how billions of dollars, much of it of unknown origins was used to purchase fine art. TheContinue reading “Is the Secrecy of the Fine Art World a Relic of the Past?”
When the Crisis is Unfolding – Tap the Brakes
The workforce that emerges from the combination of stay at home orders and the financial crisis will undoubtedly be very different than ever before. Each of us is dealing with unprecedented levels of stress, anxiety and uncertainty. External stressors can cause people in positions of trust to suspend good judgment and make some truly terribleContinue reading “When the Crisis is Unfolding – Tap the Brakes”
How to Deal with Increasingly Complex Sanctions Compliance
Office of Foreign Assets Control (OFAC) sanctions regulations and the and other regulatory regimes that impose restrictions on international trade have always been important tools to protect US foreign policy and national security interests. The use of sanctions has aggressively expanded in recent years, and the continuing inclusion of organizations and individuals’ names on OFACContinue reading “How to Deal with Increasingly Complex Sanctions Compliance”
Deconstructing the Minds of White-Collar Criminals
Psychology plays a significant role in investigations. Behavioral science profiling has proven to be invaluable to law enforcement and their ability to bring serial killers, terrorists and other violent offenders to justice. And yet the use of the psychological techniques in the study of white-collar criminals has not garnered nearly the same amount of attentionContinue reading “Deconstructing the Minds of White-Collar Criminals”
Artificial Intelligence Explained
Using AI for Trade Surveillance and Fraud Detection Artificial intelligence, machine learning and deep learning have become dominant forces shaping the banking and capital markets sector in recent years. Financial institutions are allocating significant resources on AI-based applications and talent and regulators are paying increased attention to the emergence of AI and its impact onContinue reading “Artificial Intelligence Explained”
Critiquing Leadership and Living to Tell About it
Compliance officers are rarely popular people in any organization, even when things are in a steady-state. When it’s time to critique a member of the leadership team, it can test the resolve of the leadership team to demonstrate their commitment to the ethics and compliance program. For the compliance officer who must deliver the message,Continue reading “Critiquing Leadership and Living to Tell About it”
Successor Liability is More Than You Bargained For
Gone are the days when the potential bribery and corruption risk of an acquisition can afford to be something assessed at the 11th hour or not at all. Successor liability stemming from undiscovered bribery activity can give rise to devasting financial consequences. On a recent episode of Fraud Eats Strategy, I discussed anti-corruption due diligenceContinue reading “Successor Liability is More Than You Bargained For”
Let’s Assume Fraud in Your Company Would be Unwelcome News
Fraud risk can lay dormant below the surface for years. This is often the case until someone in a control position recognizes a weakness in the control environment and exploits it for their gain. Right now, there are thousands of ongoing fraud schemes taking place in organizations that have gone unnoticed for years. Organizational resiliencyContinue reading “Let’s Assume Fraud in Your Company Would be Unwelcome News”
The DOJ Expects You to Know Its Compliance Guidance Inside and Out
In November 2012, the DOJ Fraud Section and the SEC published what would turn out to be a groundbreaking document: A Resource Guide to the U.S. Foreign Corrupt Practices Act. Detailed and yet very approachable and written in plain English, “the Guide” as it is commonly referred to, is the primary desk reference for everyContinue reading “The DOJ Expects You to Know Its Compliance Guidance Inside and Out”
Active Whistleblower Hotlines Boost the Bottomline
One of the more challenging aspects of regulatory compliance is measuring the return on investment (ROI). Efforts to measure ROI on compliance expenditures have historically been in terms of the cost savings of disasters averted. During uncertain economic times such as many organizations are now facing, the CFO will likely be unmoved by a “disasterContinue reading “Active Whistleblower Hotlines Boost the Bottomline”
It’s OK to Use Zoom to Interview Witnesses
Investigators and attorneys are two professions best practiced in person. Yet, witness interviews and depositions have had to revert to video conferencing. This has invigorated debates focused on the use of body language and other physical cues to detect deception, or if someone is being coached off of the screen. It has also caused usContinue reading “It’s OK to Use Zoom to Interview Witnesses”
Swimming Naked in a Down Economy
During the last financial crisis, Warren Buffet said, “You only find out who is swimming naked when the tide goes out.” Adverse market conditions expose risks and test a company’s resilience and like low tides, when the economy recedes, long-running frauds are often exposed. In a recent episode of FTI’s new podcast series: Fraud EatsContinue reading “Swimming Naked in a Down Economy”
The Achilles Heel of FCPA Compliance: Bribe-Paying Third Parties – Fraud Eats Strategy
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