Sanitised case 23
An account was opened in 2008 for the subject in with the disclosing institution. The subject advised that they were self employed but working for a Consulting Group (CG) in an advisory capacity.
The account only ever received four credits totalling just over USD 1, 000,000 – all by order of the CG. Of these four credits, three were made from Germany and the fourth came from a bank in the USA.
The following was noted by the disclosing institution:
The subject had no business address.
Earning sums in excess of USD1, 000,000 but did not have any invoices or contracts with CG.
Claimed to have worked multi million/billion pound companies but did not have any thing to back this up, no invoices, contracts, headed paper, business cards etc. Did not like the disclosing institution us to contact – always wanted to call the institution — only wanted to meet in a public place not at home or an office. The subject was happy for the institution to contact the MD of the consulting group but only after informing the subject first.
Due to the lack of KYC and compliance with the subject, the account was closed and the funds were transferred to an account held in the subjects own name with another institution in Luxembourg.
It was established that the subject was of Russian descent as was the managing director (X) of CG. The website for CG appeared ‘amateurish’ with basic grammatical and geographical errors. Further enquiries revealed that the City of London Corruption Unit and the FBI were actively investigating X. Further intelligence is that X, a banker with autonomy to place loans with eastern bloc countries has done soand converted the money to his own. The loans would be made through consultancy firms such as CG.
The disclosing institution was able to provide specific information relating to the payments made to the subject to X. This information was the lynchpin resulting in the arrest of X, who has been since been charged with fraud/corruption of several million dollars.
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