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Monitor your Major Remitters Regularly
20 September 2010

A disturbing report: apparently, there is a major investigation in progress in Argentina, regarding false invoices generated by a money exchange company. Here's the unsettling part; notwithstanding this law enforcement activity has been reported in the media, American banks handling remittances of this company (reputed to exceed $40m) have failed to close the company's accounts in the United States. Is that compliance malpractice ? 

It is imperative that you regularly monitor the activities overseas of companies that transmit substantial funds into your bank, for if the American banks had only reviewed the Buenos Aires newspapers each day, they would have learned about the criminal investigation of a money transfer firm that continues to send them funds, which now appears to be suspected of illicit activity. Will their failure to promptly close those accounts be regarded by regulators as a compliance failure ? what do you think ?

Therefore, task your compliance department accordingly:
  • *Check the names of all your major foreign remitters, whether banks, NBFIs, or companies, weekly, accessing the principal business and general news media outlets in their respective countries.
  • Run the names in search engines, including their news features. There are regional search engines that you may find to be the best resources.
  • Always regularly World-Check them, as they could appear there, whether for reported misconduct, or if linked to high-risk individuals or companies. If they are subsequently profiled on World-Check, perform enhanced due diligence immediately, to determine whether it is advisable to terminate the relationship for risk management purposes.
Remember that you could sustain reputation damage, if it appears first in the foreign press, if your institution is linked to criminal activities of existing clients, and this news is then picked up by your local or national media.