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
Wednesday, March 24, 2010
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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