Friday, November 11, 2011


Let me suggest to you that it is dangerous to continue to provide banking services to any Politically Exposed Persons who, for one reason or another, have either been barred from entering the United States, or have had their visas cancelled. These individuals are generally the worst of the worst: corrupt PEPs who are taking bribes and kickbacks, looting government treasuries, violating human rights, or engaging in illegal activities, and there is sufficient evidence to bar them from coming into the US, spending their dirty money, and enjoying all that America has to offer.

 I am particularly offended at those Haitian PEPs who maintain multiple mistresses in Miami, ladies who freely and lavishly spend their paramours' money, which is often stolen from the poorest country in the Western Hemisphere. Why those individuals still have multiple entry visas astounds me.

In many cases, when a corrupt PEP has his or her visa taken away, it means that an OFAC sanction, or criminal indictment is not far behind. Do not get caught with an open account for this individual when the shoe drops. Many commercial off-the-shelf high risk databases list this persona non grata status when it is known, and rumours of such pariah status also surface on the Internet, particularly on opposition websites.

Do not let the lure of a well-heeled new foreign client trump your compliance prudence. Is the client sending in funds from overseas ? Does he no longer come into the US in person ? Why not ? Find out why he sends emissaries to make his large deposits.

1 comment:

  1. I agree with you 100%. But it seems that the glint from the pile of money can blind even the most sensible people to what is in front of them. MLROs often tell me that they take damning information about PEP clients to their Board, only to be told that this client is too important, or that client is too valuable, to be lost. It is hard to see could be more important or valuable than the reputation of the firm.


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