Money Laundering and Your Bank Accounts – Part VIII – Trade Finance

Banks and containerisation are the cornerstone of international trade.
Photo by chuttersnap on Unsplash
This is the eighth part in our series revealing exactly what banks are looking for when they are combatting money laundering.
Trade finance is one of the most common areas for laundering money. Accordingly banks throughout the world look for suspicious transactions. Avoid the following situations if you want your business to flow smoothly.

Trade in Suspicious Goods

Businesses have standard types of goods associated with their businesses. When they shift to or add items to their normal purchases or sell products that aren’t their normal business, that sets off an alarm. For example, a company that sells perishables but switches to machinery would trigger an alert.

Higher Risk Jurisdictions

Transactions involving parties in higher-risk jurisdictions automatically receive more scrutiny; activities that might pass muster in other jurisdictions may lead to problems.

Transiting Higher Risk Jurisdictions

Transactions that transit higher risk or bon-cooperating jurisdictions receive additional scrutiny. That is because criminals may substitute cargo or divert funds,

Customers Involved in High Risk Activities

Banks scrutinize any customers handling risky products such as those below for possible involvement with criminal gangs or terrorists.

  • equipment for military or police organizations of foreign governments,
  • weapons,
  • ammunition,
  • chemical mixtures,
  • classified defense articles
  • sensitive technical data
  • nuclear materials
  • precious gems
  • certain natural resources such as metals, ores, and crude oil

Trade Pricing Fraud

Goods or services that are obviously mispriced are a common way to launder money and evade taxes. Central Bank authorities are well aware of this and in most cases require that their banks be alert for such activities and alert them to any such cases. And, of course, when periodic audits are conducted, this is one of the areas that receives close attention.

Misstating of the Quantity

This is a variant of Pricing Fraud where the unit cost is correct but the quantity is changed up or down to achieve the results that the company wants.


Just as corrupt governments create over-complex laws to enable graft and self-dealing, fraudsters design over-complex to enable fraud in commerce. Banks are on the lookout for such transactions and are responsible to report such cases to the Central Bank.

Third Party Payments

If a transaction between party A and party B stipulates a payment to party C, this will alert the bank to look more deeply into the transaction. Obviously the could be a legitimate transaction but the method is often used to launder money.

L/C Inconsistency

If the terms of and L/C haven’t been precisely met, the bank will not honour it. If it does, either by accident or on purpose, then the examiners will conduct an investigation to determine why that was done.

L/C Amendments

Bank authorities will investigate all significant changes to L/Cs to determine the reason why the change(s) were made.

It is clear that international trade is an area in which it is relatively easy to launder money. Banks are alert to the possibilities but the sheer volume of trade makes this an area of ongoing concern.

Money Laundering and Your Bank Accounts – Part VII – Unusual Activities

Banks Solve the Money Laundering Puzzle.
This is the seventh part in our series that reveals exactly what banks are looking for when they are combatting money laundering.

Bank-to-Bank Transactions

The size and frequency of currency deposits increases rapidly with no corresponding increase in noncurrency deposits.

You know if you expect to see an uptick in your currency deposits. If you do, pay a visit to your banker and explain to her what is happening. That will forestall any unnecessary problems.

A bank is unable to track the true account holder of correspondent or concentration account transactions.

You may have an account that receives deposits from several other banks. For example, for sales made in multiple countries plus deposits from a credit card bank. If the bank thinks you aren’t the actual account owner, then they are obligated to take action. They will report it to the appropriate authorities.

The turnover in large-denomination bills is significant and appears uncharacteristic, given the bank’s location.

There is a global effort to reduce the number of large currency bills in circulation because of their anonymity. Your account will be flagged if you process many of these through your account where this is unusual.

Changes in currency-shipment patterns between correspondent banks are significant.

Transactions between correspondent banks are tracked so that if an employee manages to bypass internal controls, she will be caught. There are several triggers to be aware of:

  1. Large volumes of small denomination bills are sold to U.S. banks. (This is a trigger in the EuroZone as well. In that case, triggering currencies are USD, GBP and EUR.)
  2. Multiple wire transfer instructions from foreign nonbank institutions requiring the bank to transfer funds to entities for which there seems to be no reasonable business purpose.
  3. Customers exchange large volumes of USD or Euros for larger denominations. This facilitates physical cross-border shipment of currency.
  4. Deposits of Euros or US Dollars by a foreign non-bank entity that subsequently transfers the funds via wire to foreign non-bank entities.

Even legitimate businesses risk losing access to their funds temporarily or permanently as well as prompting an investigation of the principals if they engage in any of these activities.

Protecting Your Information While Travelling.

Protecting Information
image by stevepb
We are interrupting our information series on the impact of money laundering controls on legitimate businesses to deal with a subject that has become increasingly urgent to many of our customers, and that is protecting their private information when traveling. We shall complete the money laundering series shortly.

Protecting Your Private Information During International Travel

Numerous businessmen have become worried about the increasingly intrusive nature of border inspections. Border security agents are beginning to treat information with the same level of concern as they do physical weapons. That concern is understandable but too often it leads to invasions of privacy that are not warranted. Furthermore, they can easily lead to the leakage or loss of critical commercial information or reveal embarrassing private facts. Governments should not act in these domains, but we’ve made it easy for them. So they do it.

Border Interrogation

When you cross into a country, there is no limit to the amount of information border control agents may demand. Your very first line of protection is to be normal in every possible way. Act as a businessman, a tourist or a relative. Don’t draw attention. Don’t project an aura of being special.

Answer questions matter-of-factly. Tell the truth. Don’t joke.

If they select you for further questioning, you’ll go to a separate interrogation room. They are being paid for the time they are there. Meanwhile, the loss of time is costing you money. You want to leave quickly. They want overtime pay. They will use your impatience against you.

When they finish asking you questions or perhaps before, they will ask to look into your laptop and phone. Of course, they will tell you to provide the passwords. Now the trouble starts. As an international traveler entering a country, you have no rights. You are at the mercy of the inspector in front of you. You have two rational choices and one irrational:

  1. Give up your passwords and give them the keys to your life.
  2. Give up your passwords and let them be meaningless.
  3. Try to fight them.

We encourage option two. Give them the passwords to unlock your devices and any applications on them. Just ensure there’s nothing important for them to see.

Finger Prints, Pattern Tracing and Iris Scans

None of these are as effective as the old-fashioned password for protection – if you create a good password and change it from time to time.
As a matter, of course, you should have your devices set for complete encryption of all the data on them whether you are at home or on the road. Then, if you have any concern at all that your device may be lost, stolen or compromised, you should be certain to use a well-formed password to protect it.

Invisible Information is the Best Defense

When you cross a border, take the minimum necessary information with you. Fortunately, in the twenty-first century, you can transport minimal data easily. On the other hand, ferreting out your secrets is easier than ever, too. Especially if you aren’t careful. There are several data storage areas you need to be aware of; border agents certainly are.

  1. Your digital devices
  2. The cloud
  3. Social media

Let’s cover these in a bit of detail:

Digital Devices 1

There is virtually no possibility that you know what data can be found stored on you digital devices. Poor programming practices and lazy habits ensure that practically everyone has far more information on their devices than they can imagine. Every time they upgrade, they get more memory and transfer more history from their old devices to their new ones. Oftentimes it is buried so far that we don’t even know it is there. And if we don’t know it is there, we certainly can’t remove it. Some of it may be embarrassing. Some of it may be incriminating.

On top of that, as almost anyone with even a slight bit of computer literacy can tell you, erasing things doesn’t actually erase them. Generally, erasing just changes the first character to let the system know that space is available, but all the rest of the information is still there if it hasn’t been overwritten.
What you are going to have to do is to leave your daily-use digital devices at home.

Digital Devices 2

From now on you will carry only the bare-bones hardware that you need. For example, an iPad and a Huawei phone. Your iPad will connect to a straw iCloud account that is bare-bones and is not your regular one. Your Huawei will have only the phone numbers of your office, home and a couple of restaurants where you have business lunches.
Everything will have been paid for in cash or through your company account. Nothing will tie to your credit cards. The SIM for the phone will be one which you purchased for cash and without identification or, at worst, will tie to your company.

Memorize your iCloud account information. Use that information to download everything else that you need.
Once through the border and in your hotel room, you can connect your iPad to your main iCloud account and then download the business information and any apps (e.g. WhatsApp and Skype) that you need. Before leaving the country, you will upload all of the data back to the cloud and then reset your iPad and erase everything. Then you will connect the iPad to your innocuous iCloud account.
You will handle your Huawei Phone similarly.

The Cloud

Digital devices love the cloud. You probably have at least ten cloud accounts of one sort or another and some of us have acquired hundreds. There are a variety of ways to track the passwords for them including through special password apps, through your digital device operating system or some manual system of your own. You will connect your iPad only to your straw account. Your straw account will contain real information but not information that you wish the border agents not to see.

Social Media

This may be your biggest problem if you have been putting information on your social media that you would prefer that the border security agents not know about. They will check the most popular social media sites.
If you are able, you can try to clean up your social accounts, but generally, there’s not much you can do. What’s done is done. You can start flooding them with entries every day so that the investigator gives up before getting to what you want to conceal or can’t distinguish the important from the dross.

Money Laundering and Your Bank Accounts – Part VI – Loans

photo by Drew Hays,
This is the sixth part in our series revealing exactly what banks are looking for when they are combatting money laundering.

Laundering Money Through Lending Activity

Money launderers course massive sums through loans and investments. Bank authorities must perform significant due diligence to detect money laundering in these cases. To top that off, some governments try to discourage detection of such money laundering activities through legislation and regulation.

A borrower secures loans using pledged assets held by third parties unrelated to the borrower.

Launderers clean dirty money by pledging an asset purchased with dirty money to secure a clean loan. Sometimes, they course the funds through several banks, several shell companies, and one or two straw men. The bank may ask many questions to prevent any money laundering. The borrower must answer those questions convincingly.

A borrower secures a loan by using readily marketable assets, such as securities. If a third party owns the assets then the transaction is especially suspicious.

Borrowers don’t usually pledge easily marketable assets to get cash. The borrower can sell such assets with less difficulty than taking out a loan. If a borrower does not, he needs to be able to explain why. He will need to provide a convincing reason.

A borrower defaults on a loan that is secured by easily marketable assets.

The borrower probably took out the loan in order to default on it. Launderers create these schemes as a way to convert somewhat clean assets and create clean money.

Loans are made for or are paid on behalf of, a third party with no reasonable explanation.

The borrower purchases a certificate of deposit using an unknown source of funds in order to secure a loan. When funds are provided via currency or multiple monetary instruments the source of the security is even more suspicious.

Banks may permit the borrower to partially or fully secure a loan by purchasing a CD issued by the bank. However, banks that do so must thoroughly vet the source of the funds. If they don’t, regulators will suspect them of colluding in money laundering.

Banks that make loans that lack a legitimate business purpose, provide the bank with significant fees for assuming little or no risk, or tend to obscure the movement of funds (e.g., loans made to a borrower and immediately sold to an entity related to the borrower) will be suspected of colluding to launder money.

Money Laundering and Your Bank Accounts – Part V – Suspicious Activity

mental laundering - starkness
photo by Jace Grandinetti

Suspicious Activity: Any Activity Inconsistent with Your Business

This is the fifth part in our series revealing exactly what banks are looking for when they are combatting money laundering.
Money launderers sometimes try to fool banks by providing convincing evidence of their honesty when they open their account. Then when the account is running, they change their operations into money laundering mode.

A business’s pattern of currency transaction patterns shows a sudden change inconsistent with its normal activities.

For example, you operate an import-export business that receives £100,000 spread among ten customers. Then, over the course of a few months, you ramp up the deposits to £300,000 spread among several hundred customers. This is a clear change in the way you do business and would elicit an investigation. The bank would also find it suspicious if suddenly one customer paid you an unusually large amount.

Money Laundering by depositing a large volume of cashier’s checks, money orders, or funds transfers deposited into or purchased through, your account when the nature of your business would not appear to justify such activity.

This is an extension of the previous pattern but extends to domestic business and physical payments are also important.

Money Laundering through a retail business with dramatically different currency deposits from similar businesses in the same area.

Perhaps a drug gang purchases a restaurant to launder money. Similar restaurants in the neighborhood receive practically all of their payments through credit and debit cards. On the other hand, the gang’s restaurant’s receipts are almost all cash. This discrepancy will alert the bank inspectors. Because they inspect the banks, they are aware of the activity of all the banks in the neighborhood. Furthermore, this activity will alert bank software that keeps track of patterns for similar businesses, local and national.

Clients effect unusual fund transfers among related accounts or among accounts that involve the same or related principals.

The owner of either a retail business and a cheque-cashing service does not ask for currency when depositing checks. He may have another source of currency.

Retail businesses in the 21st century frequently need to request currency because of a large number of credit card and debit card transactions. And, of course, a cheque cashing business that had no requirement for cash would be odd, indeed. If they don’t require currency from time to time, this is an item to be investigated.

Goods or services purchased by a business do not match the customer’s stated line of business.

A client layers transactions to launder money. For example, a fast-food restaurant assembles payments from street-corner drug dealers. Then the restaurant pays invoices for car parts to a gang-owned auto parts dealer. The dealer assembles the payments from several restaurants and passes them up the chain to a diamond wholesaler. A fast-food restaurant buying auto parts? An auto parts retailer buying diamonds? The bank sees these transactions and checks for money laundering.

A client pays for goods or services with checks, money orders, or bank drafts not drawn from the account of the entity that made the purchase.

Businesses should never pay on behalf of other businesses or individuals. Third-party transactions can mask illegal payments. Accountants will discourage such payments. Banks will suspect them.

Money Laundering and Your Bank Accounts – Part IV – Automated Clearing House (ACH)

dirty money needs laundering
image by Vitaly via

This is the fourth part in our series revealing exactly what banks are looking for when they combat money laundering.

Automated Clearing House Transactions – Policing Money Laundering

“Automated Clearing House” or ACH refers to all clearing houses, not only to the U.S. one with that name. GIRO, NETS, ACH, CHAPS, EFT, BACS, PEACH, SDD and others are all automated clearing houses. Launderers attempt to route transactions through them to bypass some anti-money laundering safeguards.


The rapid rise of financial technology (Fintech) third party quasi-banks has created new openings for money laundering. PayPal was one of the earliest Internet Fintech companies but many have followed in its wake. Fintech quasi-banks carve up the banking product into pieces. Each fintech company provides one or two services, adding to the burden of regulators. Ayden, LendingClub, Addepar, Commonbond, Kabbage, Transferwise, etc. are a few of the many third party fintechs. Fintechs are generally on the up-and-up but it is reasonable to assume that some are designed as money laundries and are even capitalized by dirty money.

Non-customers launder money by using large-value, ACH transactions through third-party service providers (TPSP) that don’t perform effective due diligence.

Regulators don’t control TPSPs as rigorously as banks. So money launderers can move money into the banking system without the usual controls. ACH systems must flag such transactions. Regulators are looking at the TPSP environment now. Even so, they only look at deposits, checks payment, and money lending.

TPSPs violate ACH network rules, or generate illegal transactions, or process manipulated or fraudulent transactions on behalf of their customers in order to facilitate money laundering.

Regulators should close down TPSPs after catching them breaking the law, but often they don’t. Usually, regulators don’t consider the transgressions to be bad enough to put them out of business and may impose lesser penalties. Bank regulators will look for regular patterns of abuse by TPSPs. When they find an abusive TPSP, they will punish banks that have done business with it. But that takes time. Meanwhile, money launderers and their crooked clients continue to operate.

Layers of TPSPs that appear to be unnecessary are involved in transactions in order to launder money.

Always and everywhere, officials use complexity to facilitate fraud or theft. Complex tax codes such as that of the U.S. are examples of regulations designed with malicious intent. Complex financial deals are often designed to defraud. Regulators find such fraud hard to detect if they were designed with care. Launderers use TPSP layers to facilitate much of the money laundering outside the main banking system.

Clients initiate an unusually high level of transactions over the Internet or by telephone.

This is simply smurfing by another means and is as easy to track as any other kind of smurfing. Banks will usually detect this in the twenty-first century, and if they don’t, their regulators will.

NACHA information requests indicate potential concerns with the bank’s usage of the ACH system… i.e. they may suspect money laundering.

NACHA doesn’t communicate directly with end users of the US ACH. That is important for you to know because fake NACHA emails are a goldmine for phishing attacks. However, NACHA does have a set of rules and the ability to fine members who do not obey them. Furthermore, banks can alert NACHA of suspicious transactions they see. Third party software such as that provided by NICE•Actimize can automatically detect the misuse of ACH transactions. Those are reported to NACHA and bank regulators.

Can Money Launderers penetrate the system?

Yes. Many people try to game the system and succeed. It is clear that in many governments themselves are anxious to leave some channels available to move dirty money with little friction. Power and money laundering go hand-in-hand.

How do money launderers work in the 21st century?

In one scheme, criminals route debt obligations across multiple borders to clean dirty money. For example, X takes out a loan for a million dollars from a peer-to-peer fintech lender in the U.S. He deposits the loan in his U.S. account. He then funds the repayment of the loan from a Bank of Cyprus account using a UK peer-to-peer fintech fund offset service. Money crossed no borders under this scheme. On the other hand, the launderer moved a million dollars from his Russian-controlled Cyprus account into the U.S. When he repays in amounts of around $5,400 per month they will be thought to be normal payments for a thirty-year loan. Only the structure of the transaction would give a clue as to what was going on and given the separation in location and time, no alarms will sound.

We will discuss other schemes later in this series.

Money Laundering and your Bank Accounts – Part III – Funds Transfers

image by Vitaly via

This is the third part in our series revealing exactly what banks are looking for when they are combatting money laundering.
Transferring funds is at the heart of commerce and is the most important function performed by modern banks. Transferring funds is also at the heart of money laundering. Move dirty money through enough hands by sufficiently devious means and at some point, it magically becomes clean.
Think about this, if we can describe an activity, it is possible to write software to detect it. Banks do just that.

Bank Checks on Money Laundering Funds Transfers

You transfer funds in large, round dollar, hundred dollar, or thousand dollar amounts.

This is classic smurfing. Sudafed smurfs were buyers for meth labs who would go from drugstore to drugstore purchasing Sudafed cold medicine containing pseudoephedrine. The manufacturer then made crystal meth from the pseudoephedrine. Smurfing has expanded into money laundering. Smurfs typically deposit small amounts to many accounts. The money from those accounts is then assembled and transferred to a master account in another country. Then someone transfers the money, this time to the actual beneficiary. Dirty money often travels through several jurisdictions before arriving at the final destination.

Funds transfer activity occurs to or from a financial secrecy haven, or to or from a higher-risk geographic location without an apparent business reason or when the activity is inconsistent with the customer’s business or history.

“Higher-risk geographic locations” tend to be tiny island nations such as the Cayman Islands, Vanuatu or the British Virgin Islands. But, they are also places such as Luxembourg and Gibraltar. Banks maintain a list of risky jurisdictions. Transactions involving such jurisdictions receive extra scrutiny.

Funds transfer activity occurs to or from a financial institution located in a higher risk jurisdiction distant from the customer’s operations.

There might be a logical reason for a Florida business to be remitting to or receiving funds from the British Virgin Islands, which are close by. On the other hand, it is unlikely that they’d be doing much business with the Cook Islands in the South Pacific. Again, banks will pay extra attention to such transactions.

Your accounts receive many small, incoming transfers of funds, or receive deposits of checks and money orders. Then, almost immediately, all or most of the transfers or deposits are wired to another city or country. Usually, the transfers are in a manner inconsistent with the customer’s business or history.

Again, we see smurfing on a large scale. Drug cartels purchase chain restaurants, casinos, entertainment and sports venues in order to be able to launder money through them. These venues typically have large numbers of small transactions; ideal for throwing banks off the scent. But law enforcement has statistical data that can sniff out this sort of money laundering.

Your accounts receive large, incoming funds transfers on behalf of a foreign client, with little or no explicit reason.

Banks want to know what to expect. If you are going to be receiving a large amount of money, it is wise to tell them in advance what is going on. Ensure that they write it down so that you can avoid suspicion. You may think it is troublesome, but having the FBI knocking on your door is real trouble.

Transferring funds is unexplained, repetitive, or shows unusual patterns.

To the average person, the world seems jumbled, chancy, ad hoc. But those who pay attention see patterns. So it is with bank accounts. Observe enough bank accounts and you’ll see that 99.9% of them follow predictable patterns. If your account is in the one-tenth of one percent, the bank will examine it closely.

You receive payments or receipts with no apparent links to legitimate contracts, goods, or services.

If you run an asphalt business and suddenly receive payment in your account for a Ferrari, that may well be flagged. Receive payment for a Ferrari and a luxury condo and it will be flagged.

You send funds to the same person using different accounts or to different accounts. Or the reverse.

Well Sir Smurf-a-lot, banks figured out this channel a long time ago. It can work, but only by using multiple aliases or smurfs at many banks over a long time.

You don’t provide enough information regarding funds transfers, not only the why but also the who of related parties.

Banks detect these omissions sometimes but they fall into a gray zone. Protect yourself by being open and up front in describing both why the transaction is taking place and who the beneficiary is.

Money Laundering and Your Bank Accounts – Part II – Avoiding Scrutiny

image by Andrew Gook

This is a continuation of our series on money laundering and bank accounts. We hope to help you avoid making yourself look guilty during the normal course of business. Keeping things above board is the surest path to a sound sleep.

Guilty Until Proven Innocent

When interacting with the banking system you have no assumption of innocence working on your behalf. With over a trillion dollars having already been laundered and billions more being laundered every year, monetary authorities are nervous. Furthermore, only 0.2% of the money laundered is caught. Every citizen pays the cost for this in higher taxes and higher prices.
Know what the cop on the beat is looking for and you can stay above reproach. Sometimes this may seem troublesome, but in the long run, your life will be easier.

Common Efforts to Avoid Reporting or Recordkeeping Requirements

You try to persuade a bank employee not to file required reports or maintain required records for your bank accounts.

This is a high-speed train to prison. Don’t even think about it.

You are reluctant to provide information needed to file a mandatory report, to have the report filed, or to proceed with a transaction after being informed that the report must be filed.

Reluctance looks like guilt. Know in advance everything that is required of you. If the workload is too great or the information too sensitive, don’t open an account.

You hesitate to furnish identification when purchasing negotiable instruments in recordable amounts.

Negotiable instruments are cumbersome, but in sufficiently large quantities can be useful to money launderers, especially if they are smurfing. (Doing many small transactions to avoid alerting authorities.) Banks know this. Bank examiners know this. Never, ever hesitate to show your identification.

You ask to be exempted from reporting or record-keeping requirements for your bank deposits.

When it comes to money, criminals don’t want perfect records. Sloppy/missing records are the hallmark of criminal intent. Keep perfect records and give the banks what they ask for and be happy to do so.

You often use the automated teller machine to make several bank deposits below a specified threshold.

Banks look for multiple small transactions (“structured transactions”) which are used to get around the $10,000 limit. Using an ATM or multiple ATMs won’t hide the structured deposits. Make deposits to different accounts and in different amounts and collect them ultimately in one account and you’ll set off an alarm. Don’t bother to try.

You deposit funds into several bank accounts, usually in amounts of less than $3,000.Then you consolidate them into a master account and transfer them outside the country.

Bad move. If you send the money to or through a suspicious location you may hear a knock on your door. This is just one small step more complicated than the earlier approach. They will notice.

You access a safe deposit box after completing a transaction involving a large withdrawal of currency or accesses a safe deposit box before making currency deposits structured at or just under $10,000, to evade the bothersome CTR filing requirements.

The bank tracks everything you do with its computers. You can’t fool them with something this simple. Why try?

Money Laundering and Your Bank Accounts – Part I – Hiding Information

money laundering machine
Businesses and individuals don’t know what banks are looking for when deciding to open an account; it used to be so easy!  Anti-money-laundering and terrorist financing detection regulations are the problems.

Over the next few blogs, we will alert you to a number of things that legitimate banks must check. If you want to avoid difficulties, don’t stray into any of these areas.

The first customers that regulators look for are those who provide insufficient or spurious information. When such situations arise, the money laundering alarms will ring and the bank will take significant actions to resolve the situation; usually not to your benefit.

Identification Problems

The customer uses unusual or suspicious identification documents that cannot be readily verified.
His chances of opening an account are almost nil at any bank that he can actually trust with his money if they don’t believe his identity is real.

When the customer first opens the account he gives a taxpayer ID and then later provides a different sort of taxpayer ID. For example, in the U.S. he provides an individual taxpayer identification number after earlier providing a Social Security number.

The customer uses different identification numbers with variations of his or her name.
The customer may not know this, but banks design their software to detect such frauds.

A business won’t provide complete information about the nature and purpose of its business, anticipated account activity, prior banking relationships, the names of its officers and directors, or information regarding its place of business.
Of course, a customer who conceals facts sets off money laundering alarms.


The phone company says that customer’s home or business telephone is not in service.
Why would someone opening a legitimate bank account provide a bad phone number? In fact, banks don’t believe they would; they’re probably money laundering or terrorists.

Suspicious Activity

The customer’s background differs from that which would be expected on the basis of his or her business activities.
If someone leaves his job in one field to start a business in another field may have this problem. He will need to give a convincing reason for accepting this.

The customer makes frequent or large transactions and has no record of past or present employment experience.

The customer is a trust, shell company, or Private Investment Company and is reluctant to provide information on controlling parties and underlying beneficiaries. In such cases, beneficial owners may hire nominee incorporation services to establish shell companies and open bank accounts for those shell companies while shielding the owner’s identity.
Anonymous intermediaries are one of the most common problems banks have with prospective accounts. Unsurprisingly, bank regulators don’t trust them and proper jurisdictions provide one way or another for revealing the beneficial owners of the account. Banks must know their customers and anonymous intermediaries prevent that.

You must beware of over a hundred other things that banks may use to impair your account. Deal with the professionals at Hilda Loe Associates to maximize your chances of opening a bank account.

Singapore Government Sets Small Business Controllers Astir As AEOI Comes Knocking

singapore registered controllers red tape
Image by James Petts
Until now the controllers of most local businesses could sit quietly in the background, passively earning money. To the world at large they appeare to be unconnected with the company providing their income or wealth. In the new world of AEOI and FATCA, goverments no longer condone such anonymity. These folks are now deemed Registerable Controllers” whom we describe in more detail further on.

For government departments to learn who actually controls the business is a significant chore today. So legislation will now go into effect on 31 March 2017 to rectify that problem.

From that time forward, some companies must maintain a register of their “Registerable Controllers”. Government owned companies, financial institutions and companies traded on a stock exchange are exempt.
Their registrar’s office or the registered address will keep a new document known as the “Register of Controllers”. You can find more detail on it here

Registerable Controllers

The legislation is interesting in that it doesn’t say who IS a registerable controller; it defines who isn’t one.
If you (either as a person or a company) control a company indirectly through one or more controllers, you aren’t a controller. In that case, don’t have to appear on the register. In other words, for example:

  1. If you are company A and own or have a significant interest in company B and
  2. company B owns company C,
  3. then B would have to register with C as its controller and
  4. A would have to register with B as its controller.

Because 25% interest in the company or in its voting shares is the cut-off. A company could have up to four registered controllers, if they each controlled 25% of the voting shares.

More Information

This is just a brief summary of how the law works. There are more details for the immense variety of ownership and control structures that could exist, but the principal is always the same:

  1. If the company is already statutorily required to keep a record of its controllers somewhere, it isn’t required to maintain a second copy.
  2. If an individual or legal person controls a company indirectly through one or more companies, they need only be listed at the directly owned company(ies) subject to a above.

As always, the devil is in the details, which you can find here.