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The Anti-Money Laundering Association is proud to announce a partnership with Mr. Erich Ferrari of Ferrari Legal, P.C. Erich is an OFAC legal compliance expert and brings a wealth of information to our association members. Erich is able to take a very complicated subject matter and translate into an easy to understand teaching. I encourage you to visit the sanction law blogspot (link below) which will benefit every BSA/AML/OFAC compliance professional. In addition, Erich recently wrote the first legal practice guide devoted to the topic of U.S. trade sanctions against Iran: The Iranian Transactions Regulations Practice Guide. This legal manual gives a detailed background of OFAC, addresses numerous topics which may arise when transacting with Iran and also contains OFAC investigations. The practice guide is very well written and the reading level is easy to understand. Please contact Erich for more information.
Ferrari Legal, P.C.
Ferrari Legal is a boutique law firm specializing in OFAC related representations. Our firm handles matters ranging from general counseling to OFAC licensing to defending against OFAC investigations and penalties. We are one of the few firms who understand OFAC and how they operate. We service clients on five continents in a variety of complex OFAC matters involving high profile clients and high stakes transactions. We have the experience and knowledge to successfully guide you through the increasingly complex web of OFAC administered regulations.
While U.S. persons are required to comply with OFAC regulations many are taking such efforts without any true understanding of what the regulations say. This is the equivalent of playing in a game where you don’t know the rules. As such, OFAC compliance is often a case of the blind leading the blind. Imagine how much stronger your compliance program will become once you truly understand the regulations you seek to comply with. It’s time to step out of the darkness; we shine the light on OFAC.
In addition to our representations, our firm serves as a thought leader on OFAC related legal issues. Click http://www.sanctionlaw.com to read about the latest trends in OFAC administered sanctions.
Erich Ferrari at email@example.com
1455 Pennsylvania Ave., NWSuite 400Washington, DC 20004Phone:202.280.6370
Register for complimentary webinars on hot industry topics about fraud detection and AML at www.verafin.com. I encourage you to take advantage of this free educational training!
Topic and Dates 2011
April 26: A new generation of money laundering
May 18: Check Fraud
May 25: Deposit Fraud
June 14: Debit Fraud
June 16: Card Fraud
There are also dates available for product demonstrations:
May 10, June 1, June 28
WASHINGTON — President Obama announced late Sunday that Osama bin Laden, the leader of Al Qaeda responsible for the Sept. 11 attacks, was killed in a firefight during an operation he ordered inside Pakistan, ending a 10 year manhunt for the world’s most wanted terrorist. American officials were in possession of his body, he said.
The fate of Ayman al-Zawahiri, the Al Qaeda number two in command, was unclear.
The death of Mr. Bin Laden is a huge punctuation in the American-led war on terrorism. What remains to be seen is whether the death of the leader of Al Qaeda galvanizes his followers by turning him into a martyr, or whether it serves as a turning of the page in the war in Afghanistan and gives further impetus to the Obama administration to bring American troops home.
One American official said that American forces, acting on intelligence, launched a “targeted assault” that killed Mr. Bin Laden, whose ability to elude capture for so long deeply frustrated the Bush administration.
The news of the death of the leader of Al Qaeda was bound to electrify the world, particularly as it comes a full decade after American forces, under President Bush, launched their all-out assault to find the man responsible for the Sept. 11 attacks.
Since those attacks, Mr. bin Laden was able to elude capture by hiding out in the mountains of Afghanistan and elsewhere. He initially escaped from Tora Bora in the mountains of eastern Afghanistan after an American invasion routed the Taliban, his protectors. Since then, he issued some 30 messages, in audio, video or electronic text. Intelligence officials believe they were passed from hand to hand repeatedly to obscure any trail back to his hiding place. Even while in hiding, he remained a potent symbolic figure. And American officials believe, based on intercepted communications from second- and third-tier Qaeda operatives, that he also still helped shape Al Qaeda’s strategy.
03/31/2011 Nonproliferation and Weapons of Mass Destruction Advisory
03/31/2011 Non-proliferation Designations
03/30/2011 Kingpin Act Designations Removals
03/24/2011 Anti-Terrorism Designations; Non-proliferation Designations
03/22/2011 Libyan Sanctions Identifications; Anti-Terrorism Designations
03/18/2011 Revocation of Non-proliferation General License No. 1 and announcement of the revocation of Non-proliferation General License No. 3
03/17/2011 Anti-Terrorism Designations Removals
03/15/2011 Libyan Sanctions Designations
03/11/2011 Update of the list of authorized Cuba Service Providers
03/11/2011 Libyan Sanctions Designations
03/09/2011 Publication of General License No. 3 - Authorizing Provision of Certain Legal Services
03/04/2011 Publication of Amended General License No. 1 - Authorizing Transactions
Related to Third-Country Libyan-Owned or Controlled Banks
03/01/2011 Publication of General License No. 2 - Libyan Diplomatic Missions in the United States
04/29/2011 Syria Executive Order; Syria Designations
04/28/2011 Kingpin Act Designations; Kingpin Act Designation Updates; Anti-narcotics Designation Removals; Sudan Designation Removals
04/26/2011 Libya Oil/Gas General License and Statement of Licensing Policy
04/26/2011 Release of OFAC Civil Penalties Information
04/21/2011 Update of Comprehensive Guidelines for License Applications to Engage in Travel-Related Transactions Involving Cuba
04/20/2011 Kingpin Act Designations
04/19/2011 Executive Order Prohibiting Certain Transactions With Respect To North Korea
04/19/2011 North Korea Designation
04/18/2011 Release of updated list of authorized providers of air, travel, and remittance forwarding services to Cuba
04/14/2011 Change to SDN data file format released
04/12/2011 Guidance on Sudanese Sanctions Regulations
04/08/2011 Libya Sanctions - General License No. 4
04/08/2011 Release of OFAC Civil Penalties Information
04/08/2011 Libyan Sanctions Designations
04/04/2011 Libyan Sanctions Designation Removal
OFAC Enforcement Actions (April 7 and April 26, 2011)
April 21, 2011
VIENNA, Va. – The Financial Crimes Enforcement Network (FinCEN) today announced the assessment of a $250,000 civil money penalty against The Lower Sioux Indian Community, doing business as Jackpot Junction Casino Hotel of Morton, Minnesota for violating Bank Secrecy Act (BSA) requirements for casinos. The Casino, without admitting or denying the allegations, consented to the payment of civil money penalties which were assessed for violations of the anti-money laundering program, reporting and recordkeeping requirements of the BSA.
“As with other recent penalty actions by FinCEN involving banks and money transmitters, today’s casino action highlights the importance for all types of financial institutions to institute and maintain BSA compliance programs commensurate with their operations and risk,” stated FinCEN Director James H. Freis, Jr.
From April 2006 through May 2009, the Casino failed to implement internal controls related to gathering and recording required information for BSA reporting. In addition, the Casino failed to conduct adequate independent testing and training for employees, among other BSA violations. The Casino also failed to develop and implement effective procedures for the preparation, review and filing of BSA reports, resulting in multiple failures to timely and accurately file Currency Transaction Report by Casino forms (CTRCs) and Suspicious Activity Report by Casino forms (SARCs).
Link to CMP
April 19, 2011: Former Chairman of Taylor, Bean & Whitaker Convicted for $2.9 Billion Fraud Scheme That Contributed to the Failure of Colonial Bank. After a 10-day trial, a federal jury in the Eastern District of Virginia found Farkas guilty of one count of conspiracy to commit bank, wire and securities fraud; six counts of bank fraud; four counts of wire fraud; and three counts of securities fraud. At sentencing, scheduled for July 1, 2011, Farkas faces a maximum prison term of 30 years for the conspiracy charge and for each count of bank fraud, 20 years for each count of wire fraud related to TARP, 30 years for each count of wire fraud affecting a financial institution and 25 years for each securities fraud count.
Department of Justice
WASHINGTON – The Justice Department announced today that Brian Lewis, Abel Mark Gonzalez and Andrew Kerber were sentenced for their roles in violating the civil rights of congregants of several houses of worship in Modesto, Calif.
Lewis and Gonzalez each received sentences of nine months incarceration and 36 months supervised release on the felony charge of conspiracy to violate civil rights. Lewis was also ordered to perform 200 hours of community service. Kerber was sentenced to 36 months probation, with a condition that he serves six months home detention with electronic monitoring at his expense, on the misdemeanor charge of damaging religious property. The defendants were also ordered to pay $3,700 in restitution.
Lewis, 23, of Modesto, Calif.; Gonzalez, 23, of Morgan Hill, Calif.; and Kerber, 23, of Chico, Calif., pleaded guilty in January to defacing and damaging the Congregation Beth Shalom synagogue on Feb. 2, 2006, by spray-painting anti-Semitic and neo-Nazi graffiti on its exterior walls. The men further admitted to spray-painting anti-Christian graffiti on the exterior walls of, and causing other damage to, Our Lady of Fatima Church and School and the Greek Orthodox Church of the Annunciation.
“Today’s sentences demonstrate that those who employ hate and intimidation to jeopardize the First Amendment rights of their fellow Americans to worship freely will be held accountable for their criminal conduct,” said Thomas E. Perez, Assistant Attorney General for the Civil Rights Division.
“Americans have the right to worship as they choose, free from intimidation and harassment. Today’s sentences make clear that we will enforce that right,” said U.S. Attorney Benjamin B. Wagner.
In announcing the sentence, Assistant Attorney General Perez and U.S. Attorney Wagner commended the FBI and the Modesto Police Department for their work in this investigation and prosecution. Assistant U.S. Attorney David Gappa and Civil Rights Division Trial Attorney Karen Ruckert Lopez prosecuted this case for the government.
Heather Nabers wrote:
This was responded to privately; however, if there are others in need of assistance regarding this topic, please let us kow and we can assist. Mary Meile
What does a money transfer scam look like? The FTC has several videos on the following listed below.
Click here for links: http://www.ftc.gov/multimedia/video/scam-watch/money-transfer.shtm
The Grandparent Scam
The Prize Promotion Scam
The Counterfeit Check Scam
The Mystery Shopper Scam
We have seen this in the past and it has been fraud. There is always a possibility that human error did occur; however, I would have more questions and recommend additional due diligence on the customer (additional forms of identification). Generally, the only information received on a SSN is that the number is valid and the date of issuance. The person it belongs to is as a rule is not provided. Also, I have more qestions as I am not certain of what your CIP procedures are, how stringent they are, who you are using for the third party service provider for the non-documentary verification, etc? If possible, I would consider pulling a credit bureau report on the customer, look for inconsistencies, alerts, etc.
It may be possible that a family member is using another family members SSN #. A brother or sister maybe or husband and wife. More to consider. All in all, this scenario does require more due diligence on your part! Good luck.
The Anti-Money Laundering Association is proud to announce a partnership with TAMLO International Inc. We are extremely excited about working with TAMLO as they bring a fresh new training perspective to the industry. TAMLO is a designer of highly engaging and fully interactive online training for anti-money laundering (AML) and counter-terrorist financing (CTF) compliance. They have an award-winning creative team that uses video, animation and real-life examples to teach employees about their roles and responsibilities. The course content is reviewed and tested by AML experts.
The courses are tailored for various regulated sectors and can be customized:
Training courses are available via the internet or they can be installed on your server and made available on your intranet. Also, their program can be integrated with most Learning Management Systems and HR management software.
I encourage you to visit their website at www.tamlo.com to learn more.
Director, Sales and Customer Service
Phone: 1-888-998-2650 Ext 104