Fri, 05 Jul 2024 14:50:40 -0700WeeblyMon, 11 Aug 2014 02:58:45 GMThttp://moneylaunderingconsultants.com/money-laundering-blog/fincen-proposing-new-due-diligence-rules-on-banksbrokeragesFINCEN is proposing additional due diligence rules on financial institutions, namely, additional "know your customer" (KYC) requirements to alleviate the use of "shell corporations" as a front to launder illicit funds through financial institutions. The new proposed rules will place additional requirements on financial institutions to identify the "true" owners of the corporations by the banks. But the proposed rule change does not require additional due diligence on the other owners of the corporation but to merely identify them which would provide investigative leads to law enforcement in the future. In addition to the identification of the owners, financial institutions will be required to conduct periodic reviews of financial transactions and ownership of the corporation etc. Most if not all financial institutions conduct periodic transactional reviews of their corporate and individual accounts as part of their anti-money laundering regime to protect the institution from civil and/or criminal prosecution under the money laundering statutes. It has been my experience through twenty-two years of conducting money laundering investigations that criminals always utilize a "nominee" or "straw person" to establish and maintain a bank account or corporate bank account to place a layer between the bad guys and their illicit money. I believe that the additional identification of the owners of the corporation may not identify the bad guy and the source of the illicit money flowing through a corporate bank account. Additional due diligence can be completed through other investigative means and database queries. ]]>Wed, 23 Jul 2014 21:00:08 GMThttp://moneylaunderingconsultants.com/money-laundering-blog/liberty-reserveGreat cooperation, dedication and hard work went into this case. These type of international investigations are extremely difficult because a great deal of the criminal conduct occurs offshore. But it is a true testament to agents and the agencies in developing great relationships overseas and eliciting the cooperation from our law enforcement counterparts to assist in the investigation. A job well done!!]]>