by Kevin Sullivan, CAMS, CCI | Mar 31, 2020 | Anti-Money Laundering Program, Commentary, News
A Field of Schemes A financial criminal today working for an organized crime ring, drug trafficking organization, or terrorist operation, wakes up singing praises to his personal idols Al Capone, Charles Ponzi, and Lex Luthor, as he knows that his world is about to...
by Kevin Sullivan, CAMS, CCI | Feb 5, 2020 | Commentary, News
The Damage of the Broad Brush After reading the recent OCC report on Wells Fargo and noting fines of multiple top level executives for sales practices misconduct, it is very easy to become sour on the bank and paint all their employees with the same broad brush. The...
by Kevin Sullivan, CAMS, CCI | Jan 28, 2020 | Commentary, News
The Cross Sell Scheme The Office of the Comptroller of the Currency (OCC) recently released an investigative report based upon the misconduct of Wells Fargo Banks’ sales practices. This was the practice of bank employees providing a product or service to a customer or...
by Kevin Sullivan, CAMS, CCI | Jan 16, 2020 | News
The Vatican Bank Investment Dilemma Recently Pope Francis ordered the investigation of the Holy See’s (Central Governing Body of the Catholic Church) Financial Information Authority (competent authority) located inside of Vatican City regarding money donated to the...
by Kevin Sullivan, CAMS, CCI | Dec 17, 2019 | Anti-Money Laundering Program, News
What’s a GTO? While the term geographical targeting order (GTO) sounds like something out of a James Bond film, it actually is a very unique order issued by the Department of the Treasury to narrow the scope of a financial investigation. The GTO is a mandate...
by Kevin Sullivan, CAMS, CCI | Nov 19, 2019 | News
The U.S. Attorney’s Office in the Southern District of New York has indicted Bruce Bagley, a University of Miami professor in the Dept. of International Studies, on charges of money laundering and conspiracy. Mr. Bagley is the author of a book on money...
