If you are working in a financial instruction, you will have at least one policy manual addressing Customer Due Diligence (CDD) and Know Your Customer (KYC). These manuals have probably been assembled in a perfectly perfunctory manner, recognizing at the time, current laws and regulations. If you are a securities broker dealer a CDD and KYC manuals are required, and they must address specific topics, such as client credentials and AML law to thwart criminals and terrorists. In our role we have had the opportunity to read many, many manuals addressing CDD and KYC.
A favorite quote (instruction?) from one manual was “...and to supplement our policies on terrorism, any terrorist that walks through our office doors will be shot dead on the spot!” The NASD took a dim view of this policy -- but the B/D insisted it remain. To this day, it remains the strongest policy on terrorism we have ever seen.
Most DD procedures are the result of combined efforts to address the legal and regulatory issues in an effort to standardize the approach across a large organization. In theory, policies are meant to raise the standards of CDD and KYC to a “best practice” level.
So where are the policy bombs, and how are they fused and detonated?
As policies are created out of a need to address regulatory requirements and law, a manual only represents a snapshot in time -- the time it was created.
For example ...
The original author of a manual drafted in 2000 addressed the rules and threats of the day, and no doubt it was an exemplary manual. In 2002 regulations were substantially changed -- requiring more information to be gathered, shared, and retained. In 2004 the company using this manual merged with a new firm. In 2006 the office changed locations -- not far, but to a different county. In 2007 the parent company was bought out by a private equity firm, reincorporated in a new state, and had a substantial reduction in staff. In 2008 the office added insurance and estate planning professionals. In 2009 the office manager is confronted with a warrant, and law enforcement officers gathering records. It is suspected that one of their clients has been running a financial fraud, and has been laundering money though their accounts. The good news is that the firm has not been charged criminally -- but was fined by regulators. The bad news is that the victims of the fraud view the firm as the deep pocket that can make them whole -- since the firm was a part of the scheme. It's known as scheme liability.
The victims are not accusing the firm of being a malfeasor, but as a misfeasor. They will attempt to ascribe liability to the firm for failing to follow the policies and procedures in their manual.
Maybe the original author did a great job. Problems began when the manual was revised by Mary -- who left the project to Don when she left the firm. Don made his changes, and gave the project to Eric, who began to automate some of the processes. Angelina, CFE and CAMS certified, took over when Don was made redundant. Angelina took
the process in a new direction. Was that five or six versions of the manual (ago)?
In the end, what CDD/KYC procedures were used when the fraudster’s account was opened probably doesn't matter.
What matters is whether the financial organization deviated from the manual and its own policy. Deviance from policy is what opens the door for liability. This deviation may also allow an insurance company to deny coverage for attorneys’ fees and any awards given to the victims. The polices and procedures it approved and agreed to insure were not the ones followed by the firm.
The solution is simple (but boring).
Keep a pedigree of every version of the manual, including a record of the drafting efforts, dates, participants, and content. Appended this material to the current version, and date the version on every page. Review and revise manuals as needed in response to regulations, court rulings, changes in the business, changes in jurisdiction, changes in suppliers, or any other change that should affect policies. This must be done no less than annually. If you have a meeting, and the result of that meeting that there are no changes – document that meeting and add it to the record. Send copies of your most recent version to both regulators and your insurance company -- and invite comments. It's more difficult for regulators to issue fines and insurers to deny claims when they have been included in the process.
L Burke Files
Financial Examinations and Evaluations Inc. / The LUBRINCO Group Ltd.
Tuesday, October 12, 2010
Monday, October 4, 2010
Global Background Checks, Know the Facts
Do Global Background Checks Really Exist? And if so, are they sufficient to meet my Due Diligence Needs?
Global background checks offered by companies on the internet are frequently nothing more than a scam. There are a few firms that actually offer truly satisfactory international investigative services to qualify... and it is estimated that up to 90% or more of the companies or websites claiming to offer global background checks are fraudulent.
That's right; a majority of such companies don't even offer a true domestic investigations, let alone global investigations. Most websites claiming to offer background checks actually often just search databases for criminal records information. This is not a Due Diligence Investigation, nor does this even qualify as a true “background check”. It is however a superficial and reckless way of dealing with risk assessment and mitigation. True Due Diligence requires professional investigation. International Due Diligence requires professional field investigators in foreign countries… by an organization that has demonstrable ability to legitimately investigate at an international level.
Authentic Due Diligence involves prudent investigation conducted by professional investigators; it is a verification and investigation process which includes searching criminal records and many other factors, including financial due diligence and an understanding of those that associate with the target of your investigation. It's important to know that criminal records cannot be checked via a database for most international cases…. nor can financial information.
True Due Diligence is much more than just checking against criminal records and various government watch lists… Information concerning the financial, social and criminal background of a target, as well as those who are known to associate with the individual or organization in question are all required in order to get a more accurate and more complete picture to then based informed decisions upon. Foreign investigations require access to information in countries where you need to gather the information. This often can only be done with “feet on the street” to gather information first hand.
If you require a Due Diligence on an individual or organization with significant operations or history in one or more foreign countries, a true global or international investigation is required to gather the necessary evidence to understand and mitigate the risks associated with the contemplated counter party.
True professional background checks and private investigations don't exist for $39.95… any more than a great top notch paint job does for your home or automobile.
Real Due Diligence is based upon investigations which assess many factors, including education and employment history, criminal and civil records, ID and passport verification, document verification, informant testimony, travel records, financial dealings, real estate holdings, known associations, etc. There is no magical global database, not even for “Big Brother”. The fact is the majority of the world is still developing, and vast regions in Latin America, Africa and Asia are still filing records the old fashioned way. If there is no field investigator on the ground who speaks the local language, is familiar with local customs, and who has appropriate contacts with police, government and others who can provide appropriate sources of information, the job simply won't get done.
To conduct an international due diligence investigation or "global background check", an international private investigator, or a company with offices of investigators in several countries is required. You can't conduct a Panamanian background or Uzbekistani background check without investigators working in Panama or Uzbekistan to gather the necessary information… It’s that plain and simple. And, while your investigator does NOT need to have a local office exist in every city or every country, the investigator does have to have a network of reliable local contacts to facilitate the investigative process. Searching databases simply isn't a sufficient option for international cases.
Fraud and scams continue to be on the rise, so it's more important than ever to know who you're dealing with, and minimize your risk. The LUBRINCO Group can assist you in such endeavors…
Thursday, July 29, 2010
Asset Location and Due Diligence - A Horse story...
As professionals, clients rely heavily upon us to find them information that they themselves cannot locate, as well as to identify solutions to a host of different situations that are not pre-packaged, off-the-shelf answers. In this vein, they also rely upon us to perform some unusual tasks.
A client, an active purchaser of businesses, had employed us for our due diligence services, to determine what issues might be associated with the business that the client was buying. As part of this transaction, she had encountered a most unique problem.
It seems our client had sold a thoroghbred Arabian Horse to the daughter of a dear friend - on terms. The terms of the sale were that the purchaser was to pay $1,000 per month for the horse for one year and that would be that. The horse was worth much more than that, but our client had figured that the horse was going to a good home and that was more important than the money. Horse people are horse people and they know one another and what matters.
The terms were not being met, but she was assured the horse was in the best of care. Our client was frustrated but understood that it takes young people a bit more time to understand how they must meet their obligations. However, the “understanding” ended when our client heard a fantastic tale of the friend's daughter ride the horse through a bar in downtown Glendale, AZ - in quite a drunken state. The details of the evening really were quite ribald and only fit for a newsletter with better graphics capabilities so the story and pictures can be properly paired.
With the understanding gone – our client did not what the payments (per the original agreement) but, rather the return of the horse.
Our client called the police, who could not be of assistance since it was a civil matter. Further, our client’s attorney suggested filing a lawsuit. Walking away versus suing offered to end of a spectrum of effort and neither appealed to her.
At this point, our client had called us for advice. We suggested a “self-help” remedy available under the UCC code and under most state laws. We suggested that our client go find the horse and take it back.
She suggested we go find the horse with her POA and to call her when we had the horse in our possession. It was too much of a challenge not to at least try. Mind you, while you may think of the west especially Arizona as filled with horses - I assure you Central Park in New York has more horses that downtown Glendale, AZ.
Our search took three nights of drifting in and out of the bars where the horse had been seen and late on the third night, as our investigator was walking out the back door that led to a bike trail at the back of the bar – our girl with the horse was riding up. She tied up the horse and went into the bar. Our investigator promptly untied the horse and road off down the bicycle trail. Not wanting to be branded as a horse thief - we immediately called the police to report the horse “repossession”.
When the young woman at the police department stopped laughing, she then patched us through to the department that handles automobile repossessions. The young officer at the repossessions desk that night thought that our call was a joke - even after he hung up on us and we called back twice more. Our investigator gave his full name and the name of the firm, and finally the officer on the line began to take our reported horse repossession a bit more seriously.
The police department’s vehicle repossession database was set up for well, automobiles - with data fields to correspond to the year, make, model and VIN. The officer and our investigator talked it over and came up with an elegantly creative (if misleading) way to fill out the fields and get a repossession case number for the horse.
Year - DOB of horse was 2001 - so it was a 2001 model. Make - Arabian. Model - Thoroughbred. VIN - We provided the officer with the AZ Department of Agriculture's Hauling Card Number – and like magic, success - a repo case number was issued.
We then contacted our client and she (along with two police cars) met us to load the horse into the trailer - after a quick photo session with the officers, the horse and the investigator. The officers, quite rightly came to see off the horse to make sure this was a true tale.
The moral of this story is simple and straightforward. Systems are set up to handle routine, everyday occurrences - not the extraordinary. Sometimes life’s circumstances require creativity, patience and good humor to bend systems to allow them to compensate for the extraordinary. Our purpose is about solutions not excuses.
A client, an active purchaser of businesses, had employed us for our due diligence services, to determine what issues might be associated with the business that the client was buying. As part of this transaction, she had encountered a most unique problem.
It seems our client had sold a thoroghbred Arabian Horse to the daughter of a dear friend - on terms. The terms of the sale were that the purchaser was to pay $1,000 per month for the horse for one year and that would be that. The horse was worth much more than that, but our client had figured that the horse was going to a good home and that was more important than the money. Horse people are horse people and they know one another and what matters.
The terms were not being met, but she was assured the horse was in the best of care. Our client was frustrated but understood that it takes young people a bit more time to understand how they must meet their obligations. However, the “understanding” ended when our client heard a fantastic tale of the friend's daughter ride the horse through a bar in downtown Glendale, AZ - in quite a drunken state. The details of the evening really were quite ribald and only fit for a newsletter with better graphics capabilities so the story and pictures can be properly paired.
With the understanding gone – our client did not what the payments (per the original agreement) but, rather the return of the horse.
Our client called the police, who could not be of assistance since it was a civil matter. Further, our client’s attorney suggested filing a lawsuit. Walking away versus suing offered to end of a spectrum of effort and neither appealed to her.
At this point, our client had called us for advice. We suggested a “self-help” remedy available under the UCC code and under most state laws. We suggested that our client go find the horse and take it back.
She suggested we go find the horse with her POA and to call her when we had the horse in our possession. It was too much of a challenge not to at least try. Mind you, while you may think of the west especially Arizona as filled with horses - I assure you Central Park in New York has more horses that downtown Glendale, AZ.
Our search took three nights of drifting in and out of the bars where the horse had been seen and late on the third night, as our investigator was walking out the back door that led to a bike trail at the back of the bar – our girl with the horse was riding up. She tied up the horse and went into the bar. Our investigator promptly untied the horse and road off down the bicycle trail. Not wanting to be branded as a horse thief - we immediately called the police to report the horse “repossession”.
When the young woman at the police department stopped laughing, she then patched us through to the department that handles automobile repossessions. The young officer at the repossessions desk that night thought that our call was a joke - even after he hung up on us and we called back twice more. Our investigator gave his full name and the name of the firm, and finally the officer on the line began to take our reported horse repossession a bit more seriously.
The police department’s vehicle repossession database was set up for well, automobiles - with data fields to correspond to the year, make, model and VIN. The officer and our investigator talked it over and came up with an elegantly creative (if misleading) way to fill out the fields and get a repossession case number for the horse.
Year - DOB of horse was 2001 - so it was a 2001 model. Make - Arabian. Model - Thoroughbred. VIN - We provided the officer with the AZ Department of Agriculture's Hauling Card Number – and like magic, success - a repo case number was issued.
We then contacted our client and she (along with two police cars) met us to load the horse into the trailer - after a quick photo session with the officers, the horse and the investigator. The officers, quite rightly came to see off the horse to make sure this was a true tale.
The moral of this story is simple and straightforward. Systems are set up to handle routine, everyday occurrences - not the extraordinary. Sometimes life’s circumstances require creativity, patience and good humor to bend systems to allow them to compensate for the extraordinary. Our purpose is about solutions not excuses.
Wednesday, June 30, 2010
Survey: Banks Are More Frightening Than Criminals For Many
A recent survey indicates that consumers are five times more likely to switch banks because of hidden fees than security concerns, according to the survey conducted by the Gartner consulting firm. And one in six U.S. adult consumers—an estimated 28 million people—said unexpected fees make them more upset or aggravated than having their financial accounts taken over or used by a thief.
In the era of stiff competition and free checking accounts, penalty fees have become an increasingly important source of revenue for banks. About half of bank profits now come from fees—exceeding profits from credit cards, mortgages and all other interest income—according to the research firm R.K. Hammer. According to SNL Financial, banks collect annual fees in the range of approximately $30-32 billion, with the bulk of that amount coming from overdraft fees or what were once known as “bounced check fees". Many financial institutions charge fees ranging from $25 to $49 per incidence.
As consumers use debit cards linked to their checking accounts more frequently—and in more complicated ways -- combined with the challenges of a languishing and mediocre economy -- the chances of overdrawing their accounts have dramatically increased.
Consumers making purchases with debit cards or withdrawing money from an ATM can now easily push their accounts into the red. In fact, according to the Center for Responsible Lending, most “bounced check” charges now arise from debit purchases or other electronic transactions.
In the era of stiff competition and free checking accounts, penalty fees have become an increasingly important source of revenue for banks. About half of bank profits now come from fees—exceeding profits from credit cards, mortgages and all other interest income—according to the research firm R.K. Hammer. According to SNL Financial, banks collect annual fees in the range of approximately $30-32 billion, with the bulk of that amount coming from overdraft fees or what were once known as “bounced check fees". Many financial institutions charge fees ranging from $25 to $49 per incidence.
As consumers use debit cards linked to their checking accounts more frequently—and in more complicated ways -- combined with the challenges of a languishing and mediocre economy -- the chances of overdrawing their accounts have dramatically increased.
Consumers making purchases with debit cards or withdrawing money from an ATM can now easily push their accounts into the red. In fact, according to the Center for Responsible Lending, most “bounced check” charges now arise from debit purchases or other electronic transactions.
Wednesday, March 24, 2010
Real Stories from the Field — But I can get it cheaper…
One of the fascinating pieces of business is the cost of goods and services, with there often being several options at several prices. We face this issue frequently, because the work we do at LUBRINCO often seems similar to what others offer.
But is it in fact the same?
A good example of this involves independent testing and review of AML Compliance programs, which is mandated by law.
There are a lot of firms that do this, and many of them are extremely competent, and cost less than we do. In fact, however, we do not do independent testing and review of AML programs per se. Rather, we do independent testing and review of AML programs where there is a concern regarding possible regulatory action, and help when a regulatory action either has taken place, or when there are concerns that such an action might take place.
Should this make a difference in your thinking? Yes. If all you want is to be able to demonstrate a bare minimum of compliance, then we respectfully suggest that you should probably not hire us: You can get the job cheaper elsewhere.
On the other hand, if you want to make sure the regulators know your firm is actually doing the proper job within your AML compliance program, rather than merely giving the task lip service, we should be among your first choices.
And if you have actual concerns about a possible regulatory action, and avoiding them, and addressing them, then we should be at the top of your list.
In a recent case, a company solicited two bidders for independent AML program testing and review. One firm provided a bid for about $6,000 for the job. The other was an estimated $40,000.
The company accepted the higher bid. The evaluation produced a number of troubling areas, all but one of which was rectified. In reviewing the work product provided by the independent provider selected, the regulatory examiners found that the program review identified and remediated all of the issues identified except for the one minor issue that was then still outstanding at the time of their examination There was a minor action over the one outstanding issue, which was subsequently dealt with.
Was the investment of the extra $34,000 worthwhile?
Well, it saved the institution a huge amount of additional time, money, and grief. Based on this, we would conclude that it was definitely worth it.
To read the entire March 2010 edition of Aegis Journal, click here
But is it in fact the same?
A good example of this involves independent testing and review of AML Compliance programs, which is mandated by law.
There are a lot of firms that do this, and many of them are extremely competent, and cost less than we do. In fact, however, we do not do independent testing and review of AML programs per se. Rather, we do independent testing and review of AML programs where there is a concern regarding possible regulatory action, and help when a regulatory action either has taken place, or when there are concerns that such an action might take place.
Should this make a difference in your thinking? Yes. If all you want is to be able to demonstrate a bare minimum of compliance, then we respectfully suggest that you should probably not hire us: You can get the job cheaper elsewhere.
On the other hand, if you want to make sure the regulators know your firm is actually doing the proper job within your AML compliance program, rather than merely giving the task lip service, we should be among your first choices.
And if you have actual concerns about a possible regulatory action, and avoiding them, and addressing them, then we should be at the top of your list.
In a recent case, a company solicited two bidders for independent AML program testing and review. One firm provided a bid for about $6,000 for the job. The other was an estimated $40,000.
The company accepted the higher bid. The evaluation produced a number of troubling areas, all but one of which was rectified. In reviewing the work product provided by the independent provider selected, the regulatory examiners found that the program review identified and remediated all of the issues identified except for the one minor issue that was then still outstanding at the time of their examination There was a minor action over the one outstanding issue, which was subsequently dealt with.
Was the investment of the extra $34,000 worthwhile?
Well, it saved the institution a huge amount of additional time, money, and grief. Based on this, we would conclude that it was definitely worth it.
To read the entire March 2010 edition of Aegis Journal, click here
Daimler Agrees to Pay $185 Million to Settle Bribery Charges
By Amanda Harding, New York Times, on March 24, 2010, 4:17 pm
On Tuesday, German automobile-maker Daimler, agreed to pay approximately $185 million to settle bribery charges by the US Department of Justice (DOJ) and the Securities Exchange Commission (SEC). Two of Daimler’s subsidiaries, located in Russia and Germany, are also expected to plead guilty to bribing foreign officials, according to The New York Times.
The Times further reports that Daimler itself is expected to avoid indictment. On Tuesday, the DOJ released criminal complaints against Daimler and three subsidiaries that accused Daimler of bribing foreign officials in at least 22 countries between 1998 and 2008. The court documents reportedly allege that Daimler “made hundreds of improper payments worth tens of millions of dollars to foreign officials,” which helped it make at least $50 million in extra pretax profits.
A hearing is scheduled for April 1 in the U.S. District Court in Washington, D.C.
Read The New York Times article
FCPA Issues as well as other financial crimes, including money laundering are squarely in the glare of regulatory and judicial spotlights.
The LUBRINCO Group can help your firm assess and mitigate your exposure to these regulatory issues in these areas as well as perform international due diligence investigations, financial investigations and locate hidden or missing assets.
By Amanda Harding, New York Times, on March 24, 2010, 4:17 pm
On Tuesday, German automobile-maker Daimler, agreed to pay approximately $185 million to settle bribery charges by the US Department of Justice (DOJ) and the Securities Exchange Commission (SEC). Two of Daimler’s subsidiaries, located in Russia and Germany, are also expected to plead guilty to bribing foreign officials, according to The New York Times.The Times further reports that Daimler itself is expected to avoid indictment. On Tuesday, the DOJ released criminal complaints against Daimler and three subsidiaries that accused Daimler of bribing foreign officials in at least 22 countries between 1998 and 2008. The court documents reportedly allege that Daimler “made hundreds of improper payments worth tens of millions of dollars to foreign officials,” which helped it make at least $50 million in extra pretax profits.
A hearing is scheduled for April 1 in the U.S. District Court in Washington, D.C.
Read The New York Times article
FCPA Issues as well as other financial crimes, including money laundering are squarely in the glare of regulatory and judicial spotlights.
The LUBRINCO Group can help your firm assess and mitigate your exposure to these regulatory issues in these areas as well as perform international due diligence investigations, financial investigations and locate hidden or missing assets.
Thursday, March 11, 2010
Due diligence: dodgy documents fool many / BISCOM News / BIScom - World Money Laundering Report: Online
Due diligence: dodgy documents fool many
BIScom News
Friday 05 March 2010
The story of the fraudulent (or fake, depending on which representative of the UK Government is making a statement) passports used by (alleged) Mossad agents to enter Dubai just one aspect a wider documents problem.
It would be difficult, one would think, for a commercial airline pilot to work for 13 years with only a light aircraft licence - which was expired for much of that time. Yet that is exactly what an un-named Swede, living in Milan and flying for the past two years for a Turkish Airline is said to admit to having done.
Or how about Emma Charlton, the somewhat chunky woman who used to be known as Emma Golightly. Whether that was a fanciful view of herself as having a part in Breakfast At Tiffanies or irony, one cannot tell. Actually, Golightly was her real name: she changed it, by deed poll, to Charlton after she was released from jail in 2007. She had been serving a sentence for fraud.
Then Charlton started to weave a fabricated life: she started by telling people her father was a judge, that she was a manager at a chain store, that she had recently married a soldier - and that she was suffering from cancer which was terminal. Oh, and that she had been born in Africa, was adopted, that she was a photographer whose work was featured in Vogue magazine, that she was the editor of Vogue,
Of this only the bit about the chain store was true - well, sort of. She wasn't a manager, she lied about her past to get the job and she was sacked for not turning up to work.
She found men who she could dupe: the previous charges related to five who she took for a total of GBP250,000.
In the latest round, she stole cheques from her fiance - who had no idea what was going on, totally taken in by her tales - and the fact that she had a little dog like rich women do (apparently) and her grandmother, issuing them for as much as GBP10,000. She used stolen money and credit cards to buy jewellery and other items that she then sold to second-hand-goods chain CashConverters, apparently without question.
It's not expensive to create a false identity, obviously.
Obviously, that is, unless one is the British government. A man who, as a youth, murdered a child in the most horrible circumstances has been given a replacement identity and released into the community on parole with a number of conditions. Jon Venables was abolished, to all intents and purposes, in 2001 and a new, bulletproof identity created in its place. But this week, due to infractions of his parole, he's been recalled to jail. It is said that there is little chance that his new identity will remain intact. That means that he will need another new identity - at a cost that some estimate of GBP250,000.
That can't be right: criminals everywhere can get false identities that work for a couple of thousand pounds. Surely there's someone that can put Venables in touch with the kind of people who make this happen?
-------------------------------------------------------------------------------------
The above blog article is a terrific representation of how not knowing enough about the parties with whom you engage in business activities can place you or your organization at risk.
The LUBRINCO Group can assist firms in performing Due Diligence Investigations (Domestically in USA or Internationally) to help firms avoid the risks associated with not adequately knowing your customers, your employees or vendors or not adequately knowing counterparites with whom you are involved.
BIScom News
Friday 05 March 2010
The story of the fraudulent (or fake, depending on which representative of the UK Government is making a statement) passports used by (alleged) Mossad agents to enter Dubai just one aspect a wider documents problem.
It would be difficult, one would think, for a commercial airline pilot to work for 13 years with only a light aircraft licence - which was expired for much of that time. Yet that is exactly what an un-named Swede, living in Milan and flying for the past two years for a Turkish Airline is said to admit to having done.
Or how about Emma Charlton, the somewhat chunky woman who used to be known as Emma Golightly. Whether that was a fanciful view of herself as having a part in Breakfast At Tiffanies or irony, one cannot tell. Actually, Golightly was her real name: she changed it, by deed poll, to Charlton after she was released from jail in 2007. She had been serving a sentence for fraud.
Then Charlton started to weave a fabricated life: she started by telling people her father was a judge, that she was a manager at a chain store, that she had recently married a soldier - and that she was suffering from cancer which was terminal. Oh, and that she had been born in Africa, was adopted, that she was a photographer whose work was featured in Vogue magazine, that she was the editor of Vogue,
Of this only the bit about the chain store was true - well, sort of. She wasn't a manager, she lied about her past to get the job and she was sacked for not turning up to work.
She found men who she could dupe: the previous charges related to five who she took for a total of GBP250,000.
In the latest round, she stole cheques from her fiance - who had no idea what was going on, totally taken in by her tales - and the fact that she had a little dog like rich women do (apparently) and her grandmother, issuing them for as much as GBP10,000. She used stolen money and credit cards to buy jewellery and other items that she then sold to second-hand-goods chain CashConverters, apparently without question.
It's not expensive to create a false identity, obviously.
Obviously, that is, unless one is the British government. A man who, as a youth, murdered a child in the most horrible circumstances has been given a replacement identity and released into the community on parole with a number of conditions. Jon Venables was abolished, to all intents and purposes, in 2001 and a new, bulletproof identity created in its place. But this week, due to infractions of his parole, he's been recalled to jail. It is said that there is little chance that his new identity will remain intact. That means that he will need another new identity - at a cost that some estimate of GBP250,000.
That can't be right: criminals everywhere can get false identities that work for a couple of thousand pounds. Surely there's someone that can put Venables in touch with the kind of people who make this happen?
-------------------------------------------------------------------------------------
The above blog article is a terrific representation of how not knowing enough about the parties with whom you engage in business activities can place you or your organization at risk.
The LUBRINCO Group can assist firms in performing Due Diligence Investigations (Domestically in USA or Internationally) to help firms avoid the risks associated with not adequately knowing your customers, your employees or vendors or not adequately knowing counterparites with whom you are involved.
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