THE BITTER LESSONS OF ROSEMONT FINANCIAL CORPORATION

Lest we forget:

(1) Money service businesses can NEVER think that they can circumvent US regulators through artful use of the accounts of a registered MSB. Both FinCEN and state regulators will find you, one way or the other; Shortcuts never work out.

(2) Your US relationships are only as good as your US partner is honest; Ramakrishna Vyasulu, Rosemont Financial's CEO (and not its owner) was caught trying to launder $1m if what he thought was drug proceeds.

(3) your US financial partner will roll over on you in a New York minute, if he is caught breaking the law, and he will not be punished nearly as strongly as you will be. Vyasulu cut a sweetheart deal with DOJ in Massachusetts, whilst his clients has $200m seized, and it was costly and time-consuming to get only most of it back.

(4) If it is discovered that you have any dodgy clients, expect years of investigation, and no clean bill of health later, should you be lucky enough to escape the criminal justice system.

(5) Your legal fees, in any dispute with US regulators and law enforcement, will be obscenely high; forego this nightmare by not giving them cause to seize your US accounts, investigate you ad nauseum, damage you in the media,  and ultimately keep some of your hard-earned profits.