Bank in Andorra helped money launderers

https://www.bpa.ad/
Banca Privada D’Andorra Logo

Do you know where Andorra is?

Probably not. It is the Switzerland of the Pyrénées.

It shares many traits as Switzerland. It is a tourist economy. It has a successful ski resort industry. It is a tax haven. And it has bank secrecy laws that make it a attractive for the wealthy to hide their wealth.

Anywhere bank secrecy laws make it easy to hide wealth is a place that attracts those who acquire wealth through illicit business. Andorra is no exception.

The Chief Executive Officer of the Banca Privada d’Andorra is facing money laundering charges. He is accused of helping clients from China, Russia and Venezuela and possibly others after a more comprehensive investigation commences. The arrest is a reaction to the bank being placed on US Treasury list of “primary money-laundering concern.” Entities and persons on this list are often barred from the US financial system, which, in return, cascades to reciprocal severances from other financial systems.


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.


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Kleptocracy is a system setup to benefit a select group of people over a whole population

Kleptocracy is a system that benefits a few over the population as a whole. It is a term usually used for governments but it can be used for corporations.

from Hunger Games
from Hunger Games

Russia would be a well known kleptocracy. Russian people pay taxes and the tax revenue is used on projects that hire corporations whose executives are supporters of Vladimir Putin. Not only are Putin’s supporters winning contracts over non-supporters even when qualifications and price would support the non-supporters over a supporter, but also the executives are spending the funds in such a way so that it benefits them directly. These executives are using these funds to build themselves houses and buy expensive things. recently, a few government ministers have been found to own recently built expensive mansions, which does not make sure considering their background of having no money and their positions not affording them such funds. This is another direct kleptocratic method.

It is a little more difficult to use it for corporations. The use of corporate funds for direct personal gain would be fraud and embezzlement, but if it is systemic, it would be kleptocracy.


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.


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Obama to Create New Central Cybersecurity Agency

The private sector plays a more central role in spotting and responding to cyber incidents than they do in the counterterrorism realm, where the government largely takes the lead. – Lisa O. Monaco, President’s Homeland Security and Counterterrorism Advisor

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Seal of the Office of the Director of National Intelligence

Lisa Monaco announced the launch of Cyber Threat Intelligence Integration Center (CTIIC), which will provide analysis to policymakers and intelligence operatives using private sector data.

CTIIC will report to the Director of National Intelligence.

This was also written about in a previous post.

 

 

 


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.


Adam Szubin’s Key Note

On Monday, January 26, Associations of Certified Anti-Money Laundering Specialists (hereon ACAMS) held its Third Annual AML Risk Management Conference at The Conrad Hotel in downtown New York. Over the course of this week, summaries and takeaways from the key notes and panel discussions will be shared in this blog.

Adam Szubin is the exiting director of Office of Foreign Assets Control (OFAC) in the Department of Treasury. Soon, he will be the acting under secretary for Terrorism and Financial Intelligence, another office in the Treasury.

HeaderSzubin has a history of speaking at Financial Crimes-related conferences because of his long held position as the director of OFAC. Applauded members of ACAMS for doing their best to make Anti-Money Laundering profession a serious endeavor. Then he alerted to three nuanced risks for the profession.

CUBA was his first concern. As the United States lifts nearly all of its sanctions against the communist island nation this year, it opens up another route for corruption to take place.

RUSSIA was his second concern. OFAC’s Magnitsky Sanctions List enumerates targets explicitly, but not all activities are sanctioned and not all enumerated have been sanctioned the in the same manner. The theme of this sanction is debt and equity financing, or the limit thereof. This is a target on a crucial source of currency for Russia in order for it to succeed. The capital markets have also worked against Russia by lowering the price of oil, the primary source of revenue for Russia. It’s an additional wind behind OFAC’s sanctions.

IRAN was his final enumerated concerns. Even more nuanced than the previous two examples. Iran’s domestic politics indicate the type and length to which the regime is willing to evade western powers to fund terror.

Transparency is the key to successful sanctions compliance. Breach of compliance is often accidental. Finding breaches are difficult because often the breaches are in omnibus accounts. Also global trade cannot stop for complex business areas, like re-insurance of trans-ocean ships.

Because of the human nature of business, financial crimes will occur in some form or another. Professionals Certified Anti-Money Laundering Specialists greatly reduce the efficacy of criminal activities.


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.
He tweets @MoneyCompliance