CH4 - Identifying Fraud and Corruption Associated with Governmental Officials and Contracts in the Mid-Atlantic Region

Every financial institution (FI) has fraud and AML challenges; geographical location will oftentimes add unique challenges for financial institutions to consider in their programs. Many FIs in the Mid-Atlantic region have the honor of servicing government related accounts. Reputation risk associated with banking a corrupt government official or lax oversight for governmental accounts can be a death warrant for a financial institution, such as the embassy relationships that brought down Riggs National Bank. Governmental fraud and corruption is a serious problem globally but particularly in the Mid-Atlantic region, where many of our government offices and representatives reside. Building a robust AML program that finds the bad guys, meets regulator expectations and is cost effective is a difficult challenge. Add to that doing business in an area where the Foreign Corrupt Practices Act (FCPA) and OFAC cannot be "check the box" exercises, and building a quality financial crimes program becomes much more difficult. Representatives from the North Carolina, Richmond and US Capital ACAMS Chapters will present recent case studies including government-related fraud or corruption, highlight the red flags for suspicious activity and provide salient and usable guidance that you can apply to your AML programs. Discussion points from this session will include:

• The steps financial institutions can and should take to identify suspicious activity by public officials
• Building FCPA red flags into your surveillance program
• Identifying funds that are derived from corruption or fraud activities