Modern banking types are well aware that the base salary of a private banker is just the starting point in determining his or her complete compensation package. His bonus – while not mentioned in the attached article – would have been substantial, especially if he was cooking the books and showing off impressive numbers to his superiors.
If the predicate offense was a Ponzi scheme fraud of the Madoff variety, can one consider his bonus as the proceeds of crime? His superiors would not have been impressed that they had rewarded him under false pretences. If he moved his bonus out of his personal accounts at the financial institution that employed him (perhaps to one of the countries on the recently revised FATF “Naughty List”), can it be considered money laundering?
His previous employers seem willing to brush the whole incident under the carpet and pay the associated FINRA penalties. I wonder if a young United States Attorney is willing to make his name on prosecuting Mr. Arbizu’s bonus payment under American money laundering laws?
“Consequences, shmonsequences! So long as I'm rich!”
- Daffy Duck
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http://www.nytimes.com/2009/06/30/business/30banker.html?_r=1&ref=business&pagewanted=print
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