Habib Soussou, Alfred Yekatom and Oumar Younous, as shown on the Recent Actions page of the Treasury Department.
Sanctioning individuals is relatively recent phenomenon. Up until several years ago, only nation-states received sanctions. And then individuals and specific business concerns started to be sanctioned. While the use of sanctions in this manner seemed tenuous at first, the success of sanctions against Russian President Vladimir Putin’s cronies solidified the practice and they are here to stay.
Who do you think should be taken off of the sanctions list? Why?
Marcus Maltempo is a compliance professional with more than a decade of experience helping banks, law firms and clients manage investigations and regulatory responses. He is a member of ACAMS and ACFE.
Hawaladar is a person who provides money services (hawala) to criminals. He is part of the criminal part of the shadow banking system. Shadow banking system is the banking services offered by non-banks. For example, a hedge fund could provide a loan to a company, which would be a shadow banking activity. Halawadar does something similar.
A Hawaladar is a person who moves money from one place to another using his network of contacts he’s developed usually from traditional import-export activity. So, for example, if a criminal in London wanted to payoff another criminal in New York in the amount of $10,000, the criminal could go to a Hawaladar in London, give the Hawaladar $10,000. The Hawaladar would call up an associate in New York and ask him to pay the criminal in New York $10,000. The Hawaladar in London would settle up with the associate in New York at a later time. The settlement usually is underpricing or overpricing of the goods being traded. The Hawaladar and the associate have both charged money for the service, of course, which the criminal in London is usually responsible for. And, in order for all of this to work, the associate in New York must trust the Hawaladar in London to settle up.
Nowadays, are Hawaladars really doing any trading? They are just a money service business.
The Hawaladar has been facing more competition over the past decade. Now, the London criminal could buy a prepaid debit card with cash at any store and then send that to the criminal. It does not require any intermediaries. The cost of buying a prepaid debit card is next to nothing. I think I could go to the corner store on my block and get one for about $5 and load thousands of dollars on it.
There are also other ways as well. People who do not have international trade businesses can get in on the Hawaladar game. I could pay off someone on behalf of a criminal using my PayPal account. I could use my Google Wallet. I could use my ApplePay. I could use Square, the payment service. I could use Venmo. I could use any store with a credit machine merchant account and pay them on my credit card and the store could pay off the criminal. It will just look like I paid for a product or service. I could even use Bitcoin.
The increasingly greater number of easy payment/transfer options are making it possible for criminal activity to be paid without the use of a Hawaladar.
What do you think was the weapon that was used to kill churchgoers in Charleston, South Carolina, confederate flag or gun?
About the Author: M. C. Maltempo is a compliance professional with more than a decade of experience helping banks, law firms and clients manage investigations and regulatory responses.
Corruption in the People’s Republic of China is nothing new to Western media consumers. The usual story is some corrupt politician in one of the ministries or provincial government who has been giving favorable contracts to friends and family for kickbacks. But in the past couple of years, a rise in a new type of corruption has been coming to light: corporate corruption.
Major Chinese corporations are generally state-owned and state-controlled. This makes these corporations arms of the government, even though they are participating in the private sector like other private sector firms. So, when corporate corruption takes place, the Chinese government is on the hook for them.
Chinese state-owned enterprises, especially China Construction Corporation (CCC), have been bidding for construction contracts in South Asian, Middle East and Africa against, primarily, South Korea. With the financial backing of the Chinese government, these firms have been winning the contracts for building infrastructure in Africa and private real estate projects elsewhere. Though these firms are working outside of China, their practices haven’t changed. Client-governments have been receiving bills that are twice as expensive as comparable projects, environmental studies and other feasibility studies have not been performed, and local officials have been getting offers to look the other way on these activities.
In a bold move, the Chinese government has primarily taken to defending CCC, asking client-governments to respect the contracts and pay up. Local governments find it hard to swallow such counter-accusations when China won’t produce evidence of work being done properly or at all. The Chinese government has a difficult time with diplomacy under such circumstances because they are considered intimately involved in these firms.
Corruption for Chinese firms like CCC puts Chinese government in a bind because it has been trying to crackdown on corruption in the government and cleanup its image. In the technology sector, firms like Xiomi has been able to prove to the world very quickly that it can compete fairly by producing better phones. If other sectors in China are to attempt to work across its borders, it’ll have to learn to compete with rules it can’t break.
About the Author: Marcus Maltempo is a compliance professional with more than a decade of experience helping banks, law firms and clients manage investigations and regulatory responses.