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

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.