October 2007

A former Criminal Intelligence Specialist at Scotland Yard confirmed that the divorcing husband was hiding millions from his wife by using bank accounts in Switzerland.  The husband’s true beneficial ownership of these funds had been concealed by a nominee (i.e. intermediary).  This nominee had opened the Swiss bank accounts in the names of shell corporations…

People don’t typically think of the common money laundering indicia when searching for hidden assets the subject of a: divorce; bankruptcy; commercial collection or other legal proceeding.  Such indicia can be effectively used as part of an asset search / recovery effort even in situations where there is no money laundering.  In the United States,…

In the United States, the Financial Crimes Enforcement Network regulates the customer identification procedures, (a.k.a  “know your customer rules”), at banks.  In order to clarify these procedures, the Financial Crimes Enforcement Network issued guidance in January 2004.  These customer identification procedures codified at 31 C.F.R Part 103.121, demonstrate  that there is no discretion…