Category Archives: Due Diligence Lists

02.26.14
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OCC Counterfeit Check Alert: First National Bank of Bellevue, Bellevue, OH

 

OCC logo Office of the Comptroller of the Currency, Ensuring a safe and sound national banking system for all Americans
Alert 2014-13
Subject: Counterfeit Official Checks
Date: February 20, 2014		 Description: The First National Bank of Bellevue

Counterfeit Official Checks of The First National Bank of Bellevue, Bellevue, Ohio

To: Chief Executive Officers of All National Banks and Federal Savings Associations; All State Banking Authorities; Chair, Board of Governors of the Federal Reserve System; Chairman, Federal Deposit Insurance Corporation; Conference of State Bank Supervisors; Deputy Comptrollers (Districts); Assistant Deputy Comptrollers; District Counsels; and All Examining Personnel

The above-named bank has reported that counterfeit official checks using a correct routing number of041204726 are being presented for payment nationwide in connection with a mystery shopping scam.

The counterfeit checks do not resemble the bank’s authentic checks; counterfeit items may be identified by several traits:

  • The check is blue with a marbled background and dark-blue top border.
  • The bank's name appears in the top-left portion of the check, enclosed in a dark-blue box.
  • A remitter line appears beneath the bank address.
  • The following security statement is located in the top border: “TO VERIFY AUTHENTICITY SEE REVERSE SIDE FOR DESCRIPTIONOF THE 13 SECURITY FEATURES.”
  • A heat-sensitive seal is located in the bottom-center portion of the check.
  • The bottom-center portion of the check contains an oval security feature with a padlock icon and the following statement: “HEAT SENSITIVE LOCK, FADES WITH HEAT ON TOUCH.”

Counterfeit checks presented to date have been made payable in the amounts of $1,980 and $2,350 and contain remitter names of Daniel Bloomberg, David Wilson, or Alex Brown.

Potential victims are contacted by mail with a letter signed by Daniel Bloomberg. The correspondence accompanying the counterfeit check appears to be typed on a typewriter and does not include any letterhead. The letter states that the recipient has been chosen for the mystery shopping assignment for which he or she had previously applied. Recipients are instructed to immediately deposit the accompanying check and wire-transfer the majority of funds to a third party. Recipients are to contact Daniel Bloomberg at (832) 800-3607 or [hueyclerks@gmail.com].

For additional information and to verify the authenticity of The First National Bank of Bellevue’s official checks, please contact Compliance Officer Lisa Ramey by mail at 120 North St., Bellevue, OH 44811; by telephone at (419) 483-7340; by fax at (419) 483-0006; or by e-mail at RameyL@fnblifetime.com.

Consumers who receive counterfeit or fictitious items and associated material should file complaints with the following agencies, as appropriate:

  • Federal Trade Commission (FTC): by telephone at (877) FTC-HELP or, for filing a complaint electronically, via the FTC’s Web site at www.ftc.gov.
  • Better Business Bureau (BBB): The BBB system serves markets throughout Canada, Puerto Rico, and the United States and is the marketplace leader in advancing trust between businesses and consumers. The Web site www.bbb.org offers contact information for local BBBs, objective reports on more than 2 million businesses, consumer scam alerts, and tips on a wide variety of topics that help consumers find trustworthy businesses and make wise purchasing decisions.
  • Federal Bureau of Investigation Internet Crime Complaint Center (to report scams that may have originated via the Internet). Its Web site is www.ic3.gov.
  • If correspondence is received via the U.S. Postal Service, contact the U.S. Postal Inspection Service by telephone at (888) 877-7644; by mail at U.S. Postal Inspection Service, Office of Inspector General, Operations Support Group, 222 S. Riverside Plaza, Suite 1250, Chicago, IL 60606-6100; or via the online complaint form athttps://postalinspectors.uspis.gov/forms/MailFraudComplaint.aspx.

Additional information concerning this matter that should be brought to the attention of the Office of the Comptroller of the Currency (OCC) may be forwarded to

E-mail: occalertresponses@occ.treas.gov
Mail: Office of the Comptroller of the Currency
Special Supervision Division
400 7th St. SW, Suite 3E-218; MS 8E-12
Washington, DC 20219
Phone: (202) 649-6450
Fax: (571) 293-4925
Internet: www.occ.gov

For additional information regarding other types of financial fraud, please visit the OCC’s anti-fraud resource page at www.occ.gov/fraudresources.html.

 

Ellen M. Warwick
Director for Enforcement and Compliance

# # #
OCC shield The Office of the Comptroller of the Currency (OCC) charters and oversees a nationwide system of national banks and federal savings associations and assures that these banking institutions are safe and sound, competitive, and capable of serving the banking needs of their customers in the best possible manner. OCC press releases and other information are available at http://www.occ.gov. To receive OCC press releases and issuances by e-mail, subscribe at http://www.occ.gov/tools-forms/subscribe/occ-email-list-service.html.

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02.26.14
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OCC Counterfeit Checks: United Bank, West Springfield, MA

 

OCC logo Office of the Comptroller of the Currency, Ensuring a safe and sound national banking system for all Americans
Alert 2014-12
Subject: Counterfeit Treasurer's Checks
Date: February 20, 2014		 Description: United Bank

Counterfeit Treasurer's Checks of United Bank, West Springfield, Mass.

To: Chief Executive Officers of All National Banks and Federal Savings Associations; All State Banking Authorities; Chairman, Board of Governors of the Federal Reserve System; Chairman, Federal Deposit Insurance Corporation; Conference of State Bank Supervisors; Deputy Comptrollers (Districts); Assistant Deputy Comptrollers; District Counsels; and All Examining Personnel

The above-named bank has reported that two different versions of counterfeit checks, both using a correct routing number of 211872027, are being presented for payment nationwide. These payments are in connection with a variety of Internet overpayment scams.

While the counterfeit checks may resemble the bank’s authentic checks, counterfeit items may be identified by several traits:

  • The checks are blue in color, and the logo appears in blue lettering with a black background.
  • The following security statement is located in the top border: “THIS DOCUMENT HAS A COLORED BACKGROUND AND MICROPRINTING. THE REVERSE SIDE INCLUDES AN ARTIFICIAL WATERMARK.”
  • The words “TREASURER’S CHECK” or “CASHIER’S CHECK” may appear in the top-center portion of the check.
  • The bank’s abbreviated routing number located in the top-center portion of the check appears as53-7202/2110.
  • The reverse side of the check includes a security feature box and padlock icon.
  • The authorized signature appears as “Michell Winer.”

Counterfeit checks presented to date have been made payable in varying amounts between $2,400 and $4,900 and may contain remitter names of Kyle J Hagen, Tom Linkous, and Mark Hartsell.

For additional information and to verify the authenticity of United Bank’s treasurer’s checks, please contact Security Officer Victoria Graffam by mail at 95 Elm St., West Springfield, MA 01089; by telephone at (413) 787-1700, ext. 1215; by fax at (413) 788-3370; or by e-mail at vgraffam@bankatunited.com.

Consumers who receive counterfeit or fictitious items and associated material should file complaints with the following agencies, as appropriate:

  • Federal Trade Commission (FTC): by telephone at (877) FTC-HELP or, for filing a complaint electronically, via the FTC’s Web site at www.ftc.gov.
  • Better Business Bureau (BBB): The BBB system serves markets throughout Canada, Puerto Rico, and the United States and is the marketplace leader in advancing trust between businesses and consumers. The Web site www.bbb.org offers contact information for local BBBs, objective reports on more than 2 million businesses, consumer scam alerts, and tips on a wide variety of topics that help consumers find trustworthy businesses and make wise purchasing decisions.
  • Federal Bureau of Investigation Internet Crime Complaint Center (to report scams that may have originated via the Internet). Its Web site is www.ic3.gov.
  • If correspondence is received via the U.S. Postal Service, contact the U.S. Postal Inspection Service by telephone at (888) 877-7644; by mail at U.S. Postal Inspection Service, Office of Inspector General, Operations Support Group, 222 S. Riverside Plaza, Suite 1250, Chicago, IL 60606-6100; or via the online complaint form athttps://postalinspectors.uspis.gov/forms/MailFraudComplaint.aspx.

Additional information concerning this matter that should be brought to the attention of the Office of the Comptroller of the Currency (OCC) may be forwarded to

E-mail: occalertresponses@occ.treas.gov
Mail: Office of the Comptroller of the Currency
Special Supervision Division
400 7th St. SW, Suite 3E-218; MS 8E-12
Washington, DC 20219
Phone: (202) 649-6450
Fax: (571) 293-4925
Internet: www.occ.gov

For additional information regarding other types of financial fraud, please visit the OCC’s anti-fraud resource page at www.occ.gov/fraudresources.htm.

 

Ellen M. Warwick
Director for Enforcement and Compliance

# # #
OCC shield The Office of the Comptroller of the Currency (OCC) charters and oversees a nationwide system of national banks and federal savings associations and assures that these banking institutions are safe and sound, competitive, and capable of serving the banking needs of their customers in the best possible manner. OCC press releases and other information are available at http://www.occ.gov. To receive OCC press releases and issuances by e-mail, subscribe at http://www.occ.gov/tools-forms/subscribe/occ-email-list-service.html.

Subscribe / Unsubscribe to receive OCC press releases and issuances by e-mail.

OCC.gov | Helpwithmybank.gov | BankNet.gov | Feedback


08.16.13
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OCC Catches Freedom 1st “Banking without a License”

In case, as part of your due diligence, you scan those lists of unauthorized financial institutions (the US and Canada have these lists, as well as a number of other places including Ireland and Mauritius), here's one hot off the OCC”s presses:

Unauthorized Banking: Freedom 1st National Bank

To: Chief Executive Officers of All National Banks and Federal Savings Associations; All State Banking Authorities; Chairman, Board of Governors of the Federal Reserve System; Chairman, Federal Deposit Insurance Corporation; Conference of State Bank Supervisors; Deputy Comptrollers (Districts); Assistant Deputy Comptrollers; District Counsels; All Examining Personnel; and Other Interested Parties

The Office of the Comptroller of the Currency (OCC) has been informed that an entity entitled Freedom Gold Club is claiming to be associated with a national bank named Freedom 1st National Bank. Freedom 1st National Bank is not authorized by the OCC pursuant to federal law to conduct business as a national bank. It is a violation of federal criminal law, 18 USC 709, for any corporation or person acting on behalf of a corporation to operate as a national bank without authorization. All national banks are chartered and regulated by the OCC, a bureau of the U.S. Department of the Treasury.

Freedom 1st National Bank is a fictitious entity used as part of a scheme that involves soliciting consumers for semi-secured credit cards through the U.S. mail. Potential victims receive solicitations and program agreements, which may mention that Credit One Bank, N.A., is connected with the card agreement. Credit One Bank, N.A., has no connection to this entity. Victims then submit check payments in amounts ranging from $500 to $900 as deposits to obtain a semi-secured credit card with the understanding that he or she is entering into a program to rebuild poor credit. The checks are cashed by an individual using the name of Bradford C. Ege II, and the victims never receive the anticipated credit card.

This fraudulent entity is purportedly located 601 NE 11th Street, Ft. Lauderdale, Fla. The individual who claims to be the owner and appears to be cashing the victims’ checks is named Bradford C. Ege II.

Additional information concerning this matter that should be brought to the attention of the OCC may be forwarded to

E-mail: occalertresponses@occ.treas.gov
Mail: Office of the Comptroller of the Currency
Special Supervision Division
400 7th Street SW, Suite 3E-218; MS 8E-12
Washington, DC 20219
Fax: (202) 649-6450
Web: www.occ.gov

Ellen M. Warwick

Director for Enforcement and Compliance

04.24.13
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FinCEN Imposes Section 311 Sanctions on Two Lebanese Concerns

The enhanced reporting measures for Kassem Rmeiti & Co. for Exchange and Halawi Exchange Co. are effective immediately for the next 120 days. Additionally, FinCEN is issuing a notice of proposed rulemaking which, if adopted, would impose Special Measure 5 (the financial death penalty, prohibiting all access to the US financial system) on the 2 firms.

Links:

FinCEN News Release

Halawi Exhange Co. Special Measures

Finding of Halawi Exchange Co. as a Financial Institution of Primary Money Laundering Concern

Order requiring enhanced recordkeeping and reporting for transactions of Halawi Exchange Co.

Kassem Rmeiti & Co. Special Measures

Finding of Kassem Rmeiti & Co, as a Financial Institution of Primary Money Laundering Concern

Order requiring enhanced recordkeeping and reporting for transactions of Kassem Rmeiti & Co.

 

03.18.13
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OSFI Warning Notice for 7Inv.com

Another unlicensed financial services firm, this one out of Edmonton:

Name and Address of Entity

7 Inv.com
15527 Stony Plain Road N.W. NE Corner 156 Street and 101 Ave.
Edmonton AB
T5P 3Z2

Web Address / Related Entity(ies)

http://7inv.com
Whois: registered owner of web site: PrivacyGuardian.org
1928 E. Highland Avenue, Suite F104 Phoenix AZ 85016
USA
ISP: Blacklotus.net Wilmington DE USA

Agency to contact with any further information

Canadian Anti Fraud Centre and Royal Canadian Mounted Police

Note: notice has been reformatted from original release.

Link:

OSFI Warning Notice

01.16.13
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Time is of the essence

An essential question of any watchlist screening program is “when”, which actually comes in two flavors:

  • When does the company’s data need to be screened?
  • When do watchlists need to be updated?

I could weasel out of both of these by saying “in a timely manner”, of course – and I’d be right. However, let’s try to be more precise.

It is true that the frequency of data updates and screening processes is a risk-based decision. However, there are some limitations. For example, business transactions – things that transfer assets or create obligations to transfer those assets – generally have to be screened against sanctions lists “real-time”, which is to say, before the item goes out the door and/or gets finalized on the books (and gives the client access to those assets). Why “generally”, you might ask? While the most prominent sanctions regulations are designed to prevent sanctioned entities from having access to assets, some (South Africa being the one Mr. Watchlist is most familiar with) only require the reporting of suspicious transactions after the fact. If the assets are no longer in the firm’s control when the government moves to seize them, oh, well… (no, I’m not kidding – at least as of a few years ago).

I should note that transactions are less frequently screened against non-sanctions lists – especially the PEP list. A match to an off-the-books party doesn’t mean much if you can’t monitor their ongoing activity in the aggregate – with the potential exception of law enforcement lists. And you know Mr. Watchlist is not a fan of law enforcement lists because the generic nature of the names on the lists and the limited information about them – perhaps that’s why all the online most wanted lists are primarily photo indices.

Screening static data is a whole ‘nother kettle of fish. If assets are not entering or leaving one’s account, the impetus for timeliness is much less urgent. So, a weekly or monthly (or quarterly) screening against other list is not unheard-of – if you’re also screening the transactions.

There is one good argument for screening static data more frequently, though – and it’s all about staff allocation and productivity. If you screen more frequently, you will, in general, spread the manual review work out more evenly. In addition, when there are changes to lists that cause a real increase in matches, screening more frequently might allow a firm to make a rules-based false positive reduction (FPR) change that will pay more benefits sooner, reducing or eliminating the increase on the subsequent screenings.

Now, to the second question: how often do you have to update your watchlists? Economic sanctions lists should be updated as available from your data provider and as practical for your business. Translation, please?

First, there will be a lag between the time a list update is made by the regulator and the time it is made available by the data vendor. The data needs to be reformatted in your software’s format, and often will need to be enhanced to include things like matching phrases.

Second, with some applications, ongoing processing may halt or be slowed by processing a list update. Therefore, waiting until a slack period in the day (e.g. lunch time), or after hours is prudent and not unreasonable.

Let’s look to the OFAC Enforcement Guidelines again. OFAC considers how recently the listing which caused the violation was added to the SDN list as a mitigating or aggravating factor when assessing a violation. Miss an item issued two hours ago? You’re not going to get fined for that – that’s as close to a guarantee Mr. Watchlist will ever give. On the other hand, if you haven’t updated the SDN list in a month… that’s not a pretty picture to paint for the regulator or auditor.

Beyond sanctions lists, the question of how frequently to update your lists is largely up to you. For example, one PEP and adverse media provider updates its database daily, while another data provider provides weekly updates. Obviously, the sooner you can identify a potential problem, the sooner you can decide what to do about it. On the other hand, unless you’re planning on terminating a relationship that matches one of these lists, an extra day, week or even month is unlikely to make a real difference to your risk in the overwhelming majority of cases.

So, like Mr. Watchlist said, with the exception of screening business transactions, you have to handle these things “in a timely manner”. And you get to define “timely”… it’s a wonderful thing.