Thursday, May 28, 2015


In light of allegations of systemic corruption in FIFA, the global professional football association, and the attendant money laundering charges unveiled against senior officials, you might be well advised to check on whether you are banking any local FIFA officers, and even low-level staff members, for one must assume:

(1)  That the hidden bribes were funneled through third parties.
(2)  That some of the payments were in cash, and I mean specifically US currency, and that had to be obtained from a bank, MSB, or other NBFI.
(3) That staff members were involved, even unwittingly, in the movement of bribe money, communications regarding the payments, and deletion of emails or other records.
(4) That accounts in offshore financial centers were employed to hold the ill-gotten gains.
(5) Most importantly, that there are other, not yet indicted, FIFA officials out there. Are any of them possibly your clients ?

Prudent compliance officers should be asking customer relationship supervisors whether there are any football skeletons in their closets. Does anyone at the bank routinely get fantastic seats, complimentary, at football games, from clients ?

 What about sports marketing companies ? Do any specialize in football ? If you are showing any as clients, you should be performing enhanced due diligence upon the entities and the individuals forthwith.

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