Published on March 7, 2014
CFCS Examination Preparation Series February 26, 2014 Part 2: Global Anti-Corruption Money and Commodities Flows Data Security Asset Recovery Presented By Charles Intriago Brian Kindle
Brian Kindle Executive Director Association of Certified Financial Crime Specialists Miami, FL
Certification, News, Guidance, Training, Networking
CFCS Certification The Credential That Shows Your Knowledge and Skill Across the Financial Crime Spectrum
About the Exam • There are 145 scenario based, four choice, multiple choice questions • Four hour exam session with no breaks, at one of over 730 testing centers or online proctored • Passing rate is 68% • Results given immediately
Preparation Suggestions • Recommended three weeks of study, if you commit 6 – 8 hours a week • Review manual in detail, including referenced materials in appendix • Prepare based on your own strengths and weaknesses • Exam based on best practices, not what you might do at your organization
CFCS Examination Preparation Series February 26, 2014 Global Anti-Corruption
What Is the Foreign Corrupt Practices Act? • US law enacted in 1977 • Two areas - Anti-bribery provision - Books and records/internal controls provisions • Enforceable by DOJ and SEC - DOJ: Criminal, civil jurisdiction over US companies, their subsidiaries - SEC: Civil jurisdiction over US “issuers”
Who the FCPA Covers • Any issuer under US securities laws • Domestic or foreign public companies registered required to file periodic reports with SEC • Domestic concerns, including US companies, citizens, nationals, residents • Person or entity that engages in any act in furtherance of corrupt payment while in US territory • International scope – 9 of top 10 largest FCPA cases are non-US companies 9
FCPA Anti-Bribery Provision • Prohibits corruptly making, offering or promising to make a payment, gift, or anything of value, directly or indirectly, to a foreign official for purpose of obtaining or retaining business
FCPA Enforcement • • 2013: 8 SEC and 19 DOJ Enforcement Actions 92 Pending Corporate Investigations as of January 2014 (FCPA Blog) Top Ten FCPA Monetary Settlements (corporations) Siemens (2008) KBR/Haliburton (2009)* BAE Systems (2010)* Total S.A. (2013)* ENI/Snamprogetti (2010)* Snamprogenti Netherlands BV (2010)* Settlements (in millions) Technip (2010)* JGC Corp. (2011)* Daimler AG (2010) Weatherford (2013)* Alcatel-Lucent (2010) 0 200 400 600 800 1000 12
Who Is A Foreign Official? • • • • • • • Very broadly defined Not limited to high-level officials Includes people acting on behalf of government entity Includes employees of government-owned or government-controlled entities - "Instrumentality" = fact-specific inquiry Includes political parties, party officials and candidates Includes employees of international organizations Effective "control" of the entity is key
Books and Records Provisions • Only applicable to issuers under US securities laws -BUT: Should still be part of robust compliance program for private companies • Issuers must "[m]ake and keep books, records… which… accurately and fairly reflect transactions and dispositions of assets of the issuer“ • Issuer also must "devise and maintain a system of internal accounting controls sufficient to provide reasonable assurances" that transactions are: - Executed and access to assets is permitted only in accordance with management authorization - Transactions are recorded in a way to permit financial statements to be prepared according to GAAP
UK Bribery Act • Enacted in 2010, effective July 2011 • Goes beyond FCPA in enforcement scope, strictness • Covers any UK citizen, all corrupt activities in UK, and any company with operations in UK • Stiff penalties – unlimited fines for corporations, 10 years for individuals • Very limited enforcement so far 15
Provisions of UK Bribery Act • Blanket prohibition on bribing any person, public or private • Specific provision criminalizing bribery of public officials – can be any “financial or other advantage” • Creates standalone offense of “failing to prevent bribery” at an organization • Organizations can avoid prosecution by demonstrating effective anti-corruption compliance 16
Anti-Corruption Compliance US, UK have provided guidance, along with many public and private-sector organizations. Best practices include: • Commitment from senior management • Effective procedures for risk assessment and internal audit • Clearly articulated compliance policies, procedures, code of conduct • Compliance program oversight by senior management with autonomy, adequate resources • Ongoing training for new and current employees, as well as third parties 17
Anti-Corruption Compliance • Procedures for confidential reporting of corruption violations and internal investigation • Updating compliance programs and policies through testing and review • Risk-based due diligence on third parties and transactions • Due diligence on mergers, acquisitions and proper integration after acquisition, merger, or joint venture 18
Third Parties • Managing third-party relationships is critical for FCPA, anticorruption compliance • Three steps to retain third parties, reduce FCPA exposure 1. Due diligence on third party's background, reputation, experience, connections with local government officials 2. Contractual provisions (FCPA representations, warranties) 3. Active oversight to ensure third party's commitment to FCPA, other laws
Key Lessons • Corrupt payments are increasingly made through complex channels – not just stacks of cash and a bag man • Third parties are a recurring risk, should be one focus of anti-corruption programs • US FCPA has international reach, has acted as standardsetter in many respects – should be understood
Practice Question Global Widget Co. recently acquired a local company in Benistan, a country with considerable state involvement in the economy and history of corruption. Before the acquisition, Global Widget hired a major international law firm to conduct a due diligence review and uncover any potential violations of global anti-corruption laws. When the review came back free of issues, Global Widget completed its acquisition. Three years later, Global Widget compliance executives were conducting their first anti-corruption training with employees from the Benistan office. During the training, Global Widget was alerted by Benistan-based employees that the distributors used by the company may be bribing local government officials. Global Widget had not conducted a review of the distributors in Benistan. When it looked into the allegations, it found widespread potential Foreign Corrupt Practices Act (FCPA) and UK Bribery Act violations. What are two weaknesses in Global Widget anti-corruption compliance program? 21
Practice Question A. Global Widget did not include its distributors in Benistan when it conducted its anti-corruption due diligence and training. B. The due diligence review should have been conducted exclusively by local counsel in Benistan because they would be better versed in the country’s culture and laws. C. Global Widget should have conducted anti-corruption compliance training as soon as possible after acquiring the company in Benistan. D. Global Widget failed to reach out directly to government agencies in Benistan to request information on any history of corrupt payments at the company it was acquiring. 22
CFCS Examination Preparation Series February 26, 2014 Data Security
Definition and Overview • Properly safeguarding, storing and disposing of the financial, personal and other sensitive data of an organization, its employees and its customers • Data security and financial crime are increasingly interconnected • • • Data breaches lead to fraud, identity theft schemes Organized crime rings turning to cyber financial crime Internal data theft and malfeasance supports range of financial crimes 24
What We Will Cover • These are the primary topics we will cover today • Types of Cyberattacks • Preventing Cyberattacks • Reacting To Cyberattacks • Data Privacy 25
Common Types of Cyber Financial Crimes • There are two main types of cyberattacks • Network based attacks • Relatively rare • What most people think of as hacking • Prevented by firewalls and ACLs • Virtual attacks • Most common • Take many forms • Prevented by security policies • Today we will focus on Virtual Attacks 26
Common Types of Cyber Financial Crimes • Types of Virtual Attacks • Social Engineering • Malware • Account Takeover • Other Attacks 27
Common Types of Cyber Financial Crimes • Social engineering • Deceiving or manipulating target into turning over personal data, confidential information • Uses similar tactics to “traditional” fraud • Often involves multiple channels – email, phone, social networks, in-person contact 28
Types of Social Engineering • These are the common types of Social Engineering Attacks • Phishing • SMS Phishing (Smishing) • Voice Phishing (Vishing) • Spear Phishing 29
Types of Social Engineering • Phishing • Using false e-mail or other electronic message to manipulate recipient into providing confidential data • There are many types of phishing attacks • • • • Data Capture Nigerian 419 Scam (Often Advance Fee Fraud) Man-in-the-Middle Attack Data captured in phishing furthers identity theft, account takeover schemes 30
Types of Social Engineering • SMS Phishing • Smishing is achieved by sending SMS messages to people with links to website that will perform a data capture • Becoming more common • More successful than email phishing since most people are less cautious about SMS Messages 31
Types of Social Engineering • Voice Phishing (Vishing) • Vishing is basically using phone calls while posing as someone in authority to elicit sensitive information (like Passwords and logins) • Most similar to standard confidence frauds from the past • Far more successful than you would expect • Sometimes Vishing refers to leveraging VoIP systems to commit a fraud, but is less common 32
Types of Social Engineering • Spear Phishing • This is very similar to a standard phishing attempt, but more targeted • Uses some personal information to personalize the communication • Far more likely to be successful than a standard phishing attack 33
Common Types of Cyber Financial Crimes • Malware • Computer Virus- a computer program that can replicate itself and extend from one computer to another through actions undertaken by the user to proliferate • Trojan Horse or Trojan- a non-self-replicating type of malware which appears to perform a desirable function of a legitimate software application but instead facilitates unauthorized access to the user’s computer system • Computer Worm - a standalone malware computer program that replicates for the purposes of spreading to other computers automatically 34
Common Types of Cyber Financial Crimes • Malware • Malicious or intrusive computer code used to obtain and transmit data to a third party • Typically delivered by a compromised or malicious website, but can be delivered within other software packages • Designed to run undetected, capture activity on a device (i.e. keystroke loggers) or allow a third-party remote access or control 35
Common Types of Cyber Financial Crimes • Account Takeover • Often the end result of other cybercrime, identity theft schemes • Occur when attacker obtains login information, credentials for an individual or business financial account, performs unauthorized transactions • Estimated $350 million to $ 1 billion lost from US commercial accounts in just the past year 36
Case Study: Target Data Breach • In early January, Target confirmed it was the victim of one of the largest data breaches of all time • • • • Full credit and debit card information on 40 million customers Personal data on additional 70 million customers Major fallout- civil suits, investigation by US Attorney general JPMorgan, other banks limiting transactions 37
Case Study: Target Data Breach • The Target attack was a multi-tiered attack • • • • • • Began with attackers purchasing “crimeware” that steals data from point-of-sale systems Attackers compromised Target web server Once server was accessed, attackers were able to upload malware to POS systems POS systems automatically transmitted information back to computers controlled by attackers Card information was uploaded to blank cards for charges, withdrawals around US Personal information will likely result in further identity theft, spearphishing schemes 38
Planning for a Data Security Program • Assess what needs protection, classify and prioritize data based on risk • Take into account physical and human aspects of data security, not just technological issues • • • Physical security is a major vulnerability, a great deal of security breaches are due to failings of internal security Must have internal security policies as well as external access policies Consider and plan for potential repercussions from data breaches and theft 39
Data Security Program Best Practices • Manage log of changes • Multi-tiered access rights, highest levels of access only from specific internal sources • Change all default, vendor-supplied credentials • Partition networks to isolate sensitive data • Strictly manage your data retention policy • Multi-factor authentication for network access • Data retention/deletion policies and process 40
Data Security Program Best Practices • Train both your employees and customers to recognize fraud attempts • Actively monitor your network • Restrict administrative connections to specific internal sources and do not allow any external connections • Implement firewalls and ACLs and keep them updated • Implement internal policies to keep all software updated with automatic systems 41
Ongoing Data Security Monitoring and Testing • Flagging, monitoring failed login attempts • Enforcing password, authentication policies • Password cracking tests • Routine log monitoring • Ongoing employee training, monitoring 42
Responding to a Data Breach • Unfortunately, it is likely a matter of time before a data breach will occur • An important part of you data security program should include how you react to data breaches • There are often legal requirements, depending on your jurisdiction, for how to react • It is far better to be proactive in controlling the narrative rather than to trying to ‘sweep it under the rug’ 43
Data Breach Response Best Practices In addition to closing the vulnerabilities that led to the breach, you should: • Identify the sensitivity of the data lost and the impact on the subjects and the organization • Establish if the data can be accessed without special software or techniques • Identify whether the data can be recovered • Notify the crisis management team • Establish a list of affected customers • Draft both public and direct communications • Prepare a PR Strategy 44
Essentials of a Data Privacy Program As custodians of personal data about your customers there are certain responsibilities in keeping that data secure. You should: • Designate an employee(s) to manage the Information Security Program • Identify and asses the risk of losing customer data in each area of the company • Test and monitor on an ongoing basis • Assure service providers with access to the data are compliant with your data security program • Know how to respond to Law Enforcement requests for data 45
International Data Privacy Laws EU Data Privacy Directive • In addition to protecting customer data from data breach, companies have a great deal of regulation as to how and when they can release customer data • While there are several international laws, and numerous local ones that depend on the jurisdiction, the EU DPD is a strong example • The EU DPD is very restrictive for protecting data privacy, it requires: • • • Consent from the customer Necessary for compliance with a legal issue Necessary for meeting a legitimate interest 46
Key Lessons • Securing human side is more important aspect of data security • Cyberattacks rely heavily on old-fashioned fraud • Data security and privacy policies should focus on limiting access to data • “Stricter” is not always better 47
Practice Question Your financial institution has been subject to several social engineering attempts over the last few weeks. While none have been successful, you worry that it might be a matter of time. To keep your network secure, you have decided to update your network security policies. What is an important step to include in your network security policy?
Practice Question A. Educate your online customers to detect phishing attempts and other fraudulent email scams. B. Disable auto deletion of old data, including access logs, and move them to an archive server. C. Only permit administrative connections via the Internet through HTTPS or SSH connections. D. Require confirmation from network Engineering before resetting any lost passwords.
Practice Question Answer A is correct as this is a recommended step in all network security policies. While not high tech or glamorous, educating your staff and your customers to recognize phishing and fraudulent emails is a fundamental and highly successful way to prevent fraud. Answer B is incorrect as this is the opposite of a good data retention policy, and has nothing to do with a network security policy.
Practice Question Answer C is incorrect as a good security policy will not allow any administrative connections through the internet, even via secure connections like HTTPS or SSH. Administrative connections are those that allow you to log into internal devices and make changes to how they function. This task should only be allowed from internal connections. Answer D is incorrect as it is not very scalable and network engineering is the wrong group to manage this anyway. There are hundreds of password resets that are performed every day by most large financial institutions. There is no way that the network engineering staff would be able to keep up with the requests. They would also have no way to determine if the requests should be approved or denied.
CFCS Examination Preparation Series January 29, 2014 Money and Commodities Flows
Financial Crime and Money Transfer Mechanisms • Mechanisms to move, transfer and employ criminal proceeds are essential to perpetrating financial crimes • Methods to move money and other financial assets are limited only by imagination of the financial criminalwire transfers, international trade, informal value transfer systems, prepaid cards, etc. • As new mechanisms evolve, pre-existing money transfer methods remain, leaving complex and growing network of threats 53
Checks and Bank Statements • While declining in use, checks in combination with bank statements can still be useful to map flows of money or other assets. • Financial crime professional should look for: • Payees on checks • Comparison of endorsers to determine consistency • Volume of checks and pattern of account use show in bank statement • Large checks or others that do not fit general use of account • Notes and numbers written on the back of a check by bank employees 54
Wire Transfers • All-purpose vehicle to move funds in all financial crime scenarios • Examples of red flags include: • Funds transfers to known tax/secrecy havens • Wire transfers with no legitimate business purpose • Customer with low account balance sending or receiving frequent wire transfers • Rapid succession of wire transfers in similar or exact amounts • Customers in cash-intensive businesses that send large wire transfers • Unusual funds transfers by correspondent banks • Customers using cash or bearer instruments to purchase wire transfers 55
Trade Price Manipulation • Also known as trade-based money laundering, continues to be a popular vehicle to move illicit proceeds • Requires two or more persons working together to move funds using combinations of over-valued and under-valued imports and exports Parties may understate the price of imported goods or overstate the price of exported goods. Parties may overstate the price of imported goods or understate the price of exported goods. 56
Trade Price Manipulation Assume Person A wishes to move money from Country X to Person B in Country Y. • Person B buys 10,000 widgets in Country Y and exports them to Person A in Country X with an invoice for $100 per widget, although he only paid $10 per widget. • Persons A or B go to a bank to obtain trade financing to finance the exportation or importation of 10,000 widgets at $100 apiece. • Person A pays Person B the $1 million that is invoiced. By this transaction, Person A is able to move an excess of $900,000 disguised in international trade. 57
Trade Price Manipulation • Why so popular? • Difficult to detect • Lack of accurate, timely data on goods and commodities pricing in many jurisdictions • Volume of legitimate trade • Able to move funds across borders • Key concern for institutions engaged in trade finance – letters of credit, factoring, etc. 58
Trade Price Manipulation • Red flags for TBML include: • Payments to vendors in cash or wire transfers by unrelated parties • Packaging inconsistent with commodity or shipping method • False reporting on type, quantity or quality of commodities imported/exported • Carousel transactions- repeated importation, exportation of same high-value commodities • Trading in commodities that do not match business 59
Money Service Businesses • Like banks and other financial institutions, MSBs are vulnerable for use by financial criminals. Some reasons for this include: •Simplicity and certainty of transactions •Global reach of network of MSBs •Cash nature of initial steps of transactions •Fewer customer identification rules are imposed • Because of the high volume of customers, reduced possibilities of verification of customer identification • Customer relationships sometimes less formal, customers rotate 60
Informal Value Transfer Systems • System for transferring value through exchange of goods or currency from one person in one country to person in another country • Not banks in the traditional sense • Maintain their own financial accounts but do not rely on global financial system to move funds • Common examples include: • Black market peso exchange • Hawala 61
BMPE Narcotics proceeds in US dollars sold to “cambistas” in US or Mexico Drugs smuggled into US and sold Cambistas swap dollars with import/export businesses that need them Cambistas pay off narcotics rings in pesos Import/exporters or cambistas purchase goods in US dollars Goods transported or smuggled 62
Money Transfer through Securities Trading • Trade in securities is multi-trillion dollar sector of global economy, can be very difficult to monitor • Securities trading can be used to launder and move criminal proceeds, also be manipulated to earn illicit proceeds • More commonly used in layering, integration for money laundering, as in wash trading • May involve complicity of broker or employee 63
Money Transfer through Securities Trading • Common indicators of suspicious activity in securities industry include: •Liquidating what would usually be a long-term investment within a short period •Using a brokerage account similar to a depository account •Opening multiple accounts or nominee accounts •Changing share ownership when making cross-border transfer •Engaging in transactions involving nominees or third parties 64
Prepaid Cards and Financial Crime Risks • Also called “stored value cards,” can represent easily transferred, highly portable means to move funds • Sometimes can be obtained with less due diligence than opening bank account or obtaining credit card • Prepaid card fraud is sometimes tied to credit/debit card fraud and account takeover schemes- stolen cards and account value is used to purchase prepaid cards 65
Prepaid Cards and Financial Crime Risks • Ways to mitigate prepaid usage for financial crime include: • Understanding how and why card will be used • Monitor reload activity, set limits on reloads • Identify source and location of reloads • Monitor number and type of cards issued to any given customer • Conduct due diligence to understand all parties involved in issuance of cards 66
Key Lessons • Channels for illicit transactions are multilayered and increasingly complex • Professionals should be able to recognize key attributes, red flags in many payment and value transfer systems • Understanding “normal” behavior in any given transaction, customer relationship is essential 67
Review Question • You are an investigative professional who has been asked look in to an import/export firm that specializes in tropical fruits, vegetables and other agricultural products. The firm is suspected of involvement in a trade-based money laundering operation. You gather the following intelligence. What would be the best indicator of TBML, and a lead to focus your investigation? 68
Review Question A. The firm’s articles of incorporation do not list its beneficial owners B. The firm has made large numbers of domestic wire transfers C. The firm has a number of invoices for exports of high-end electronics D. The firm has received a letter of credit from a large, well-known financial institution 69
Practice Question A young woman who is a national of Country A, works as a caregiver for a family in the U.S. She sends much of her earnings to support her family back in Country A by giving the amount in cash to a local grocer, whose family heritage is also in Country A. Once the grocer receives the cash, he calls his partner who runs a market in one of the larger cities in Country A. From there, the young woman's family can pick up the money sent. What is the name commonly used to describe this form of remittance transaction? 70
Practice Question A. Cash transfer B. Hawala C. Referral Banking D. Black Market Peso Exchange (BMPE) 71
CFCS Examination Preparation Series February 26, 2014 Asset Recovery
Concepts of Asset Recovery Investigations • Traditional approach: Asset tracing: Attacking profits, discover where assets are hidden and freeze them • New approach: Money flow investigation: Attacking money flow, discover how money flowed back to criminal, identify vulnerabilities, seek to interdict funds
Making the Case for Asset Recovery Operations • To justify asset recovery operation, professionals should prepare: • List of assets for which recovery is sought • Actual or appraised value for each asset • Names and contact information of persons who may have interest in asset • Listing of registered owners, lien holders on assets • Statement explaining legal theory or justification behind freezing each asset • Copies of all investigative or analysis reports in the case • Copies of all court orders previously issued in the case
Typical Members of Asset Recovery Team • Investigators • Forensic accountants • Lawyers • Analysts and support staff
Initial Considerations for Asset Recovery Team • Does asset have value? Heavily encumbered What will it cost to preserve it during process • Are there innocent owners who may impede recovery?
Equitable Weapons of Courts • Restraining and mandatory injunctions • Civil search warrants • Break and search orders • Accounting • Constructive trust • Appointment of receivers •Many others found in CFCS manual
Other evidence-gathering tools • Production orders • Search warrants • Customer information orders • Account monitoring orders • Disclosure orders, subpoenas or summons
Typical records kept by financial institutions • Transaction and wire transfer records o ID requirements on transactions over $3,000 • Know Your Customer and other customer data o Due diligence reports o Photo IDs o Signatures o Information on customer relationships o Information on source of customer’s wealth or funds 79
Regulatory Records • Subpoena Required - Bank Examination Records - Applications Records - Ownership and Location Information - Financial Data 80
Receivership • Serve to locate, safeguard, recover assets • Trustees, receivers, administrators, liquidat ors, officeholders • Step in shoes of directors, entitled to all information 81
Subpoena Tips • Comprehensive production of records - Subsidiaries, affiliates, etc. - Use “bank terminology” • Wire transfers - Fedwire or SWIFT - Authorization document, letter or form 82
Asset forfeiture • Criminal forfeiture - against the defendant or person • Civil forfeiture - in rem’ - against property - proceeds, instrumentality of crime • Substitute assets 83
Asset forfeiture 84
International Assistance • Freezing Orders - Mareva injunctions • Pure Bill of Discovery - Norwich Pharmacal • Production Order - Bankers Trust Orders • Stand and Deliver - Anton Piller Orders • Lis pendens • Letters rogatory 85
International Assistance Mutual Legal Assistance Treaties (MLATs) • Taking testimony of persons • Providing documents, records and evidence • Service of documents • Locating or identifying persons • Executing requests for search and seizure • Identifying, seizing and tracing proceeds of crime 86
International Assistance • Foreign ministries, nation's chief legal officer • Embassies – yours and theirs • “Back channel" assistance, for location of witnesses, authentication of records • Direction to useful public sources to uncover true beneficial owner 87
Enforcement of Judgments • Uniform Foreign Money Judgments Recognition Act • Domestic judgments often are enforced in other countries based on "comity" 88
Liability of Third Parties • Third parties can be valuable, if difficult, targets for asset recovery operations • Preliminary questions on liability - Identify payees - Find related entities - Check public records -Understand regulatory requirements 89
Liability of Third Parties • Preliminary questions on liability - Intelligence sources - Affiliated entities - Gratuitous donees - Fraudulent conveyances - Overpaid investors 90
Possible Third Party Targets • • • • • • Banks Broker-dealers, investment advisers, etc. Company directors Employees Lawyers Auditors and certified public accountants
Key Lessons • Understand viable targets for asset recovery options • Understand information sources, including open sources like corporate registries • Many asset recovery operations have crossborder component – recognizing international tools is essential
Review Question • You are employed as part of an asset recovery team seeking to recover funds from a corrupt government official indicted for bribery and embezzlement in Canada. You have identified financial accounts and properties the official held in several common-law countries, including Australia and the UK. You are concerned that the official may attempt to transfer funds out of his accounts or dispose of properties while legal proceedings against him are still underway. What is one legal tool you could use to prevent the official from transferring these assets?
Review Question A. Letters rogatory B. Anton Pillar order C. Mareva injuction D. Production order
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