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JOURNALS of Monte Friesner ~ Monday December 13, 2010

Financial Crime Consultant for WANTED SA >

Do not Ignore those Not-Quite-PEPs

Remember this, corrupt PEPs can also read; expect that many of them have carefully reviewed the textbook definitions of exactly what constitutes a Politically Exposed Person [PEP], and could be utilising staff members that do not quite meet the generally accepted criteria you are looking for. These senior government officials, military officers, or government-controlled company leaders may go to their trusted intermediate-level staff to move that dirty money. Are you ensuring that they do not succeed at your bank ?

Look for the following individuals, from countries known for corruption, who may be seeking to open a substantial account relationship for a PEPs "flight capital:"


  • Lawyers who work as government agencies or ministries, or outside counsel engaged by those types of governmental entities, are perfect candidates to place illicit proceeds abroad. Those without ethics, and with a significant amount of greed, might agree to deposit bribe or kickback money for their client. Though most lawyers value their law licenses too much to participate in money laundering, there are always some who succumb to temptation. Look for imaginative cover stories. Remember, Pinochet's attorney told the US banks where he was placing his client's kickback money that it was from his practice of law. Insist on proof regarding Source of Funds, and remember, court documents can be forged (a la Scott Rothstein)  but complete court files and recorded documents will uncover the deception. 
  • Senior trusted staff at the PEPs government agency might be "persuaded," for monetary consideration, to visit a financial institution in the EU or US, and drop their leader's dirty money in an account. Again, it's all about Source of Funds; if they claim an inheritance, ask for a certified copy, AND verify it through independent means. If they say it is an insurance recovery, or a lawsuit settlement, accept if, but always go to the information source and confirm that it is the truth.
  • PEPs who are military officers, are generally field grade or general officers, meaning Major or equivalent, if Army or Air Force, or Lieutenant Commander if Navy or Coast Guard. Expect military PEPs to recruit what are known as company grade, or junior, officers, meaning Ensigns, Lieutenants or Captains, as they are not universally recognised as PEPs. If one appears at your bank, check out his or her story regarding exactly how they came into possession of a large amount of money very, very carefully. Family money, they claim ? Have you checked out the family wealth on local-language regional search engines and websites ? Have you verified the family businesses ? How about their local banking references ? Be thorough, please.
  • Finally, junior staff at government-controlled companies may be forced to do their corrupt leader's bidding, through threats and intimidation, not just the lure of easy money. Again, verify everything given to you as truth. Have you checked out this "private" company, to ensure that it is not, in truth and in fact, government-owned and controlled?

There are some lists of senior staff members at government agencies on the agencies' websites, but they are far from complete. Do your homework, and no junior staffer will be able to place that bribe and kickback money through you.


WANTED SA Thanks Mr. Kenneth Rijock of World Check 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.