Military Whistleblowers Get Little Help

The AP released a story describing the poor performance of the Department of Defense Inspector General’s Office: Whistle-blowers get little help if punished. The inspector general’s office rejected claims of retaliation and stood by the military in more than 90 percent of nearly 3,000 cases during the past six years. More than 73 percent were

Policy Lifecycles

Sumner Blount of CA puts together his thoughts on the lifecycles of policies:Policy Lifecycles: The Foundation for a Unified GRC Approach. As you can easily see, it’s a constant feedback loop, where policies are devised, controls are created and tested, and risks adjusted based on the success of those controls.

Top Ranked Codes of Conduct

Ethisphere ranked 50 Codes of Conduct. According to Ethisphere, here are some of the best: Cisco’s Code of Business Conduct “An attractive Code that passes with flying colors. Only areas that could be improved are the non-retaliation and reporting sections, and the 13,000 word length.” Alltel Wireless Ethics Policy “Excellent supportive learning aids and good

“Proceeds” From Money Laundering

In US v. Santos (06-1005), the United States Supreme Court sent confusion into what is required for a conviction under the federal money laundering statue: 18 U.S.C. 1956.The problem is the use of the word “proceeds” in 18 U.S.C. 1956(a)(1). Does “proceeds” meean gross receipts or profits? The justinces could not get together in a

Politically Exposed Person

Politically Exposed Person “PEP” is a person who may be or recently acted in the political arena of a country or has held a position in the recent past. These individuals must be tracked by financial institutions as they pose potential risk. PEP-specific compliance legislation underlines the link between corrupt politicians, money laundering and the

Specially Designated Nationals and Blocked Persons List Updated

The Office of Foreign Assets Control has just updated the Specially Designated Nationals and Blocked Persons List. It is a big list. The .pdf file is 404 pages long. The separate file of additions in 2008 is 106 pages long. Here are the new bad guys added on October 30, 2008: ABDELRAHIM, Abdelbasit (a.k.a. ABDUL

FinCEN Programs for Mutual Funds

Here are links to the text of some FinCEN program for mutual funds: 31 CFR 103.130 Anti-money laundering programs for mutual funds(.pdf) each mutual fund shall develop and implement a written anti-money laundering program reasonably designed to prevent the mutual fund from being used for money laundering or the financing of terrorist activities and to

FinCEN Withdraws Proposed Rulemaking for Unregistered Investment Companies

On September 26, 2002, Financial Crimes Enforcement Network issued a notice of proposed rulemaking, proposing to require unregistered investment companies” to establish and implement anti-money laundering programs. (Anti-Money Laundering Programs for Unregistered Investment Companies, 67 FR 60617 (Sep. 26, 2002)) In that notice of proposed rulemaking, FinCEN proposed to define the term “unregistered investment company”

Money Laundering Reporting Officer Fined

The Financial Servies Authority of the United Kindom fined Sindicatum Holdings Limited £49,000 and its money laundering reporting officer (MLRO), Michael Wheelhouse, £17,500 for not having adequate anti-money laundering systems and controls in place for verifying and recording clients’ identities. [FSA fines firm and MLRO for money laundering controls failings]  Apparently this is the first