You're absolutely right. BTW Behaviour Dynamic Models are particularly powerful things. Let's supposed a webshop does $300,000 a month. Let's suppose that it varies with a given standard deviation (a standard deviation for a particular set of data tells you how much the daily deposits vary by). Now lets supposed that the webshop shows that for two days out of the month, the deposits are way above the normal plus a standard deviation. In other words the deposits suddenly start to swing upwards from normal behaviour. If normal behaviour is resumed, then those transactions are suspicious. It looks like someone is laundering money. A computer monitors these transactions with a model. The model is built from the customers previous history.
But as you point out, that is after the fact. KYC also involves knowing who deposited those funds into your legitimate business, and the source of those funds. I am sure that the webshops do not do due diligence. They take everyone's money. I see illegal Jamaicans buying numbers and I'd like to examine the due diligence done on them.
And it is indeed laughable to think that you can deposit a businesses money into a chartered bank if your partner has been indicted by the US Dept of Justice.
You're too funny. My master's degree is in Machine-Learning to identify Customer Transfer Models for profiling and Transactional Behaviour Dynamic Models from Big Data on client accounts for KYC Compliance Planning. Look that up on Wiki! LOL!
Prior to 2011, ACAMS, which has international reach in publishing KYC and AML standards, published a Capability Maturity Model that re-stated Initial, Repeatable, Defined, Managed and Optimized models for KYC that eliminated specific rubrics and instead offered a simplified model with leeway for country-specific implementation. The specificity of the rubrics were taken away with the new model, and instead the compliance onus was placed on member implementation and not an ACAMS implementation algorithm. I am not talking about Bahamian legislation, I am talking about international KYC banking compliance procedures. And as to your questions, yes, each jurisdiction can have its own implementation procedure as long as it aligns with the ACAMS model of high level compliance. It is a huge problem for financial institutions, because in the old days, one could tick off a check list of compliance items. Now, one must insure KYC compliance without being specifically told how to do it, and if you get it wrong, you are censured and blacklisted. Generally, the compliance procedures are inspected but not tested rigorously until this is a compliance failure.
So in effect, different banks can have different implementation algorithms for KYC and they still all adhere to the high level KYC principles. The efficacy of the fit and form but not the function of KYC implementation models are not externally validated and verified with any rigor until there is a compliance failure.
I would kindly suggest that you familiarise yourself with international standards, not Bahamian ones. I would also point out the KYC due diligence, several years ago, was transferred from a central body with rubrics to the individual institutions themselves, relying on their compliance procedures instead of central codified ones. In other words, it "we offer guidance, but no directives, and if you are wrong, it is your fault". That is why the Canadian banks are barring these essentially illegal funds. Your admonition about arming one's self with knowledge should be taken personally and not be skin deep -- with all respect.
How can you say that KYC is effected with a webshop account that is opened with dubious paper credentials by a disinterested employee who merely glanced at documentation when the account was opened?
For those having trouble understanding the ramifications of banks accepting webshop money, let me explain.
With the new anti-money laundering rules, if I show up to open a bank account and I have a whole pile of money, according to world standards, I must show that I obtained that money by legitimate means. The source of my money is looked at. If I run a business that is accountable to some jurisdictional law, then that money is declared legitimate. If it is the cash takings from a business, then that business can be audited to make sure that the sales of actual merchandise reflects the amount of money being deposited. If it is from a sale, transaction or such, there must be an audit trail as to the origin of the money. This is part of KYC or Knowing Your Customer.
Web shops do not do KYC on behalf of their clients. If the mafia or a criminal element, or a PLP drug smuggler or cabinet minister stealing from his ministry, puts his money into a webshop account, the webshop owner can take his money, deduct a fee, and put it into the banking system, making the money legitimate. Webshops do not have to record or disclose the identity of depositors. Nor are they compelled to reveal the identities of the depositors to foreign law enforcement agencies making inquiries, as outlined in the various Tax Exchange Information Agreements that the Bahamas has signed with over 25 countries. Hence they are highly susceptible to criminal money being laundered. They could even be doing it unknowingly. Hence in this world full of narco-fueled terrorism, real banks won't go near tainted money.
The PLP are too stupid to understand this, and they are just paying back political debts to the webshops that financed their election wins. There is not one shred of patriotism among them, doing right for the good of the country. If they wanted to capitalised on the gambling penchant of human beings, they should have started their own national lottery, and jailed the likes of Bastien, Flowers et al. Their moral compass is so skewed that the country's legislative agenda is driven by webshop (gambling) and Nygard money (stem cell pseudo-science). Truly a country for sale, and nothing has changed since the days of Lynden Oscar Swindling.
Who ever made the comment about this man not being the brains behind the operation is right. Banks have to follow a KYC (Know your customer) chain of compliance. That means they have to know the origin of the money and the individuals behind it -- not just from the webshops, but from the customers of the webshops as well. The webshops do not do KYC and hence they are perfect venues for money laundering. Nobody launders money through a casino because of strict oversight. If the CEO of Island Luck can't see this, he indeed is a low fence - one brick short of a load. The figurehead chairman should know this as well.
I wonder how it feels that if your name is Julian Brown or Warren Davis or any number of Bahamians, that you could never visit the United States again. Either you will be turned away at the border or you will be led away in handcuffs.
banker says...
This news went national on the Canadian Broadcasting Corporation network.
On 88-year-old Canadian killed in home invasion
Posted 7 April 2015, 3:20 p.m. Suggest removal
banker says...
The sad part is for the Bahamians, is that the bank jobs are the true middle class jobs.
On Bahamas is ‘catching hell’ under PLP
Posted 7 April 2015, 12:51 p.m. Suggest removal
banker says...
You're absolutely right. BTW Behaviour Dynamic Models are particularly powerful things. Let's supposed a webshop does $300,000 a month. Let's suppose that it varies with a given standard deviation (a standard deviation for a particular set of data tells you how much the daily deposits vary by). Now lets supposed that the webshop shows that for two days out of the month, the deposits are way above the normal plus a standard deviation. In other words the deposits suddenly start to swing upwards from normal behaviour. If normal behaviour is resumed, then those transactions are suspicious. It looks like someone is laundering money. A computer monitors these transactions with a model. The model is built from the customers previous history.
But as you point out, that is after the fact. KYC also involves knowing who deposited those funds into your legitimate business, and the source of those funds. I am sure that the webshops do not do due diligence. They take everyone's money. I see illegal Jamaicans buying numbers and I'd like to examine the due diligence done on them.
And it is indeed laughable to think that you can deposit a businesses money into a chartered bank if your partner has been indicted by the US Dept of Justice.
On Banks ‘reckless’ on web shop bar
Posted 7 April 2015, 9:13 a.m. Suggest removal
banker says...
You're too funny. My master's degree is in Machine-Learning to identify Customer Transfer Models for profiling and Transactional Behaviour Dynamic Models from Big Data on client accounts for KYC Compliance Planning. Look that up on Wiki! LOL!
On Banks ‘reckless’ on web shop bar
Posted 6 April 2015, 10:46 p.m. Suggest removal
banker says...
Prior to 2011, ACAMS, which has international reach in publishing KYC and AML standards, published a Capability Maturity Model that re-stated Initial, Repeatable, Defined, Managed and Optimized models for KYC that eliminated specific rubrics and instead offered a simplified model with leeway for country-specific implementation. The specificity of the rubrics were taken away with the new model, and instead the compliance onus was placed on member implementation and not an ACAMS implementation algorithm. I am not talking about Bahamian legislation, I am talking about international KYC banking compliance procedures. And as to your questions, yes, each jurisdiction can have its own implementation procedure as long as it aligns with the ACAMS model of high level compliance. It is a huge problem for financial institutions, because in the old days, one could tick off a check list of compliance items. Now, one must insure KYC compliance without being specifically told how to do it, and if you get it wrong, you are censured and blacklisted. Generally, the compliance procedures are inspected but not tested rigorously until this is a compliance failure.
So in effect, different banks can have different implementation algorithms for KYC and they still all adhere to the high level KYC principles. The efficacy of the fit and form but not the function of KYC implementation models are not externally validated and verified with any rigor until there is a compliance failure.
Does this explain it for you in greater detail?
On Banks ‘reckless’ on web shop bar
Posted 6 April 2015, 4:02 p.m. Suggest removal
banker says...
The difference is Al Qaeda, 9-11, FATCA, the John Doe subpoena, ISIS, ... the world has changed considerably.
On Banks ‘reckless’ on web shop bar
Posted 6 April 2015, 11:26 a.m. Suggest removal
banker says...
I would kindly suggest that you familiarise yourself with international standards, not Bahamian ones. I would also point out the KYC due diligence, several years ago, was transferred from a central body with rubrics to the individual institutions themselves, relying on their compliance procedures instead of central codified ones. In other words, it "we offer guidance, but no directives, and if you are wrong, it is your fault". That is why the Canadian banks are barring these essentially illegal funds. Your admonition about arming one's self with knowledge should be taken personally and not be skin deep -- with all respect.
How can you say that KYC is effected with a webshop account that is opened with dubious paper credentials by a disinterested employee who merely glanced at documentation when the account was opened?
On Banks ‘reckless’ on web shop bar
Posted 6 April 2015, 10:30 a.m. Suggest removal
banker says...
For those having trouble understanding the ramifications of banks accepting webshop money, let me explain.
With the new anti-money laundering rules, if I show up to open a bank account and I have a whole pile of money, according to world standards, I must show that I obtained that money by legitimate means. The source of my money is looked at. If I run a business that is accountable to some jurisdictional law, then that money is declared legitimate. If it is the cash takings from a business, then that business can be audited to make sure that the sales of actual merchandise reflects the amount of money being deposited. If it is from a sale, transaction or such, there must be an audit trail as to the origin of the money. This is part of KYC or Knowing Your Customer.
Web shops do not do KYC on behalf of their clients. If the mafia or a criminal element, or a PLP drug smuggler or cabinet minister stealing from his ministry, puts his money into a webshop account, the webshop owner can take his money, deduct a fee, and put it into the banking system, making the money legitimate. Webshops do not have to record or disclose the identity of depositors. Nor are they compelled to reveal the identities of the depositors to foreign law enforcement agencies making inquiries, as outlined in the various Tax Exchange Information Agreements that the Bahamas has signed with over 25 countries. Hence they are highly susceptible to criminal money being laundered. They could even be doing it unknowingly. Hence in this world full of narco-fueled terrorism, real banks won't go near tainted money.
The PLP are too stupid to understand this, and they are just paying back political debts to the webshops that financed their election wins. There is not one shred of patriotism among them, doing right for the good of the country. If they wanted to capitalised on the gambling penchant of human beings, they should have started their own national lottery, and jailed the likes of Bastien, Flowers et al. Their moral compass is so skewed that the country's legislative agenda is driven by webshop (gambling) and Nygard money (stem cell pseudo-science). Truly a country for sale, and nothing has changed since the days of Lynden Oscar Swindling.
On Bank support for web shops
Posted 6 April 2015, 9:57 a.m. Suggest removal
banker says...
Who ever made the comment about this man not being the brains behind the operation is right. Banks have to follow a KYC (Know your customer) chain of compliance. That means they have to know the origin of the money and the individuals behind it -- not just from the webshops, but from the customers of the webshops as well. The webshops do not do KYC and hence they are perfect venues for money laundering. Nobody launders money through a casino because of strict oversight. If the CEO of Island Luck can't see this, he indeed is a low fence - one brick short of a load. The figurehead chairman should know this as well.
On Banks ‘reckless’ on web shop bar
Posted 5 April 2015, 2:31 p.m. Suggest removal
banker says...
I wonder how it feels that if your name is Julian Brown or Warren Davis or any number of Bahamians, that you could never visit the United States again. Either you will be turned away at the border or you will be led away in handcuffs.
On Broker ‘acted in good faith’ on $400m fraud
Posted 5 April 2015, 2:10 p.m. Suggest removal