Saturday, April 29, 2017


This week's news, regarding the fact that the government of the Republic of Turkey is blocking local access, on the Internet, to Wikipedia, when added to the fact that other websites are known to have been blocked or censored within Turkey, is not good news for compliance officers, no matter where their banks are located.

If compliance officers inside Turkey do not have free and unrestricted access to the world wide web, then their efforts to confirm negative information on a customer could be blocked, meaning that an high-risk individual could be granted the ability to open accounts, when a complete, and unimpeded, due diligence, or enhanced due diligence investigation would have uncovered information sufficient to block his or her access.

This impacts banks located outside of Turkey, for existing clients for whom assurances of adequate due diligence are assumed, may be, in truth and in fact, money launderers, terrorist financiers, or international sanctions violators. Let us not forget why Reza Zarrab, and one of his Turkish bankers, are facing long terms in Federal Prison in the US, for oil sanctions violations; they used Turkish financial institutions to evade UN, and US, sanctions.

If Turkey's compliance officers are working with one hand tied behind their banks, perhaps you want to take a hard look at any substantial wire transfer, originating from Turkey, as part of your risk-based compliance program. You do not want to be approving any major transaction, from Turkey, where you rely upon their banks' due diligence, using a restricted and censored information resource.

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