On demand 1h 6m 45s Intermediate

Anti-Money Laundering Basics for Attorneys

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Anti-Money Laundering Basics for Attorneys

In this program, attorneys will learn how to prevent their firm from being used as a tool for money laundering and how to recognize the risks associated with specific types of transactions. We will take a deep dive into what constitutes money laundering, how to best protect attorney trust accounts, and how lawyers can be guided by the American Bar Association’s (ABA) Good Practices for Lawyers to Detect and Combat Money Laundering.

Transcript

Good afternoon, everybody. Thank you so much for attending this CLE regarding anti-money laundering basics for attorneys. My name is Timothy Dunfey. There's my contact information on this slide. I'm a financial crimes compliance attorney for financial institutions, primarily. And one of the reasons I put together this CLE was to, you know, give attorneys the knowledge of how to understand the risks associated with financial crime so that you don't unwittingly become a vehicle for financial crime to take place through. As I say, if anyone goes to jail, make sure it's the client. Right? So. So here is our syllabus for today. We're going to start with some introduction, the perspective of lawyers as gatekeepers. Some more definitions. We'll go through who has financial crimes, compliance reporting requirements. We'll get into that. The Bank Secrecy Act, the USA Patriot Act. How you can take the basics from the Patriot Act and apply that to what you do. Then we're going to go into understanding risk, geographic risk, and then go to the guidance to detect and combat money laundering and terror finance. So the ABA does have guidance on this, and they've highlighted some areas of law, some practices of law that can be susceptible to financial crime and how to be aware of that and just letting you know that that risk is there. But what this presentation does is go into more detail, helping you detect that potential financial crime risk. So with that, we we really we're focusing on protecting your trust account. Trust accounts are still the number one reason why attorneys are disbarred. And you know, your trust account from for a money launderer is an opportunity, right? So when that money comes out of your trust account, there can be a legitimate explanation for it. It's a lot easier. And and so for that reason, because you have this trust account that can be used by money launderers and because lawyers have knowledge of the law and lawyers who are acting unscrupulous scrupulously can help their clients launder money and disguise the true origin of the funds or the origin or or the true ownership of the company or the beneficiaries of the trust. Right. Because lawyers are in this position, lawyers are higher risk from a banking perspective. And so you may have been asked for additional information for your law firm when you had to open your law firm account. So your law firm account is reviewed more closely. Same thing is true for accountants, right? They have this additional knowledge. They can help their clients disguise funds. Et cetera. And so money laundering does take place through trust accounts. Lawyers do act unscrupulous early. And so because of that, they're seen as higher risk. And it's not just, you know, an industry thing. Fatf which is the Financial Action Task Force. Fatf is an international organization of where different countries participate through the their financial intelligence unit. Here in the United States, our financial intelligence unit is called FinCEN. So FinCEN is the US representative to fATF. Fatf is the Financial Action Task Force, and they set the global standard for financial crimes compliance for any money laundering and terror finance standards. And fATF calls on countries to consider various means to address money laundering through the efforts of professional gatekeepers of the international financial system, including lawyers, accountants, company formation, agents and others. And so fATF, in most countries, most you know, in Europe in particular, lawyers have a duty, a responsibility to report financial crime when they suspect it or are aware of it. And so lawyers have a reporting responsibility here in the United States. Attorneys do not have this reporting responsibility. In the end of last year, when the budget was being passed, the defense budget, there was a bill inside of the defense budget called the Enablers Act. And the Enablers Act would have required attorneys to file suspicious activity reports, in fact, a narrow subset of attorneys. But that did not pass. So the ABA has pushed back against lawyers having the responsibility to report. But what they have done is they've put out guidance. You know, they recognise that lawyers do have this gatekeepers role and, and so, so we'll go through that guidance that they've given. But I just want to point out that the US is a bit of an outlier when it comes to the requirement for attorneys to report. One day attorneys may have that responsibility to report bringing the US in line with other developed countries. And and so don't be surprised if that happens. But and if you work with a large international law firm, you may already have that some of these due diligence requirements that we'll go through, you may already have training that you have to go through and you know, you'll you may just because, you know, these that law firm being an international law firm would have to comply. So what is money laundering? This definition is taken from the ABA, the voluntary good practices for lawyers to detect and combat money laundering. So money laundering is the criminal practice of filtering ill gotten gains or dirty money through a series of transactions. In this way, the funds are cleaned so that they appear to be the proceeds of a of legal activity. So. There's the different statutes there. But what I want to go through on this slide is that money laundering is a process. You know, there's three steps in the process. There's placement. The next phase is layering and then integration. So you go through a simple example. We'll go through the pizza shop example. So, you know, someone sells drugs on the street. You know, they can one way of placing it would take that those funds from the drug sales, the cash that, you know, $50 a piece at ten times that $500, they could take it down to the local bank and they could deposit it either through the teller window or through the ATM. But that really doesn't make a lot of sense. That's not the best way to launder money. Another thing that that person could do is they could take that $500 and walk down to the convenience store and buy a $500 money order. So buying that $500 money order would, you know, make it a lot easier rather than a stack of cash they're walking around with. They've now got one piece of paper. Let's say that they sell that $500 worth of drugs every day for ten days. Now they've got $5,000 in money orders, right? Ten, $500 money orders. They can put those inside of a envelope and put it through the night deposit drop or deposit it through the ATM. That way a lot easier, right? You can put a lot it's a lot easier to put $5,000 into an envelope, $5,000 in money orders into an envelope. But those both of those are examples of placement that's putting the funds into the financial institution. So or converting that cash, converting those into financial instruments. Money orders would be negotiable instruments. If you remember your negotiable instruments, class money orders would be those negotiable instruments. So you would have converted it. You would have placed it into the financial system, Right. So the money's now been placed, The funds from the activity or funds intended to support illegal activity are first introduced into the financial system. Next is the layering. So this is where it gets complicated. Layering is where the money moves around. So further disguising and distancing the illicit funds from their illegal source through the use of a series of frequently complex financial transactions. It may occur through creating a tiered entities complicated entity structures designed to conceal the source of illicit funds. So this could be from, you know, back to the pizza shop example. Let's say you take that money from the drug sales and you bring it into the pizza shop and you're mixing it in with the funds used to buy pizza. Right. So now you take your pizza shop deposit, you go into the bank, you place it in the bank as part of your deposit for the pizza shop. You mingled it with that. That's your placement. So it goes into a pizza shop operating account. Once in the operating account at Bank A, they move it over. They send that check over. Once it's cleared, it's deposited. Money is in there. They then transfer that money over to Bank B across the street and they transfer it into the ABC real estate account that owns the real estate for ABC Pizza. So now that is, you know, they could then transfer it to a different account. So that would be an example of layering. You can transfer within the same bank. You can transfer to different banks. Once again, as it refers to here, this is where you can have complex structures that come into place where, you know, various, you know, layers of ownership are used to disguise who owns or where the funds originate from. And so that's layering the moving around, further distancing those illicit funds from from the source. Right. And then next is integration. So that's getting the funds out of the financial institution, the status of Expendability in the hands of organized crime groups that generate them. So this is now returning the funds into the legitimate stream of commerce, buying the car, buying the Ferrari, buying the house, buying the real estate, Right. So integrating. So you've now you've gone out and purchased something. So it is a process placement, layering and integration integration is returning that money to the legitimate stream of commerce and and buying. Right. Whatever's out there because the purpose is always to get the money out, whether it's cash or whether it's Bitcoin or whatever it is. Having that money in the bank doesn't really do them any good. The purpose is to buy the Ferrari. The purpose is to buy the house. They've got to get the money out of the financial system for it to do them any good. So that are the three layers or the three steps in the money laundering process, placement, layering and integration. Uh, next, let's move on to money laundering through trust accounts. So law firms, especially small law firms, may be ill informed of how clients may take advantage of their trust accounts. One of the easiest and most common examples today is the one MDB case. This is the case of J Law. You may have seen it in the news with regard to a rapper who used to be in the Fugees and and some Hollywood stars. Paris Hilton. Et Cetera. Were all involved with this son in law of the prime Minister, step son, step son of the Prime Minister who stole $4.5 billion from the sovereign development Fund. A good portion of that money, 368 million, was transferred through law firm A here in the United States, and the second was held held a second law firm held $218 million. So law firm trust accounts do become ways in which funds are laundered. And, you know, as I said, you know, once that money passes out of your account, there's an air of legitimacy to it. So this can happen in a number of different ways. And these are things like politically exposed persons, you know, asking questions, why would you do business with us? Right? Why asking some questions about the underlying transaction and understanding what the risks are is a is, you know, something that you need to do in order to protect your trust account from being used. So be aware. So, you know, a lot of this goes back to the Bank Secrecy Act. So the Bank Secrecy Act of 1970. It put in place. It is really a record keeping and reporting requirement for financial institutions, and it requires banks to file the following reports. First is what's known as the currency transaction report, the CCR. So that is for transactions over $10,000. So going back to our pizza shop example, you know, if the pizza shop comes in at noon and deposits $9,800 and then comes back in the afternoon and deposits another $9,800, that would require write a ktrw because they're over the $10,000 reporting requirement, cash deposits within one day. Right. That's got to be cash. And so when people structure their cash transactions to avoid this reporting requirement, it is called structuring. Structuring is a crime. And so purposely avoiding structuring your transactions to evade or avoid this reporting requirement is a is a crime. And so that's something that banks are aware of and they monitor for. Next there is the negotiable instrument log reporting. So this gets back to those negotiable instruments that we spoke of cashier's checks, money orders and traveler's checks. More than $3,000. So whenever anyone purchases those cashier's checks, money orders or traveler's checks over that amount, they have to provide identification. The bank has to keep a log of that and they have to maintain that log for five years. Next inside of the BSA reporting requirements is the suspicious activity reporting. Now, this is the one that gets the most attention. There's a huge amount of, you know, process behind this. So suspicious activity reports are typically filed by they're filed by financial institutions. A financial institution has been defined broadly to be expanded to those involved in car sales and real estate transactions. They have reporting requirements. So if you bring over $10,000 to a real estate closing, you're going to have to meet. You're going to have to file a. Or a similar version. So. So the suspicious activity reports, those get filed with FinCEN. I mentioned FinCEN earlier as the financial intelligence unit for the US. It is also the government entity which monitors and collects statistics from suspicious activity reports and is the repository for suspicious activity reports that allows law enforcement to search the database for transactions that have been taken place and suspicious transactions. So if your law firm is doing suspicious transactions, you could be end up being you know, they can file, they will file a SAR on you. So be aware that, you know, this is something you're, you know, being, you know, transactions are being reviewed by your financial institution. So and then another reporting requirement is the FBR foreign bank account reporting. This is a two part reporting requirement. So individuals who have foreign bank accounts are required to report their account as part of their tax return. So that's an individual reporting requirement. But as we're referring to it here inside of the Bank Secrecy Act, banks that have foreign bank accounts. So if a bank has an account offshore, they are required or if they are owned by a foreign bank, for example, they are required to file an FA. So the Bank Secrecy Act is really a record keeping and reporting requirement for financial institutions, but they have been the definition of financial institution has been expanded. As I said, attorneys here in the United States do not have to file suspicious activity reports. But in other countries they do. So the nice thing for our financial institutions is that filing a suspicious activity report provides the bank, its directors and employees from civil liability should some damage arise out of the filing of that suspicious activity report. So if the bank were to file on you or if you were, you know, then you would not be able to sue them for that. They have that safe harbor. Next, let's go through some more laws related to financial to money laundering. So we had the Bank Secrecy Act of 1970. Now we have the war on drugs throughout the 80s and 90s. First we had the Money Laundering Control Act of 1986 that established money laundering as a federal crime created structuring, as I mentioned earlier, to be a crime directed banks to have policies and procedures to monitor compliance. Then into 1988, the Anti-Drug Abuse Act. This expanded the definition of financial institution to car dealers and those involved in real estate closings. And went into the negotiable instruments and where that came from, the requirement to identify their came out of the Anti-Drug Abuse Act of 1988 1994, we had the Money Laundering Suppression Act. The interesting tidbit from that act is that it recommended states to adopt uniform rules for operating money. Service businesses made operating an unlicensed money service business a federal crime, and required money service businesses to register and maintain a list of authorized agents. So money service businesses, unlike financial, unlike banks, are regulated on a state by state basis. But states have been required to adopt uniform rules for their operation. So Money service businesses have a requirement to have a financial crimes compliance program. It made operating an unlicensed money service business a federal crime. So if you're familiar with the digital asset cryptocurrency world at all, this is how a number of folks have been charged, Arrested on who? Individuals who were laundering money for, people using cryptocurrency, accepting cash and then turning it around and giving them Bitcoin or some other cryptocurrency. They were doing this and they were operating as an unlicensed money service business, and that was the initial crime that they were charged with. So that's where the state standards for money service businesses come from. And then in 1998, we had the money Laundering and Financial Crimes Strategies Act. And the important, you know, points here is that the Treasury developed a national money laundering strategy, which they still do to today. They come out with that annually and it's created and hit zip codes, which is a federal program which provides enforce funding to law enforcement where there is high intensity financial crime areas or high intensity drug trafficking areas. So these would be major cities like Miami, New York, Los Angeles, etcetera. And then because federal funds are associated with this, some smaller communities may be considered and hit zip codes as well. But there is a list out there and, you know, well known. All right. So so those are the that's the development of laws, rules and regulations related to money laundering since the Bank Secrecy Act that brought us so so under that, you know, as we've mentioned earlier, is that financial institutions must have an AML program. So what we have here over on the left is those who are financial institutions that must have an AML program. And so over on this side, you have banks, broker dealers, money, service businesses. Et cetera. Over here, they must have the five pillars, five ways of controlling and preparing for financial for around financial crime. So they have to have a policies and procedures in place. They have to have a designated compliance officer. They have to be audited, and they have to have controls in place, specific controls. So those these guys over here on the left have both a record keeping and reporting requirement as well as a requirement for a program. But over here on the right, this is where we start getting into what really relates to you as an attorney. These guys over here have reporting requirements, as we mentioned, pawnbrokers, dealers and precious metals dealers and cars, boats and planes and those involved in real estate closings. So if you as an attorney are working with any of these folks over here on the right, you need to understand that they have they are exposed to financial crime. They've been used for financial crime and money laundering so much that they've been given a reporting requirement. And if you are working with them as clients, then they're bringing kind of risk to you, right? If they're not doing their job, if they're, you know, involved in this, then they're bringing that risk over to you. Will specifically, we'll go into those involved in real estate closings because there is now a geographic targeting order that will go through in a number of different geographies that look specifically at the use of real estate for financial crime. This is true in all economies. If you know the those purchasing real estate from ill gotten gains generally do it with cash. And so because of that, they don't care if interest rates are high and they don't really care whether they're getting a good deal on the real estate or not, they're just looking for a place to put the money. And so real estate brokers love them. And and they you know, they're they're not hesitant to buy when others are holding on to their funds or not taking out additional loans. So that was the Bank Secrecy Act. Those who have reporting requirements under the Bank Secrecy Act. We've now moved on to the year 2000 2001. Most particularly, this occurred after the financial the terror attacks of nine over 11. It was already written before that, but it really was pushed through. After that, it criminalized the financing of terrorism and increased civil and monetary penalties. It required banks to consider the agencies to consider banks records when they were going through mergers. There have been a number of large mergers that have been held up, or because potentially because in some cases, clearly because of financial crime, compliance department at a given bank was not where it should be prohibited. Shell companies, shell banks and required due diligence procedures for foreign correspondent banks and private bank accounts. So this is where due diligence requirements first originated and they were limited to correspondent banking accounts and private banking accounts. So created the programs 314 A and 314 B are information sharing programs. So 314 A is where law enforcement can send an alert out to financial institutions around the country saying, hey, do you have this person's account? Financial institutions are required to respond within ten days if they have a match. And so that's information. That's required information sharing with law enforcement. All financial institutions have to participate in the 314 program. 314 B is voluntary information sharing between financial institutions. So if Bank A says, hey, you know, we don't feel comfortable about what's going on with ABC's ABC Pizzas account, they keep bringing in $9,800 every day. There's no fluctuation in their business cycle. And we went by there and we didn't see anybody coming in on Wednesday. How did they how did they deposit 10,000 or $8000 or whatever in cash on a Wednesday when we didn't see anybody go in there? Right. We don't there's just no fluctuation in ABC Pizza's business cycle and their money smelled like drugs the last time. We don't trust the guy who brings the money in. Let's go ahead and but we're not sure but they do a lot awful lot of transactions with Bank B across the street. If Bank B participates in 314 B, then Bank A can send them a secured message saying, you know, we you know, how do you you know, do you see any suspicious activity in ABC? Pizza's a real estate account because we see a lot of money going over there, a lot more than is required to than than that shop that they own is is worth. Right. So anyway, so that's voluntary information sharing between financial institutions, special measures. This is literally an act of Congress. They don't happen that often, but when they do, financial institutions have to respond within 120 hours. The easiest example here for that is a bank known as Delta Asia Bank Limited. They were a bank that was owned and run by the son in law of a dictator. The they used Delta Asia Bank Limited and its correspondent banking account to move 400 or so million dollars out of that country and through US banks. And so they put a stop to that and they designated them an entity of primary money laundering concern. And then under 31 CFR 1020, we have the what are the five pillars of AML. So we will go through these and large law firms or perhaps your law firm, if you were dealing with customers that are, you know, exposing you to financial crime, potential money laundering, you may wish to put these pillars in place. As I mentioned, large international law firms already have systems that basically mimic these five pillars. So the five pillars are a system of internal controls. These are things like policies, procedures, transaction monitoring programs, scanning names against government lists, independent testing that's also known as audit, then a designated BSA officer that persons designated by the board, some large law firms have their own BSA officer. They then training programs. Many law firms have training programs similar to this and risk based procedures for conducting ongoing due diligence. So this final one was not one of the original. It was originally four pillars. The fifth pillar was added in 2016, and we'll go through some of this risk based due diligence for you to help you perhaps put a process in place that will help your firm limit its risk and exposure to financial crimes and anti money laundering issues. So the five pillars of AML and we'll go into them a bit more. Now, that's not the you know, nine 2001 was more than 20 years ago. Now the Anti-Money Laundering Act is the latest of the laws, rules and regulations related to money laundering. And within that, the real reason that we bring this up here, right, it's intended to improve information sharing among agencies and allows FinCEN, right? It elevated financial crime to an issue of national security, which allows FinCEN to share financial crimes or SAR information. Right. That they may be collecting with other foreign governments around the world. So that so escalated financial crime to a national security risk, focus around modernizing and innovating. And then but what we really want to focus on here is it established uniform beneficial ownership reporting requirements. So and a secure nonpublic database. Now, this is this is also managed by FinCEN. And what this does is it requires and will be coming online within the. 12 months. It actually comes online. It's supposed to in January. Let's see if that happens. So all new entities formed in after January 2024 will need to sign on to a FinCEN database known as the Boss, the beneficial ownership sharing service boss, and they will need to register their beneficial ownership there with FinCEN. So this is a non-public database. You'll not be able to go in and look up who information on that. Financial institutions will not be able to search it. It's only open to law enforcement. The purpose here is to to really to bring the US in line with international standards. So this does not write this database. Fincen database of beneficial ownership does not replace the state by state registrations of, you know, corporate registries. So here in Florida, we have we have sun biz. You have to go on Sundays and register on Sundays. But what you don't do on Sundays is list who your beneficial owners are. So there is no way here in the US to understand whether people are truly providing the or being honest when they're telling you who their beneficial owners are. Banks are allowed to rely on what customers tell them. But there will be this database that will be managed by FinCEN, but there are exclusions from the database. So it really applies primarily to to small businesses. They're really focusing on shell companies here, states like Nevada and Montana, where people can open shell companies and not disclose who the owners are. Et cetera. Et cetera. So really the intent here is to create greater transparency. And and so in that regard, companies with more than 25 employees and more than I believe $5 million in annual revenue do not have to register in the database. And that's because they have a large enough profile with the IRS that they are clearly legitimate company. They have 25 employees. So so they're not worried about them being a a shell company. And obviously, that would include, you know, publicly traded companies are excluded from having to be in the database. There's approximately 25 exclusions from being required to register with the boss. But, you know, the largest exclusion being 25 employees or more and more than $5 million in revenue. So. So the this requirement to register your corporation with FinCEN comes out of the Anti-Money Laundering Act of 2020. And we'll be going live in January for new companies. And then previously established companies have another year approximately in which to go on and register. So that's the AML Act of 2020. Now, when we speak of anti-money laundering risk and financial crimes risk, we can't. We really need to discuss FinCEN excuse me, OFAC and geographic targeting orders. So there's there's there's a geographic component to financial crime and some money laundering. Some countries are either covered under OFAC, in which case you cannot do transactions with them or there are very limited we'll go through that or there are places that are privacy and secrecy havens such as Panama or Cyprus or the Seychelles or others who who when you know, somebody is conducting business through, let's say, Panama, you have to question why. What is your purpose for going through Panama? Why? I understand that you're buying a condo here in the United States, but why are you doing it through a Panamanian corporation? Does that make sense? Why? Right. You're asking. You're asking the question. So getting into the concept of geography and geographic risk. So first, let's start with OFAC. Ofac is an office of the US Treasury. They, you know, promote US interests through sanctions, our economic interests and foreign foreign interests. So, you know, basically when there are different types of, you know, programs within fencing. So it used to be that they were primarily country based sanctions. So you would look at countries like Iran, North Korea, Sudan, that, you know, you could Cuba that you just could not. They were restricted. You couldn't do any business with them unless you had some special license. But throughout the last, I'd say, 15 years, the that has been expanded to come up with targeted solutions, looking at specific areas. So now instead of just having country based sanctions, they have targeted programs. So there are over 34 active sanctions programs. There's the cyber related programs, there's the Global Magnitsky Act. There are sanctions related to the Hong Kong demonstrations a few years ago, sanctions around rough diamond trade controls in Africa, sanctions related to transnational criminal organizations. So there are different sanctions programs that have become more complicated for financial institutions to comply with. And so a lot of this and so our OFAC used to be very much a strict liability regime in which if you did the transaction, you were required to report it immediately block the funds. Et cetera. But so fact has gone to more of a voluntary self disclosure regime, a VSD where perhaps after the fact a financial institution has realized that they may have facilitated a transaction that was in violation of one of these sanction programs. The example could be that under the Magnitsky Act, we won't even go into the most recent Russian sanctions. But but under the Magnitsky Act, you could not export fracking technology to Russia or Ukraine. And so if you had a company who was perhaps had a subsidiary in Canada or they were in the fracking business and you saw that they sent a wire to Canada that had in the wire instructions, you know, for payment of Russian fracking material, for example. It would be then the bank would perhaps not see that until later. Uh, and then, um, you know, in that wire would have been sent to Canada, not Russia, but it has the, you know, note in the wire that says for fracking material and, and had a Russian company on there, then, you know, you may end up reporting something like that later through a voluntary self disclosure next or sectorial sanctions. So you know along the same veins really the US focusing on entire segments of economies making it more difficult for financial institutions to detect that. And then what's what we also have here are is the the specially designated nationals. So these are individuals or companies that are owned or controlled by or acting on behalf of. They could be drug kingpins, they could be terrorists. So these are either individual company names or individual names that banks will scan these names at account opening. And so depending on what your name is, you may have hit against an OFAC list. They may have had to contact you and say, hi, are you Pablo Escobar? You know, you're not the real Pablo Escobar or whatever the case may be. Names get matched against this list and banks match names against these lists. So further along the lines of geographic risk, right? So that you can have countries such as Panama and those, you know, Panama, Cyprus, the Seychelles, the British Virgin Islands, whatever the case may be, privacy and secrecy havens that are used to facilitate financial crime and disguise who the true owners of corporations may be. But also you have geographic risk here in the US, as mentioned, the easiest example is Venezuela. When people were stealing money out of Venezuela as fast as they could, perhaps taking that money out of the oil funds and stealing it. And they were using those funds to buy real estate in Miami. And they were able to do it without taking out a loan. And so what happened? The response was a geographic targeting order. And so the geographic targeting order requires, it says, that title companies must collect and report information involving persons engaged in residential real estate transactions of $300,000 or more made without a bank load or similar financing. So residential real estates that are more than residential real estate or residential excuse me, residential real estate transactions for the purchase of real property $300,000 or more and that are purchased without a mortgage or similar financial interest must be reported in the following areas. So geographic targeting order, just what it says, Texas. So that's you know, that's Houston and Dallas. Here in Florida, we have Miami Dade County up to Palm Beach. So, you know, Houston and excuse me, Florida in particular. As I mentioned, that was a Venezuelan issue. New York, the same efforts were being done primarily for Russian and Chinese, you know, money laundering. You know, California, of course, being very and also Seattle very and Hawaii were being used by kleptocrats in China to get money out of China and purchase real estate. So that is why there is this geographic targeting order. So, you know, as you see down below, it's not just, you know, you take out a loan, but, you know, it's the wire transfer, it's the payment all at once. Right. We're paying for all of it with a cashier's check. You know, you've got to meet the reporting requirement. You're paying for it with a wire transfer. Well, where's the wire transfer coming from? Et cetera. You've got to meet the reporting requirements. And it's because of this this money laundering typology that's, you know, was out there is out there. And so they increase the reporting requirement. So there's a geographic targeting order which requires this extra level of reporting. And so, you know, as you may be involved in real estate transactions, it's imperative that you be aware of this and you may be aware of the risk even if you're not in these locations. Right. Money moves. So if there is an order and these places don't see Atlanta on here, hey, let's buy in Atlanta, right? I don't see Charlotte on here. Let's buy in Charlotte. Right. So they're going to move they're going to buy in other locations because they've got to get their money converted. Right. Drugs are a big business. Financial crime is a big business fraud, kleptocracy. They've all got to move their money. And once it gets here to the United States, got a number of benefits. Right. They they they want their kids to be here. Right. Because it's a safe place for their children to be. And then once your money leaves the United States, by and large, it's considered to be clean. So if you're trying to get to a third country, then then the US is a great place to launder your money through because of the perceived legitimacy. And a great way to do that is by sending it through your trust account. So. So now let's get on to the ABA's voluntary good practices for. For money laundering, for preventing and detecting money laundering. So the ABA recognizes this typology that we just mentioned. So they say that those involved in real estate transactions need to collect documentation and conduct due diligence on the parties to the transaction. Families of corrupt politicians are a good example here. We went through that using real estate LLCs to buy real estate and sending the funds via wire transfer. That's the Venezuela to Miami example. Then you have those who are involved in managing clients monies. So where the attorney touches the funds. So the example here is the buying and selling of bonds held in a in a private investment company or personal investment company, a pick for a client in another country. So let's say a BVI account. But the attorney is perhaps the one who's responsible for moving the funds. They have power of attorney over that account. So the illicit actor is not the one touching the funds you are. And so the ABA says, Hey, if you're in this role where you're moving the funds, we recognize that there's a greater risk here and you need to be aware and we would recommend that you not do that, that you would use an escrow agent in that scenario to avoid that responsibility. So the ABA recognizes that potential risk is there. Next, we have those who are the once again involved in trust accounts, helping clients set up trust accounts. Lawyers are advised to avoid situations where they are essentially providing banking services as opposed to merely holding client money for legitimate purposes, for example, in the sale of real estate. If a lawyer is being asked to make payments not just to mainstream lending institutions, but to more obscure recipients, including private individuals whose identities are difficult to verify, the lawyer should exercise caution or treat this as a higher risk situation. The example here is the real estate closing. So, you know, the often what'll happen is they'll provide a source, a false sense of urgency. And that will be, hey, we have to they show up at your office at 5:00 on a Friday or 430 on a Friday and say, I have this money to move. They call. We got to get this closing done. We've got money coming in and we we got to get it done today. Can you help us? We really need your help. We'll transfer in the funds so you get wired money in into your trust account. Then you know the closing takes place and only a portion of it goes into the closing. And then, you know, half of it gets sent to an individual, perhaps in Canada. Then you realize, hey, that wire transfer came in from Panama. It sat in my trust account for two days. Half of it went to a bank related to this closing and half of it went to an individual in Canada. And, you know, how did what happened there? And you only realize afterwards that you were really being used as a pass through. So be aware of that false sense of urgency when you're involved in these transactions, as well as making sure that you identify who all of the parties that are involved. And you know, going back to the earlier statement, this is a great situation in which you could use an escrow agent and avoid putting yourself in this situation of letting your trust account be the one that's dispersing the funds. Another category of law practice that is an increased risk for. Financial crimes is those who are forming entities. So this can be done right? Shell companies, if you're forming shell companies or also what's known as shell companies, right? You organize the company and you keep it alive for ten years. Makes it look like the entity has been opened longer. Those are called shelf companies. They are like shell companies only. You know, clearly, you know, fewer legitimate reasons to use a shelf company. But it used to be done. And so those were involved in these organizations are creating of these complex structures need to be aware that they can be used for financial crimes purposes and to disguise the origin of the funds. And so you have to have a real purpose for why you're doing this. There may be a legitimate reason to incorporate in the BVI. There may be a legitimate reason to incorporate in Turks and Caicos and Dutch protectorates, but it your needs to be a clear, articulated reason on why you're doing that. And if it is an overly complicated structure with no clear business purpose, then you have to question why they're doing it and perhaps distance yourself from that transaction. So. Uh, moving along. Uh, once again, attorneys who are involved in the buying and selling of business entities. So this specific activities appear to include most routine work that is done by real estate lawyers, corporate and business lawyers, trusts and estate lawyers. So, you know, if you're involved in the creation of entities, the buying and selling of entities, be aware that this can be another way of money laundering. Lawyers must evaluate the risks and determine the extent of required. So customer due diligence lawyers need to do due diligence like everyone else, even lawyers who do nothing more than prepare or carry out task of forming legal entities are likely to be subject to the lawyers guidance under this criteria. So be aware that the ABA has categories that they've identified as high risk. There's some of the categories that we've gone through already, but we'll start going into some more detail. So. Here's an example here. Mr.. S headed an organization importing narcotics into the US from Belize. Mr.. S employed a lawyer to establish a web of offshore corporate entities through which Mr. s could launder proceeds of a of the narcotics importing operation. These entities were incorporated in Panama, where there were lax security, lax scrutiny of ownership records and finances. A local management company in the BVI administered the companies. These entities were used to camouflage the movement of illicit funds, the acquisition of assets and financing of criminal activities. Mr.. S was the holder of 100% of the bearer share capital of these entities, of these offshore entities in the US. A distinct group of entities without any apparent association to Mr.. S transferred large amounts of monies to the BVI where it was deposited in or transferred through Mr.. S offshore companies. The same web network found was found to web. The same network of web of companies was found to have been used to transfer large amounts of money to a person in country, let's say Switzerland, who was later found to be responsible for drug shipments destined to the US. So obviously this is a real life example where offshore shell companies have been used to facilitate financial crimes, particularly drug trafficking in particular, you know, offshore financial centres and the BVI and Panama. And so you need to, you know, these things are red flags for a reason. Be aware that they're out there and understand that these things increase your risk. So what do you do to manage your risk in terms of risk management? It's you conduct due diligence, right? You know, your customers and this is how you manage your customer risk for the. So the first thing you do is you have a standard process in place. So you onboard all customers the same way. So when you are onboarding a customer, you collect basic information and then you verify that to make sure that it's true. So you may not need to do this in all cases. You may only do this in cases where you feel uncomfortable or, you know, going up the risk spectrum where you in terms of verification, you may not verify everybody, but there may be some people that you want to verify their information. You may want to do a background check on them. But you need to have a standard onboarding process where you collect the client's information name. So this is what financial institutions collect. And I would recommend that you do the same thing, that you have a standard onboarding process where you at the least collect the same amount of information from everyone so that you can say that you have a process, a standard process for customer onboarding. You can put this process in place so you collect a name, date of birth, their physical address, right? Not a P.O. box and a government issued ID number, whether it be their driver's license number, tax ID number, etcetera. But I would recommend your getting the tax ID number and requiring that as your means of verification. So the next step would be the verification. Maybe you only do this on a risk based basis. Financial institutions are required to go through some form of verification, but it is as well on a risk based basis. They can rely on the documentary verification. So we looked at the driver's license. It really is them. That's. That's him. That was our verification passport. Et cetera. We relied on that document to verify that individual. But the preferred method, especially for law firms and you guys, is that you would subscribe to one of the many online verification systems that are out there. I use Lexus here as an example. It's not the only one. I'm not recommending it. But it does do is that you enter in somebody's Social Security number, their information, and you get an exact match that gives you where that person has lived for the last 20 years. And it also give you any criminal history that they have. So where there's smoke, there's often fire. So like I said, I would recommend that in certain cases where you may not feel comfortable, where some of these geographic risks or where these entity or industry risks are present, that you would go that extra step looking at somebody's background. So if they're not willing to give you this additional information, then that itself is a red flag. But I would suggest that you have a standard process for onboarding your customers and on a risk based basis that you would go through some level of verification that would include a criminal background check. Next. You know, that was really for individuals. But when you're dealing with entities, the question, of course, get more complicated. Right? Money laundering. If you're going to launder money, I would say that you should probably do it through an entity and not in your personal name. Right. You're less likely to go to jail. And so entities are higher risk from a money laundering perspective. So, you know, you're going to want to collect more documentation so you can get the articles of incorporation from the Department of State's website and understand and then start asking questions, right? So you're going to get those beneficial owners who are the beneficial owners. In most cases, it's only going to be, you know, to one person, perhaps maybe two people, husband and wife, maybe it'll get more complicated. But it's important to know, especially, you know, who those beneficial owners are and then ask why did they incorporate there? Why did you incorporate in Nevada if you're operating in Florida, why did you incorporate in the Seychelles? Is that where your headquarters is? I don't imagine you're flying to the Seychelles, you know, for your corporate meetings. You know, it just doesn't make sense. Why did you choose to incorporate in the BVI? Why did you choose to incorporate there? It's a legitimate question and they need to have a legitimate answer. You know, and, you know, to to protect yourself and your firm, you know, you need to ask these questions. Then, you know, collecting that beneficial ownership information. So, okay, well, you know, your husband and wife ownership, we're going to need your wife's documentation as well. Right. And so you can rely there is, as I've mentioned, no standard database for, you know, verifying that they're telling you the truth. So you can rely on what your client tells you to be the truth. They can lie to you. But, you know, you've done your process of collecting the information. In most cases, they're not going to lie to you. Um, so and it's up to you to what level you're going to collect that information. Financial institutions do it on a risk based basis. Where the risk goes up. They'll collect more due diligence. They'll go down to a lower level of shares. You also have to remember that if you get to this level of beneficial ownership where you don't have anyone who owns 10% or more, you go down or even 25% or more. Right? You know, if you can't satisfy yourself down to that ownership or there's not you can't collect all of that beneficial ownership because there's too many of them, you move on to the control version of the collecting of beneficial ownership information. So this is where you would get the those who are the president, vice president, treasurer and secretary or whatever the top four officers of the corporation are. You would they would be the control prong of this beneficial ownership and you would collect their information and verify it the same way that you would do for an individual. You know, once again, where there's smoke, there's fire. You get their Social Security number, you run it through LexisNexis and you see that three of the officers have have fraud convictions in the past. You know, that's going to be, of course, a red flag. Right. Publicly traded companies are a lower risk. So and going back to the the fact that beneficial ownership can be masked through through various complicated structures. We've gone through high risk geographies. We've mentioned, you know, Cuba, Venezuela, Iran, for example. But also keep in mind places that are known for like Mexico, right. With the cartel situation they have there, there's a link to transparency.org known privacy or secrecy havens. We've mentioned those Panama, the BVI. Et cetera. And then so these are all things that are going to increase your risk. And as mentioned, you'll have that standardized onboarding process. And as you go up the risk spectrum, seeing any of these geographies, you're going to want to, you know, sea scan that name, see if they have a background, these background issues. This is particularly true when it comes to politically exposed persons. So these are individuals who have been entrusted with a prominent function in a foreign country. So it would it is also their immediate family as well as their close associates. So they would be politically exposed persons or senior foreign political figures. We have this example below where a politician was involved in corruption. The lawyer here in the US received $50 million from a shell company into their trust account. They transferred that money to then offshore entities. It turned out that the beneficial owners of these entities were the former head of the Secret Service in Venezuela and the state Secretary for the Minister of defense in Ecuador. So this does happen. Lawyers are involved in this and you just don't need those headaches. So there are certain entity industries that present higher risk than others. So here we have a list Trade, finance. Right? Trade. Finance. They can misprice The value of goods was shipped ten Rolexes to my friend in Canada. Well, was were those ten? Were they were they real Rolexes or were they fake Rolexes? Were they presidential Rolexes or were they, you know, cheap fakes? So really, they were worth $10 each. There were ten of them. The real value was 100 bucks. But you shipped it to Canada and wired $1 million because your statement is that they're all $100,000 presidential Rolexes and therefore you've now laundered, you know, $990,000 using mispricing of goods. So trade finance puts you at a higher risk. Real estate transactions put you at a higher risk. Automobile and machinery Exporting in sales puts you at a higher risk. As we mentioned earlier, cash intensive businesses, the pizza shop bars, car washes, parking lots, nail salons, housing and lodging. All are ways that can be used to launder money. How many cars were parked in the parking lot? No idea. Right. That's that's a great way to launder money. It was never full, but they used it as a as a way to pass that money through nail salons, been involved in human trafficking and lodging. Right. Is that hotel really at 90% occupancy? It looks empty to me. So a hotels can be used for money laundering as well. Pawnshops and precious and non-ferrous metals. All of these are things that when you see them, they're going to increase your potential of being exposed to financial crimes risk. And so you're going to want to collect more due diligence. Top five customers are involved in trade finance. Et cetera. Do more background checks on the on the customers, knowing who your customers customers are. And then once again and what other products they sell. You know, all of that's important. If they're not willing to answer these questions and give you this additional information and tell you more about their business, then it's then that's a red flag. You know, as attorneys, you're very much aware that the more information you have about a client, the more it will help you do a good job for them and get avoid some legal pitfalls. So you should be collecting more information. You should be asking more questions. If they don't like that, you're asking questions. It's a red flag. Also look for unusual activity. I gave you that example of, you know, that false sense of urgency. Hey, we've got to get this done now. We've got to get this done now. You know why? Why this false sense of urgency, right? They want to rush you into doing this transaction. Also, you know, if you don't normally do cross-border transactions, why are they coming in to do this transaction with you? It could be because they know that you don't know what you're doing and they want to take advantage of you. So be aware of that. Client Why did you pick me? Why do we have to do this? So closing, you know, be willing to walk away from these things when you're getting that false sense of urgency. In adequate consideration, right? The value of $1 million of land to a third party for $20,000. Right. So, you know, an adequate consideration is also a money laundering tactic. And then also, you know, from the ABA, these are all based on ABA guidance is where you're dealing with estate administration from somebody who has died but previously been convicted or is involved in some industries that are known to be high risk and known to be associated with organized crime. And the examples that the ABA provides are casinos, bars, strip clubs and dealers and pornography are all, you know, you know, when that estate administration happens, you know, that may be funds that are linked to illicit activity and you want to be aware of that. You know, then cash payments. There's IRS form 8300. So these are payments received from unassociated or unknown third parties or payments in cash, which should So clients paying in cash are a higher risk situation for payments from third parties. Always understand the reason for that arrangement. Be aware of the requirement that each person engaged in trade or business who in the course of the trade or business receives more than $10,000 in cash in one transaction or two or more related transactions, must file that 8300. So that's you. If you're taking in cash, if you're involved in criminal defense, you're obviously very much aware of this. Uh, and then, you know, back to managing your risk. Do those new searches, It can be as simple as a Google search on somebody. You can go to your local criminal database, your, you know, your your court database and see if they have past convictions. You know, have a risk based process in place for collecting additional due diligence as some of the risks that I've pointed out to you come along. And, you know, so if you're seeing these red flags that we've mentioned in terms of industry, in terms of geography, in terms of the types of transactions, the immediacy, the cash, if you're seeing these things, then your risk should be elevated. You should be conducting more due diligence, asking more questions and perhaps doing that background check to protect yourself. Really, you know, if something does go wrong, at least you can fall back on your process and show that, look, we do we do this for everybody. We did a background check on them and we got nothing. You know, we didn't enter into this unknowingly. So establish a process, a standard process for onboarding, escalating your the amount of due diligence that you do as your risk increases. And then an easy thing to do is establish training for your firm so that they can be aware of these risks and they can prevent you from taking on these risks. So the ABA once again says that you must satisfy yourself that there is no criminal activity taking place. So what do you do if a client presents an unacceptable risk? So not every risk based approach analysis of a potential client will inexorably lead to the conclusion that with appropriate controls, the lawyer can accept and proceed with the proposed engagement. It may be possible that the lawyer's analysis will lead the lawyer to reject the engagement or to withdraw from the representation. So we go to ABA Model Rules of Professional Conduct 1.16. This is when to decline or terminate the client relationship. And so a lawyer may withdraw from representing a client if, among other things, the client persists in a course of action involving the lawyer's services that the lawyer reasonably believes is criminal or fraudulent, or the client has used the lawyer's services to perpetuate a crime or fraud. So if anyone goes to jail, make sure it's the client right? And if you're going down this path, you can withdraw from representation under ABA model rule 1.6 when you should withdraw from representation. So that's the end of my course. If you have any questions, please feel free to contact me. Thank you for listening and I hope this has been useful.

Presenter(s)

TDJ
Timothy Dunfey, JD
President
Alhambra Compliance

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