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JOURNALS of Monte Friesner >

Financial Crime Consultant for WANTED SA >

Monday November 15, 2010 >

WANTED SA is pleased to post articles ** With the Compliments of Mr. Kenneth Rijock.  


DIFFERENT ANGLE by Kenneth Rijock

Financial Crime Consultant, for World-Check

Sources inside Venezuela have asserted that criminal organisations there are effectively laundering their proceeds of crime through the energy sector. You will recall that I have previously reported that oil brokers purchasing that commodity from Venezuela are frequently ordered and directed to divert up to 50% of the commissions earned on their sales to third parties located inside Venezuela, generally PEPs and former military officers. This is surely a FCPA violation if the broker is operating out of the US. This new development, though, which is detailed below, is very disturbing.

Here's how it reportedly works, and why transactions originating in the government-controlled petrochemical industry could now be considered high-risk:

  • Narcotics proceeds, in bulk cash (US Dollars) are being accepted by corrupt government employees.
  • A cheque is prepared, by the governmental entity, less a "commission", in the name of the narcotrafficker, or anyone else he wishes, and is made to appear that it was payment for goods or services.
  • Local banks, taking the document as a normal payment,  readily accept it, thus laundering the criminal proceeds.

Therefore, if you are a compliance officer at a bank where such cheques are frequently deposited, demand that the customer document a factual basis for the payment; invoices are rarely sufficient. require that he or she show you evidence that sufficient stocks of goods were purchased to support the sales, or other proof that will satisfy you that the payment is for a real, and not phantom, expense.

**   The facts and opinions stated in this article are those of the author and not those of World-Check. World-Check does not warrant the accuracy of any facts and opinions stated in this article, does not endorse them, and accepts no responsibility for them.

WANTED SA thanks Kenneth Rijock and all the parties, law enforcement and securities forces who have contributed to this article and their sincere opinions and statements.

WANTED SA states that the facts and opinions stated in this article are those of the author and not those of WANTED SA. We do not warrant the accuracy of any of the facts and opinions stated in this article nor do we endorse them or accept any form of responsibility for the articles.