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CONFESSIONS OF A
MONEY LAUNDERER by Kenneth Rijock
MONEY LAUNDERER by Kenneth Rijock
Financial Crime Consultant, for World-Check
Confessions of a Money Launderer - Part 67
1 June 2008
In conducting the lectures on the efficient use of what was then the relatively new Internet, I always held a Q & A session at the end of each class. Their questions revealed not only a lack of knowledge of the best websites, but an inflexibility in search techniques. Whether this was specific to the industry, as law enforcement culture encourages conformity in all things, or simply a lack of imagination, it required a solution. Since many searchers were glued to one or two search engines, I encouraged the use of sites that featured multiple search engines, such as Dogpile (www.dogpile.com), or the use of more obscure search engines, like Northern Light, and similar significant alternatives to Lycos. AltaVista, Excite, HotBot and others. They needed to understand that search engines were not a substitute for an inquiring mind. But on to the resources I found that were of great value in money laundering investigations, due diligence enquiries, customer identification procedures, and suspicious activity queries.
Some of the additional Internet assets I passed along to my students, and which can open doors to information not otherwise available:
Next Week: More websites of relevant interest.
- Telephone number/address sites: Before the Internet, we used what Americans refer to as "criss-cross" directories, or hard-copy indexes of addresses and telephone numbers. Such volumes, which were unfortunately generally updated only annually, would confirm that your target did or did not own his residence. how many years he or she had been there, and any additional residents and telephone numbers listed at that specific address. it also allowed you to literally cross the street and get the neighbor's name and number, in case you wanted to make a tactful call to enquire about details, or simply to verify, information on your target. With the advent of the Internet, more-current information was available instantly, searching was facilitated, and information about non-public numbers might be available that was previously out of bounds. Also, if you wanted reverse look-up information on areas outside your own, it was now within reach.
- Secretary of State Corporations Division websites: Before the advent of the world-wide-web, I routinely encountered criminal investigators sitting patiently in the Miami office of the Florida Secretary of State, combing company records on the agency's public-access computers. They were seeking to learn whether their criminal targets of enquiry were officers, directors or registered agents of companies formed in the state, or out-of-state companies qualified to transact business there. The companies uncovered could be fronts for money laundering operations, shell companies, or virtual companies with no other purpose than to shield criminals from casual enquiry. They would then order copies from the clerk. Nowadays, free or pay searches of the corporate records of just about all of the states are easily accessed on the Internet, and much more efficiently. Such searches also reveal straw men, who front for individuals whose names cannot appear, and previously-unknown associates or partners. The actual scanned-in filed corporate documents are also often available, giving one an actual signature for comparison purposes. Corporate & home addresses are also discoverable on those databases, as are Federal tax identification numbers. One also can verify exact corporate names, deceptively similar names, defunct companies being held out as active, and a host of other hidden problems. Has a new client failed to disclose his interest in a company that might cause you to decline his business? Are there suspected organised crime members as officers in a company?
- Personal and occupational data: Licensed professionals' standing can generally be verified through the websites of their regulatory agencies, and some do provide disciplinary history, or at least a hint of whether the target has had problems in the past. My 1991 resignation as a member of the Florida Bar, filed by me due to pending administrative proceedings that appeared as a result of my felony conviction, can be found on the Internet. Many persons' names can be found somewhere on their company's websites, and images are often also in there somewhere. Note that I find Google Images superb for tracking down photos of persons under enquiry, often whilst engaged in recreational, charitable or social functions. As a compliance officers interested in verifying clients' employment at large European companies, the firm websites often provided either the client's name, or an e-mail address at the company where I could request employment verification.
- Financial regulator websites: Does the bank where a large number of high-value wire transfers have a disciplinary history with federal and /or state regulators? Is it perhaps presently operating under a Cease & Desist or Consent Order? Since banks hope the world doesn't discover their shortcomings for reputation damages purposes (customers move their accounts), they often don't publicise regulatory actions, or utilise spin to give the actions a quasi-positive slant. Using the regulator databases can uncover information that will aid you in risk assessments. Has a banker himself been fined or disciplined? This information is available.
- Securities and broker/dealer issues: the EDGAR website, at www. sec.gov, is invaluable in learning whether the prospective clients has ever had a problem, is a major holder of publicly-traded stock, is or was involved with a large company, and has been barred from acting as a broker. It can open your eyes about how your clients does business. Also, in a world where insider trading is a major crime, it tells you what role the client has in corporations listed on the stock exchange.
Next Week: More websites of relevant interest.
The facts and opinions stated in this article are those of the author and not those of World-Check. World-Check does not warrant the accuracy of any facts and opinions stated in this article, does not endorse them, and accepts no responsibility for them.
Read more in this exciting series
11 April 2010
8 March 2010
8 February 2010
24 January 2010
6 December 2009
27 September 2009
9 August 2009
3 August 2009
30 March 2009
9 March 2009
2 March 2009
22 February 2009
18 February 2009
26 January 2009
18 January 2009
11 January 2009
5 January 2009
29 November 2008
24 November 2008
17 November 2008
8 November 2008
3 November 2008
27 October 2008
20 October 2008
13 October 2008
4 October 2008
28 September 2008
20 September 2008
15 September 2008
15 June 2008
8 June 2008
1 June 2008
26 May 2008
19 May 2008
12 May 2008
4 May 2008
27 April 2008
20 April 2008
13 April 2008
31 March 2008
18 March 2008
4 March 2008
25 February 2008
16 February 2008
10 February 2008
3 February 2008
27 January 2008
20 January 2008
14 January 2008
6 January 2008
16 December 2007
9 December 2007
1 December 2007
25 November 2007
18 November 2007
11 November 2007
3 November 2007
27 October 2007
21 October 2007
14 October 2007
7 October 2007
1 October 2007
23 September 2007
16 September 2007
3 June 2007
27 May 2007
21 May 2007
6 May 2007
30 April 2007
22 April 2007
15 April 2007
8 April 2007
2 April 2007
24 March 2007
19 March 2007
12 March 2007
5 March 2007
25 February 2007
19 February 2007
12 February 2007
4 February 2007
28 January 2007
22 January 2007
15 January 2007
7 January 2007
2 January 2007
16 December 2006
10 December 2006
3 December 2006
27 November 2006
19 November 2006
11 November 2006
5 November 2006
29 October 2006
22 October 2006
16 October 2006
9 October 2006
2 October 2006
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