Tuesday, June 30, 2009

Articles of Interest 094 - Bonus as proceeds of crime

Hernan E. Arbizu was a private banker at two prominent international private banks who earned a base salary of USD300,000 at one bank in 2003 for managing 13 accounts with USD200m in assets. He is now accused of fraud in shuffling around client money in order to meet the expectations of clients who were promised by him outlandish returns.

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

A historlcal archive of the Articles of Interest series is available on http://manchestercf.blogspot.com

Monday, June 29, 2009

Articles of Interest 093 - Silence says it all

The Japanese Financial Services Agency (“FSA”) has imposed a one month ban on Citibank Japan’s retail banking marketing activities. Citibank Japan’s private banking business incurred a similar wrath from Japanese regulators in 2005, leading to the closing of a business that contributed almost USD100m to the group’s bottom line.

The main problem cited by the FSA was an “...(i)nadequate system for accurate execution of the obligation to make notification of suspicious transactions including money laundering”

Even more interesting is the following quote from the FSA’s assessment: “...moreover, it is found that procedures to control any dealing with anti-social forces have not been developed.”

In some societies, loud confrontation keeps rule-breakers in line. In other societies, an apology, “business improvement plan” self-examination confession and silence condemns the violator to an even harsher punishment.

“In the end, we will remember not the words of our enemies, but the silence of our friends..”

- Martin Luther King Jr. (1929 - 1968)

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http://www.citibank.co.jp/en/customernotices/customernoticesindex/customernoticepages/cust_062609_01.html

Citibank Japan Receives Administrative Action From the Financial Services Agency

June 26, 2009

Tokyo June 26, 2009 - Citibank Japan Ltd. ("Citibank Japan") received an administrative action from the Financial Services Agency ("FSA") based on Article 26 of the Banking Act. This action relates to the compliance framework and governance framework of Citibank Japan. The administrative action issued by the FSA today is referenced below.

In accordance with this action, Citibank Japan will suspend sales activities (including advertising, sales campaigns and solicitation) of all products that are handled by its Retail Banking Division from July 15 to August 14. This suspension does not restrict any activities with customers who wish to enter into a transaction with Citibank Japan.

Citibank Japan takes this administrative action very seriously and would like to express our sincere apology to our customers and other parties concerned. Citibank Japan is committed to implement all necessary measures to prevent any future occurrence of the problems identified.

The FSA cited problems relating to Citibank Japan's insufficient governance, compliance and internal control framework to fulfill its filing obligations for suspicious transactions. Since an initial incident was first identified and reported voluntarily to the FSA, Citibank Japan has subsequently been cooperating with the FSA and has already begun to take actions to address issues raised.

In response to the administrative action, Citibank Japan will submit a business improvement plan to enhance its governance and compliance framework to the FSA by July 31, 2009. In addition, Citibank Japan will clarify responsibility for this matter and take appropriate disciplinary action. Citibank Japan will announce the summary of the business improvement plan and disciplinary action promptly after submission to the FSA, and the improvement plan will cover the following:

Enhancement of the governance and internal control framework.
Enhancement of the compliance environment and re-training of all employees on applicable laws and regulations.
Enhancement of the framework to file suspicious transaction reports adequately, including the management, monitoring and cancellation of such transactions, and specifically as related to handling of anti-social forces.
Enhancement of internal audit review function.
Citibank Japan reiterates that it takes this administrative action very seriously and is deeply apologetic for the issues insufficiently resolved, including as part of its 2004 Business Improvement Order. Citibank Japan is committed to focus all necessary resources to implement every necessary measure to prevent future occurrence.

The administrative action does not affect Citibank Japan's ability to serve its Corporate Banking Division clients.

Citibank Japan Ltd.

Administrative Actions against Citibank Japan Ltd.

The Financial Services Agency (FSA) issued today the following administrative actions against Citibank Japan Ltd.;

I.　Description of the Administrative Actions

Orders based on Article 26(1) of the Banking Act

1.　Suspend all sales operations (including advertisement, sales campaign and publicity and solicitation) pertaining to all products that are handled by Retail Banking Division during the period from July 15, 2009 to August 14, 2009; provided however, that this shall not preclude sales operations (including the explanation of products) in cases where there are any voluntary manifestations of intention by customers and where such manifestations of intention can be objectively found.

2.　In order to ensure appropriate and sound business operation, fundamentally review and restructure the current governance, internal control and business management system (including adequate staffing and the construction of a proper organization and structure) of the Citibank Japan Ltd. [hereinafter referred to as the "CJL"] from the following perspectives:

(1)　clarify the business attitude of the board of directors and management committee towards the establishment and enhancement of governance and internal control systems;

(2)　develop and enhance a system for accurate execution of the obligation to make notification of suspicious transactions including money laundering; and establish a system for the control, monitoring, cancellation, etc. of transactions, etc. subject to notification;

(3)　ensure a thorough understanding of and compliance to laws and regulations and other rules by officers and employees and foster and improve awareness of compliance with laws and regulations;

(4)　restructure the system necessary for ensuring the effectiveness of internal control functions, review methods, the frequency, etc. of audits, and conduct follow-ups after the audits; and

(5)　investigate the causes why the improvement plan that was submitted to the FSA in response to the FSA's previous order on September 17, 2004 to improve business operations was not implemented appropriately and clarify where the responsibility lies, including with management.

3.　Submit business improvement plans (including clarification of the assignment of responsibilities for the development and establishment of a governance system to implement the improvement plan steadily and to ensure the effectiveness of the improvement plan) pertaining to matters stated in 2. above and the report order by July 31, 2009 and execute the plan immediately.

4.　Report the progress, implementation status, and improvement status of said business improvement plan every three months on the fifteenth of the following month from the end of September 2009 until the business improvement plan is completed.

II.　Reasons for the Administrative Actions

According to voluntary reporting submitted by CJL, a report collected by FSA pursuant to the provisions of Article 24(1) of the Banking Act, and subsequent on-site inspection (notification made on April 3, 2009), it is found that there are fundamental problems with CJL's compliance and governance system from the perspectives of sound and appropriate business management stated below.

1.　Problems with Compliance System

(1)Inadequate system for accurate execution of the obligation to make notification of suspicious transactions including money laundering

Control systems necessary for the detection, monitoring, and follow-up of suspicious transactions have not been developed, such as the following: with regard to CJL's system to make notification of suspicious transactions including money laundering, despite the fact that it mainly relies on screening based on the database, input data is extremely limited; in addition, the database has not been updated since 2004; under these conditions, the screening has been performed, therefore, prior screening at the opening of an account or ex-post verification has become meaningless; moreover, it is found that procedures to control any dealing with anti-social forces have not been developed.

As mentioned above, CJL is in a condition where systems for accurate execution of the obligation to make notification of suspicious transactions, pursuant to Article 54 of the Act on the Punishment of Organized Crimes and Control of Crime Proceeds prior to the revision and Article 9 of the Act on the Prevention of Transfer of Criminal Proceeds after the revision, have not been developed.

(2)Violation of a business improvement order pursuant to Article 26(1) of the Banking Act

In response to the result of our on-site inspection, in September 2004, CJL (Citibank, N.A. Japan Branch then) received a revocation order of Marunouch branch et al., pursuant to Article 27 of the Banking Act and other regulations, and a business improvement order regarding fundamental review pertaining to the compliance and governance of Citibank, N.A. Japan Branch, pursuant to Article 26(1) of the Banking Act and other regulations.

In spite of the business improvement order, as mentioned in (1) above, with regard to the establishment of an operation and management system for the accurate execution of the obligation to make notification of suspicious transactions, the fact is found that the improvements on the plan that Citibank, N.A. Japan Branch has established have not yet been implemented.

2.　Problems with governance and internal control systems

Despite the fact that the board of directors and management committee of CJL (including the CEO and management committee of Citibank, N.A. Japan Branch) were responsible for the execution of the business improvement order, they lack an understanding of the rules applied in Japan, such as laws and regulations, and an awareness of improvement. Therefore, the board of directors and management committee do not have systems to consider, discuss, or inspect important matters of management across the board and have no way to control or check business departments, since the board of directors and management committee failed to confirm and inspect a system necessary for execution of the obligation to make notification of suspicious transactions, including money laundering; they overlooked the fact that the responsible department, such as the Anti Money Laundering Department of the Compliance Division, lacks engagement in the business improvement plan, etc.

3.　Internal audit

CJL has established an internal audit department in order to establish a system to engage in identifying problems by checking, following up, etc. the implementation status of the business improvement plan, in addition to auditing normal operations; however, CJL has not accurately identified a series of problems that were recently found during the implementation of the improvement plan up until today and the effectiveness of the internal audit has not been ensured.

Tuesday, June 23, 2009

Articles of Interest 092

Mathematical Difficulties

The Daily Telegraph has performed a rudimentary analysis on the United Kingdom’s Serious Organised Crime Agency’s (SOCA) figures:

Amount of money received by SOCA from Her Majesty’s taxpayers since inception in 2006 = GBP1.2b
Amount of money recovered from criminals = GBP78m

One is tempted not to insert a third line with the word “priceless”, however SOCA – like most other financial intelligence units – should not be designed as a profit centre. One cannot measure the contribution of an FIU on the basis of money recovered only, as it ignores prevention, deterrence, national security, education and so many other benefits.

The modern press has had a difficult time sorting the nonsense from the truth amidst the current financial crisis (best name to date = “The Great Recession”). Given the target-rich environment, hammering away at the local domestic financial intelligence is a poor decision in these troubled times.

“Do not worry about your difficulties in Mathematics. I can assure you mine are still greater.”

- Albert Einstein (1879 – 1955)

===========

http://www.telegraph.co.uk/news/newstopics/politics/lawandorder/5612151/Britains-FBI-Soca-spending-15-for-every-1-it-recovers.html

Britain's 'FBI' Soca spending £15 for every £1 it recovers

The Serious Organised Crime Agency (Soca) - Britain's "FBI" - is spending £15 of public money for

every £1 it seizes from criminal gangs but its chairman has still marked it eight out of ten for effort.

By Tom Whitehead, Home Affairs Editor

Published: 2:28PM BST 23 Jun 2009

Soca has received around £1.2bn since it began in 2006 but has so far only recovered £78 million from criminals, MPs were told. Sir Stephen Lander, it's outgoing chairman, also admitted the organisation had underestimated the scale of crimelords and gangs it had to tackle.

He said there are now an estimated 4,000 individuals involved in serious criminal gangs.

"The scale of the problem is larger than people have anticipated," he told the Commons Home Affairs Select Committee. He added later: "It was always going to take some time to get going. To be honest, I think I underestimated some of the organisational difficulties we would experience in the beginning. Sir Stephen said the actual money seized did not include assets and cash that have been restrained and that overall criminals had been stopped from using some £460 million.

Asked how well he thought the organisation had performed he gave it eight out of ten.

Challenged on whether others would agree, he added: "I have the advantage of knowing the facts."

Bill Hughes, director general of Soca, said only around a third of cocaine is stopped from entering the UK and warned it is being cut with inappropriate substances such as worm powder.

Soca recently claimed cocaine traffickers are in retreat following a series of operations against them which has forced the price up. But drugs campaigners Release said the price had gone up because of the poor exchange rate between sterling and US dollar.

Saturday, May 9, 2009

Articles of Interest 091

Upsetting More than Regulators

If a bank fails to identify a money laundering scheme and report it properly to the authorities, is it liable for the losses incurred by those who fell victim to the scheme?

Legal risk traditionally meant the risk a bank faced in following the letter and the spirit of the law. Does a new risk need to be added as a subsection of legal risk, namely civil litigation risk?

http://www.consumeraffairs.com/news04/2009/01/bofa_scam.html

----------

Bank Of America Sued In Internet Ponzi Scheme

Hundreds of millions of dollars collected in gigantic swindle

January 30th, 2009

Victims of an Internet-based Ponzi scheme have filed a lawsuit against Bank of America and the organizers of the scheme in the United States District Court for the District of Columbia.

Using elaborate misrepresentations, including numerous video postings on YouTube, organizers induced victims from around the country to purchase so-called "ad packages" from the following entities: AdSurfDaily, AdSurfDaily Cash Generator, Golden Panda Ad Builder, and La Fuente Dinero.

The scheme promised that participants could earn large rebates for viewing web advertisements and commissions for referring additional participants.

Hundreds of millions of dollars were collected from approximately 140,000 victims across the country, in amounts ranging from $500 to $250,000 at large rallies and through online deposits.

"We intend to hold all defendants accountable for this Ponzi scheme, including the Bank of America, and secure the return of all funds that were lost by innocent victims, said Steven N. Berk, a partner in the law firm of Chavez & Gertler LLP and a former federal prosecutor representing the plaintiffs in this case.

How does Bank of America figure into all of this?

The complaint alleges that a scheme of this magnitude could not have been possible without the involvement of a financial institution like Bank of America.

At least one other financial institution closed the accounts of the organizers for suspicious activity, according to a sworn government complaint. VISA also considered the enterprise suspicious and would not process charges directed to the scheme by would be victims. And the very popular PayPal payment system rejected efforts by participants to purchase "ad packages" using their system.

Nevertheless, the suit charges Bank of America, in the face of tell-tale signs of money laundering and other criminal conduct, provided both the imprimatur of legitimacy to the scheme and the banking infrastructure that facilitated many thousands of transactions for over two years.

Beginning in November of 2006, Bank of America allegedly allowed the scheme's main perpetrator carte blanche at the bank. The complaint claims the scammers opened and maintained at least 10 separate accounts for running an unlawful Ponzi scheme. These accounts were opened at a tiny Bank of America branch in Quincy, Florida under various "doing business as" designations.

The suit claims Bank of America looked the other way when these accounts amassed deposits in the tens of millions of dollars from thousands of individual transactions.

"We expect to establish that Federal banking regulations, including the Bank Secrecy Act, the USA Patriot Act and related anti-money laundering regulations, clearly required Bank of America to scrutinize the legitimacy of the tens, if not hundred of millions of dollars deposited into a branch in Quincy, Florida to fuel this scheme. Red flag after red flag was ignored by Bank of America. And with the assistance of Bank of America, this fraudulent scheme needlessly expanded" said Steven N. Berk, Counsel for the Plaintiffs.

Articles of Interest 090

Drugs and Guns

If there was any doubt that international narcotics could be intertwined with terrorist activity, the prosecution of Bashir Noorzai should answer all questions.

----------

News Release
FOR IMMEDIATE RELEASE
April 30, 2009
Garrison Courtney
Office of Public Affairs
202-307-7977

Top Taliban Associate and Former Mujahideen Warlord Sentenced to Life in Prison on Heroin Trafficking Charges

APR 30 -- LEV L. DASSIN, the Acting United States Attorney for the Southern District of New York, announced that BASHIR NOORZAI, a former Mujahideen warlord and strong ally of the Taliban, was sentenced today to life in prison on heroin importation and distribution conspiracy charges. NOORZAI was found guilty of the charges following a jury trial before Federal Judge DENNY CHIN in September 2008. According to the evidence at trial:

NOORZAI, the leader of his namesake tribe, one of Afghanistan's largest and most influential tribes, owned opium fields in the southern province of Kandahar, Afghanistan, and had subordinates convert the opium into heroin at laboratories in Afghanistan's border regions. Heroin from these labs was later imported into the United States, hidden in suitcases and on ships. As early as 1990, NOORZAI had a network of distributors in New York City who sold his heroin.

During the Russian occupation of Afghanistan, NOORZAI raised his own army of Mujahideen fighters, financed and armed with drug proceeds. After the Russian army had quit Afghanistan, NOORZAI ruled western Kandahar, establishing and controlling his own police, border guards and courts.

NOORZAI met MULLAH MOHAMMAD OMAR in the 1980s while the two fought in the same Mujahideen faction. In the mid-1990s, when the Taliban was ascending to power in Afghanistan, NOORZAI used his influence in Kandahar to assist OMAR in securing the position of supreme leader of the Taliban. NOORZAI then provided the Taliban with arms, including AK-47 assault rifles, rocket propelled grenade launchers, and anti-tank weapons, as well as vehicles and a portion of the proceeds of his narcotics trafficking activities. In 2001, after the United States began military operations in Afghanistan, NOORZAI, at OMAR's request, provided the Taliban with 400 of his own fighters to wage a battle against Afghanistan's Northern Alliance in Mazar-e-Sharif.

In return for his financial and other support, the Taliban permitted NOORZAI to continue his drug trafficking activities with impunity. In addition, NOORZAI and his co-conspirators benefitted from advance knowledge of the Taliban's 2000 opium ban, and used that information to stockpile opium and sell it at a tremendous profit after the ban caused opium prices to spike.

At trial, NOORZAI was found guilty of both counts against him -- one count of conspiring to import heroin, and to manufacture and distribute heroin knowing that it would be imported into the United States, and one count of conspiring to distribute heroin.

NOORZAI, who faced a mandatory minimum sentence of 10 years, was sentenced by Judge CHIN to life imprisonment on each count in the Indictment. In sentencing NOORZAI, Judge CHIN found that he led a conspiracy involving hundreds of people, and that the conspiracy helped arm the Taliban with narcotics proceeds.

Prior to his arrest in 2005, NOORZAI had been designated by the Department of Justice to the Consolidated Priority Organization Target ("CPOT") list, a list of the most powerful and dangerous narcotics traffickers in the world. His successful prosecution is the result of a long-term investigation by this Office's International Narcotics Trafficking Unit, the Drug Enforcement Administration's New York Field Division, its Kabul, Afghanistan and Islamabad, Pakistan Country Offices, and
the New York Joint Terrorism Task Force, which includes special agents of the Federal Bureau of Investigation. The DEA's Special Operations Division also assisted in the investigation and prosecution.

"BASHIR NOORZAI's worldwide narcotics network supported a Taliban regime that made Afghanistan a breeding ground for international terrorism, a legacy that continues to destabilize the region," said Acting United States Attorney LEV L. DASSIN."Today's sentence definitively puts an end to Noorzai’s long criminal career."

The prosecution was handled by the Office’s International Narcotics Trafficking Unit. Assistant United
States Attorneys JOCELYN STRAUBER, ANJAN SAHNI, BOYD JOHNSON, and ANIRUDH BANSAL are in charge of the prosecution.

Friday, May 8, 2009

Articles of Interest 089

Lack of Proper Training

The former bank managers from Bank of China have been sentenced in the United States for laundering their embezzled funds through Hong Kong, Canada and Las Vegas casinos. Sentences were imposed ranging from eight to twenty-five years in prison.

Given the general lack of creativity - especially when one has half a billion dollars at one's disposal - exercised by the BoC managers, money launderers would do well to seek the advice of others. Where were multiple shell banks and international business corporations registered in faraway offshore financial havens? Where were the hidden tricks that should be known to bankers employed with a global financial institution?

Anti-money laundering training at BoC clearly does not delve into enough detail.

http://www.usdoj.gov/opa/pr/2009/May/09-crm-446.html

----------

FOR IMMEDIATE RELEASE
Wednesday, May 6, 2009
WWW.USDOJ.GOV

CRM
(202) 514-2007
TDD (202) 514-1888

Former Bank of China Managers and Their Wives Sentenced for Stealing More Than $485 Million, Laundering Money Through Las Vegas Casinos

Two former managers of the Bank of China and their wives were sentenced today after their convictions on Aug. 29, 2008, by a federal jury in Las Vegas on charges of racketeering, money laundering, international transportation of stolen property as well as passport and visa fraud.

U.S. District Judge Philip M. Pro sentenced Xu Chaofan aka Hui Yat Fai to 25 years in prison, Xu Guojun aka Hui Kit Shun to 22 years in prison, Kuang Wan Fang aka Wendy Kuang to eight years in prison and Yu Ying Yi to eight years in prison. All four defendants were sentenced to three years of supervised release and ordered to pay $482 million in restitution. Denaturalization proceedings against Kuang Wan Fang and Yu Ying Yi have been initiated by the government.

Evidence presented during the trial established the elaborate scheme to defraud the Bank of China of at least $485 million, orchestrated by former managers Xu Chaofan, Xu Guojun and a third former bank manager, Yu Zhendong aka Yu Wing Chung, who pleaded guilty in connection with this investigation and cooperated with the United States. According to information presented in court, the scheme involved efforts by the bank managers to launder the stolen money through Hong Kong, Canada and the United States, among other countries, and then immigrate to the United States from China with their wives by obtaining false identities and entering into sham marriages with naturalized U.S. citizens. Evidence also proved that the bank managers’ true wives, Kuang Wan Fang and Yu Ying Yi, assisted their husbands in laundering the proceeds of the fraudulent scheme and violated U.S. immigration laws by entering this country illegally and then securing U.S. citizenship and passports through fraudulent means.

All five defendants were charged with engaging in a RICO conspiracy that began in 1991 and continued until October 2004 when the former bank managers and their wives were arrested. The underlying racketeering activities included engaging in monetary transactions with stolen money, transportation of stolen money, passport fraud and visa fraud. Evidence presented at trial established that the former bank managers created a number of shell corporations in Hong Kong and with the assistance of others funneled the bank’s money into these companies as well as numerous personal bank and investment accounts. Assisted by their wives, relatives and others, the former bank managers then laundered the stolen proceeds through Canada and the United States. Evidence presented at trial included a significant number of transactions with the stolen money through Las Vegas casinos, including bets at the casinos that ranged from $20,000 up to $80,000.

All five defendants also were convicted of engaging in a money laundering conspiracy and conspiracy to transport stolen money that began in 1998 and continued through October 2004. These conspiracy charges focused on the laundering of the stolen money in the United States not only through casinos, but also through numerous bank accounts established in the United States by the defendants.

The two former bank managers were also convicted on three counts each of visa fraud – specifically, the possession and use of a fraudulently procured non-immigrant U.S. visa to enter and/or remain in the United States. The two bank managers’ true wives were convicted of three counts each of passport fraud – specifically, the use of a U.S. passport secured through a false statement to enter or facilitate their stay in the United States.

"We will hold fully accountable those foreign nationals who abuse the financial systems of their home countries and who then, by fraudulent means, seek to live richly off their ill-gotten gains in the United States," said Assistant Attorney General Lanny A. Breuer. "Despite the best efforts of these defendants to avoid detection, their scheme first to steal nearly $500 million from a Chinese bank, and then to hide themselves and the money in the United States, was exposed thanks to the tireless efforts of federal agents and prosecutors. With their hard work, and the work of countless others like them who are on constant guard against theft and fraud, the Department will continue to unravel the most complicated financial crimes."

"The defendants sentenced today engaged in a complex scheme from across the globe, using U.S. banks and casinos to launder more than $485 million stolen from the Bank of China. Financial crimes like these know no borders. By partnering in investigations such as this one, the FBI and our law enforcement partners in the United States and abroad can combine our collective resource to most effectively attack this worldwide criminal threat," said Assistant Director Kenneth W. Kaiser, FBI Criminal Investigative Division.

Xu Chaofan, Xu Guojun, Kuang Wan Fang and Yu Ying Yi were charged on Sept. 21, 2004, in an 11-count indictment with conspiring to violate, and substantive violations of, U.S. immigration law. The third former bank manager, Yu Zhendong, pleaded guilty to engaging in a racketeering enterprise on Feb. 18, 2004, and voluntarily returned to China, where he was convicted for embezzlement for his role in the bank theft. Yu Zhendong’s true wife, Yu Xuhui (aka Fion Yu), pleaded guilty on April 26, 2005, to unlawfully procuring U.S. citizenship. She has agreed to voluntarily relinquish her American citizenship, but was permitted to remain in the United States with the couple’s children as long as she does not commit another crime. Yu Zhendong’s fake American wife, Shanna Yu Ma (aka Yu Shuzhan) pleaded guilty to submitting a false statement to the Immigration and Naturalization Service, now part of the Department of Homeland Security, in support of Yu Xuhui’s application for naturalization. Both Ma and Yu were sentenced in December 2007 to terms of probation.

This matter was prosecuted by Trial Attorney Krista Tongring and former Trial Attorney Cynthia Stone and of the Criminal Division’s Organized Crime and Racketeering Section and Assistant U.S. Attorney Ronald Cheng of the U.S. Attorney’s Office for the Central District of California. Organized Crime Strike Force Chief Eric Johnson of the U.S. Attorney’s Office for the District of Nevada served as local counsel. Significant assistance was also provided by Kyle Latimer of the Criminal Division’s Office of International Affairs. The U.S. Attorney’s Office for the District of Nevada provided significant support for the prosecution and coordination of witnesses from throughout the United States and overseas. The case was investigated by the FBI’s Las Vegas Field Office and U.S. Immigration and Customs Enforcement of the Department of Homeland Security. Essential support was also provided by the FBI’s offices in Beijing and Hong Kong. The government of the People’s Republic of China, in particular the Ministries of Justice and Public Security along with the Hong Kong Department of Justice and Hong Kong Police Force, also provided substantial assistance in producing evidence and making witnesses available, both for testimony at trial and videotaped depositions.

###

09-446

Wednesday, May 6, 2009

Articles of Interest 088

Word from on High

Times are tough for financial institutions but regulatory expectations remain the same in the realm of anti-money laundering and counter-terrorist financing. Reporting entities in Canada – and abroad – would do well to ask their supervisory agencies and financial intelligence units how the public sector is assisting them to defray the enormous expense of mounting an effective financial crime risk management regime. For those worried about solvency risk vs. legal / regulatory risk, this is a realistic question.

“Lack of money is the root of all evil.”

- George Bernard Shaw (1856-1950)

Tuesday, June 30, 2009

Articles of Interest 094 - Bonus as proceeds of crime

Monday, June 29, 2009

Articles of Interest 093 - Silence says it all

Tuesday, June 23, 2009

Articles of Interest 092

Saturday, May 9, 2009

Articles of Interest 091

Bank Of America Sued In Internet Ponzi Scheme

Hundreds of millions of dollars collected in gigantic swindle

January 30th, 2009

Articles of Interest 090

Friday, May 8, 2009

Articles of Interest 089

Former Bank of China Managers and Their Wives Sentenced for Stealing More Than $485 Million, Laundering Money Through Las Vegas Casinos

Wednesday, May 6, 2009

Articles of Interest 088

Articles of Interest

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Tuesday, June 30, 2009

Articles of Interest 094 - Bonus as proceeds of crime

Monday, June 29, 2009

Articles of Interest 093 - Silence says it all

Tuesday, June 23, 2009

Articles of Interest 092

Saturday, May 9, 2009

Articles of Interest 091

Bank Of America Sued In Internet Ponzi Scheme

Hundreds of millions of dollars collected in gigantic swindle

January 30th, 2009

Articles of Interest 090

Friday, May 8, 2009

Articles of Interest 089

Former Bank of China Managers and Their Wives Sentenced for Stealing More Than $485 Million, Laundering Money Through Las Vegas Casinos

Wednesday, May 6, 2009

Articles of Interest 088

Articles of Interest

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