Unlock Online Signature Licitness for Investment Contract in United States

How to eSign a document: online signature licitness for Investment Contract in United States

spoken and i'm i'm concerned as a person who did the homework the majority of them are not here and i i really wanted them you know for us to have this discussion um a lot of persons are creating scenarios rather than using cases or case studies or they're taking pieces of what i said in the class i'm not going out and doing the research and saying ing to you know the national guardian on such a such a date this was the situation it's alleged you know so we do you don't get any points for creating a scenario you get points for real life cases um another thing i saw is that i know that all of you and what's up who and you may um find a what should i call it a a past writing or looking at past papers and taking information i had four at least four persons with the the same wording okay and so you want to be very careful of that and i had two persons with a particular quote that was used previously and what happens is we're preparing you for for ica when you write these essays by c the 3 500 words um the i say requires you to format and reference in a particular way and so that's why i sent you a copy of what their requirements are and the type of referencing they use because you could get up to 40 percent of failed papers because of referencing so i had asked you to go through those pages and look at the reference and style and use that in your paper i see people copying and pasting links in their papers you don't do that okay and you put the footnotes and you you know you go on um and you reference properly um what happens when you submit a paper in ica is there's a system called truth like turning or truth in i can't pronounce it properly but you upload your paper into that system and it tells you which percentage of your um paper is copy and paste and then it then tells you this percentage is behind me law you get no points for rehashing i mean presents a whole page no sense okay you get no points then it tells you this section of the paper has been submitted by another student previously and it gives you a percentage for each of these issues and if you get 50 you might as well don't submit that paper because you you will fail okay so we want to move away from the copy and paste i 100 you know it is easier i support working together however you cannot work together and walk away with the exact same information as your colleague that's in the same class as you and still expect to get full points you won't okay so like i said i saw four essays but exact wording then i saw a lot of rehashing of lois that gave you no points a lot of scenarios created rather than going online and looking up um actual cases okay and then the question starts off by asking you um to use the eggman cases and some persons didn't even use the a1 cases they did no overview of the three cases so i i don't know but like i said this is very important because more than likely this will be the mandatory question on the final exam which means everybody has to answer it and it's worth 20 points if you don't get at least 10 points on this question more than likely you won't pass the final exam so we're going to dive in a little deeper to get as much information as possible and make sure that we are all on the same page okay are you all there are you on the property yes um [Music] yes yeah yes ma'am okay good good so we have to move away from this bullet talking for the entire class and we need persons to participate in the chapter and tell us what the chapter is saying again like i said this chapter 6 is just a refresher um we know that from recommendation 10 all the way to recommendation 24 all ideas of customer due diligence and so we want to ensure that everybody has that down back and and we understand so before they shouldn't have to say anything about chapter six we'll go through the class and and let everybody give us um some information about um due diligence and then we will um look at the paper the homework to make sure that everybody is on track with the mandatory question okay so um let's start with um newspaper or civic organizations four more classes after this before you blink this is going to be over please i have a questionnaire yes go ahead i don't finish a lot of my work correct you have your points for your civic organization that's the i deal with that from the second class okay let me look at my list leanne what's for what a name i can't and the rest of um people in another class yeah okay all right just checking my temperature okay yeah and so you and you did your homework right so yes and you've been participating with the newspapers on the um conversation so yeah um he was welcome to you okay thank you hello hey thank you i don't want you all to now just stop now that's it i but i was expecting at least 10 more points but oh i gotta say i guess you trust me did you understand from the comments what was missing yeah that was straightforward what you said was straightforward i didn't use any readment case you're right so that's my bad right and so we have to be careful when we read these questions these questions normally have three parts here okay and and i had to fight for your points because i i realized i said she okay okay yeah so sorry go ahead dimitri so we don't know we don't have another chance no chances because the last class the last class ruined or every courtesy that was offered with you i told you we had a person who did at least 10 revisions to one essay and demanded that it be marked when she after she finished revising it 100 guys and so that's why one or two you sent me the and said let me know no you have to go and get help or tutor or whatever yeah wow okay so okay yeah all those courtesies got after we got 100 reports from the last class that means if we get a low mark that means basically he stuck with it remember now before if you didn't get at least 70 i would send that to you until you just redo it so i can give you a reasonable grade but right i know i was told to stop that as well look i got reported for that oh wow i got reported i said okay i i was reported that i'm making um persons due to work two and three times i said okay fine let me give her about 30 and i gave it because i'm gonna lie i can be honest i you see when i missed the class right that day um i didn't read i didn't listen to the youtube until after i submit i can be honest i did not i think oh my god when i have submitted it that's when i realized and i went and listened to it i was like oh wow yeah all the answers right there right so before you answer any essay you listen to the recordings just as a refresher and then when we get to the remote class that it seems like persons are now showing up to the review class expecting to get the answer rather than going out there and doing research you know so you would know how to study and so all of that cut out please if you whatever topic if your topic it was from um class one you go back to class one and you listen to risk or the fatf or sanctions don't come to the review class say it i didn't know and i going online i know everything you know you have to do some research but the majority the answers come from the book okay good all right your mom go ahead jamaa good afternoon everybody um two things um one mr bullet um with the mandatory home with dumb question one um the issue i had was in i had to cut back a lot of the wording because i was over so i had to try and condense so um that was my that wasn't that was my problem but my paper um and secondly i have my um civil organization i would like to present okay and get your five um with ica they allow you to go over 10 and under 10 anything over that you penalize okay so with those um cases at the back of the book condense it as much as possible some people wrote one line is on them and i don't know why you were supposed to be able to know which case they was even talking about but no more than a paragraph to you know you know what i mean to explain exactly what is happening unless you you want to do a comparison so does this happen in the bahamas or only one person talk about all the uh champs and and with uh somebody say sugar hill and something that one person as if we don't have strip clubs here that's famous i was surprised that was uh okay yeah i was like but i mean anybody else know about sugar oh yeah interesting i thought she made that one up i i had i said i'll [ __ ] check it i i don't know okay but but good work but god indira and and and that's what you know how i was able to fight for your extra points i think she's well aware yeah you have i like okay okay the whole class must go together i guess you'll do it i guess i can line that up no that's okay that's okay that's a joke yes i do you have to verify and do his homework oh lord okay okay but good work okay jamal go ahead come get your five percent so you could be in line with these ladies so at the top of the class that's wrong um on on tuesday evening i attended a toastmasters meeting for club 7178 um the topic for the night was time and time wait for no one uh the toastmaster of the day was chanelle williams and toastmaster nisha knows she gave the word of the day the word of the day was abscond a-b-s-c-o-n-d which means to leave hurriedly and secretly typically to escape from custody or avoid arrest um the topic for the evening was pass me the keys three pathways to home ownership um which was presented by toastmaster lynn clark um the first pathway she she talked about was purchasing a move in a move-in ready structure well she said how the benefit one of the benefits is you would have less property maintenance and some of the drawbacks she spoke on was an increase the increased asking price a high down payment and she said how the layout of the home or the property may not be to your standard and she also spoke on how moving properties and i saw our praise between 350k to 800 000 then she went to her second pathway where she's she speaks on building your home from the ground up where she said the the number one benefit is you get to design your own and the major drawback there is that it's time consuming and her last pathway she spoke on was purchasing a distress asset where she spoke on the benefits of it being you would have a reduced asking price and a reduced down payment and your drawbacks would be an increase renovation cost and difficulty securing funds and she says he spoke on how distressed property is for our prayers between 50 000 to 250 000 so that was the like the meeting in a summary and a quick summary but it was a pretty informative meeting especially as a young man who seeking uh when they get home so i i enjoyed the meeting okay very good and do you plan to join um as of right now maybe not so but then maybe in two years or so possibly okay did you introduce yourself yes mom they are the um introductory portion at the beginning okay okay good very good yes that was very informative jamal i i really does this group here if i have to join toastmasters i will join the same club right here that's the fun club if you all go in and like to meet people that's the that's the club for you to be in if you look conservative you'd have to go on the other one um i can't remember the one that's happened on thursday night i like no man dynamic the same one you said to me to you that's the one yeah that's what i'm saying if you're laid back that's the cool to you i like the next one the tuesday okay good i joined actually i had joined i must be okay that's excellent i'm very happy that um you know y'all are getting informative information and even if you don't join like you say there are various goals that you would have set and these topics you know they they help and so i'll get to know the right people networking and get your name out there okay so very good jamal thank you for sharing claudia go ahead i was supposed to attend eating and it's the second week the person never get back to me so i'm actually now to me to meet you to me syria i swear to write on demetria pardon is it to me theory or to be trio dimitra tamitra um if it's okay can you extend an invitation to your group for me please but for sure this person can't get me to run around and i i like it i really like it okay okay so i i'll i'll reach out to you um yeah try to attend the meeting this week you know i'd love to read the paper okay good go ahead and share with us um there's a lot of things that happened this week um one of the main things oh you can't sing an eye in glass um one of the main things that um i noticed is everybody's talking about we still talking about the rise in fuel and i noticed that um the people are saying that ppl did not capitalize on not the government sorry to not capitalize on fuel for bp also you know um in all actuality we're kind of looking to watch a few uh electricity bills increasing well you know they did after they did freeport you know freeport ran up by three percent they did put it out there in the news and there was complete outrage and then they retracted the statements right but it looks as if right now they have no control over it because they have no control over the price absolutely listen we have this big investment services board shell initially when gas rose stayed at 552. you know why because they bought futures what are the traders that work for the uh bahamian government and the investment person is doing what are they doing how possible they do not know that's what the article was about the article was like how no one advised the government to get you know what you call future for bpm right how possible are you using all this gas every day come on understand your oil and then you know another topic that i don't see it make the news yet but you know books are now duty-free or allegedly about to be done listen once you is again let me tell you [Music] if you have a fishing business license you go and apply for the duty free card and they look at you and you could bring in stuff related to fishing so technically it was always duty-free as far as i'm concerned if were a fisherman and you knew that concession was out there you would you know what i mean yeah you would go and do it anyway so i mean it moved from they had a death 10 but everybody applied for the concession before i don't know if technically that was a gift i think they just put it in there to make it look good that's how i feel apartments miss palette you know we already used y'all making bones duty-free but bad basket items still have fat oh to go minutes i have to go minutes go on okay they ain't know what they was gonna get okay so don't be sorry now that's it you're literally nobody force yours miss fuller menace needed to go but not the afternoon menace needed to go yeah that's a good point because he's too rude he he is a different level of human i agree okay no but think about it now he's a little bit stricter because he's a millionaire he's self-made he made all his money i mean he did have some inheritance from his parents but he didn't mess that up he developed that and and multiplied that so you know and he is a little bit more disciplined more stricter than you know what people would you know want i support castro 100 i don't think he had a total disconnect but let me tell you about cuba in cuba you all bred basket items you go you get your um loaf of bread your milk your butter and everything for 15 cents gas for tourists is 25 cents and for citizens is 15 cents um you could walk to cuba at any hour tonight there is the army which is like our defense force on every corner okay the crimes are so severe if you going to show up in t if you get 15 years so crime is very low they are considered the sex capital of the world and they have the lowest aids and std rate in the caribbean how possible so i think to a certain extent persons need a little bit of communism i mean it's so bad okay no no communism is life okay you have to look at the results you got to look at the results the old cubans they support castro the new the young cubans they want internet and this and all these things and so they don't want to be restricted yes just like the bahamas a lot of old people was like okay fine lock us down we ain't got to come out of too dangerous out there the young people going crazy over the lockdown the menace is a doctor think about it man i mean people who have a relationship with god we had lawyers every prime minister or businessmen y'all don't think it was the appointed time that at the time was a pandemic the first time yeah any of our lives there was a doctor that's a quad worker okay because he went where so what state when it where his daughter was the doctor when he got over it i take atlanta i'm not sure i think it was atl okay and do you all not see the amount of traveling in the pandemic when people you'll be paying for this you know every week is an entourage and pictures and they stand in five star hotels and i went five star star meals i it ain't even been a year yet and they don't travel more i mean this only used to be fred now it looks like the whole party catch gets onto this anyway you all vote them in you're voting well trust me i'm very disgusted with it just being important yeah yeah they go to me so you'll see what happens god speed us all right okay anita go ahead anita good afternoon miss bullets good afternoon class all right i just wanted to um speak on the civic organization that i um attended okay go ahead okay and i just wanted to confirm also miss bullet that i actually got my points for the newspaper article let me look at this you can yeah you can just let me know because i know i presented already right yes your name is on the message okay thank you um i actually attended the rotary club of nassau meeting on last week um the guest speaker was alfredo gonzalez he's the international sales manager for frontier airlines and he basically spoke about um of course frontier airlines being in operation for 27 years uh he mentioned that the company opened 11 international destinations including the bahamas the company is all about the green initiative meaning their goal is to do something about protecting the environment he also touched on low airfare rates particularly after covet due to the fact that it separated families businesses and people and he said that their fares were rated based on the population size and the needs of the people he also explained um gone other days when persons had to pay 1700 for a ticket based on the destination for one individual and was unable to afford it so they're at a point now where they're kind of uh lower lowering airfares to accommodate uh the pockets of of many and he also touched on the awareness on saving gas and saving animals in danger of extinction and the reason for this well actually ing to him on their airline or on their plane the tail of their plane they have images of animals on it and they he also mentioned um negotiations with spirit airline to purchase that and he said if they were to win the bid they would be the fifth largest airline airline company and at the end of the presentation they had i think the rotary have an upcoming change over party event so he donated two tickets to that and then they went in to their regular question and answers and their parking lot is what they call it and i did introduce myself i did say that i'm from the intermediate compliance class from biffs okay excellent excellent and so you you found it beneficial and you listen again or look into joining i've actually been attending that particular um rotary meeting since i um started the compliance course but i don't think i'm gonna attend the rotary because i'm already a part of kiwanis so yeah so i don't think i'll i'll attend that i didn't want to talk about kiwanis because i'm already a part of it okay understood okay so very good i'm happy that you found it beneficial yeah i saw an article about santeya um you know in the big dubai spirit and the article was a very nice two of the worst um airlines is in terms of customer service uh are thinking about joining say they really need to revamp their customer service um you know i guess offices in order to be able to you know make it in the market yeah but that's interesting to know that they've been um open for many years okay and then has anybody been on franti i see that they're leaving from nassau now has anybody tried it as yet or no mom good i'm hi um okay i see don nicola major she's saying her electricity is off so she's unable to attend right now log in okay yeah mice is off too yeah so tell her yes this is the rule also sasha stewart isn't able to attend class today okay yeah thank you yeah yeah mine's just blank thankfully because i was i was thinking what if i could do this class for my phone yeah but thankfully bc come right back on you know one piece of thunder and that was it that was it okay guys so very good um like i say four weeks left please don't um let it sneak up on you and you know um we not get what we need done in a timely manner to be able to sit in the exam comfortably and i promise you it really really just makes a difference to be there not worrying about you know um how many points you need to just pass at least you should say no matter what i decide no i pass it but i'm aiming for foreign aiming for a higher grade okay so please don't let the time pass you by okay so chapter six so we only have one two three four five six persons but um i'm hoping this is because you know persons are gonna listen at a later date or we are already sitting comfortably um but you know with due diligence and so there isn't much that we need to cover so we'll start with clavia claudia please tell us um after reading the chapter what would was he a take away with chapter six thanks for letting repeat the question again what was your take away with chapter six after reading chapter six what's your takeaway well i think this is question three and the homework right has to do with respace or something like that yeah yeah i'll pull up the homework okay so actually i'm doing i actually started my paper and so it had to do a lot with um the race-based approach and you know how you question three say recommendations custom countries should apply risk based approach to ensure that measures prevent and mitigate money learning and terrorist terrorist financing so yeah and and so on so i've been doing some research on that uh in alignment with what's in the book so um the main two challenges is kind of straightforward you know you do your leg work make sure all your crop your eyes i thought it is across don't miss nothing make sure you follow all the rules um if the person is you know a pep if the person is um someone from a country that shouldn't be doing certain things you just follow the guidelines make sure that you have done everything to assess the the person that's actually trying to do business with the establishment okay very good very good and so i think somebody had asked about this question already um it's on the homework i think it's also on the classwork let me pull up the class where um and persons had asked and we had gone through this already in terms of various jurisdictions how do you answer this question let me just pull it up well it's it's similar it's similar um because on the classwork persons that ask how to answer question four and five and it talked about clients residing in various countries and we talked about you know some other countries have a high risk versus lewis and so that's what the question was looking for to ensure that you differentiated between the high risk and the lowest okay um this says critically analyzed about hope and so when you see an analyzation you want to go out and see what is the interest of industry saying about um the west space approach and country is applying it okay so in your research clavia um just look around on the internet and see who would have commented or who would have made um i guess the person from the fatf of various countries um talking about you know the implementation of the space approach you should find a lot of information where i'm there saying how expensive it is you know and then of course you know everybody compares their selves to europe or america and you know smaller countries were complaining you know we can't be measured with the same stick because you know we don't have the resources and i always say that with it with the tax regime the irs spent 18 million dollars to upgrade the irs just to be able to receive that information because they were going to make probably 550 million a year so they could have spent that 18 million however lil bahamas could be could we do that could could we spend 18 million dollars to upgrade our um right okay we end up the first million right but again all these laws were implemented and you had to put them in the place or you would have been black listed so again we all know the statutory requirements we all know um identification we know record keeping we know training we know monitoring we know the mlro okay and so basically the risk based due diligence falls under just implementing the statutory requirements as well as doing the checks and balances to make sure that you get correct information and um miss bullet also if anybody else is i i mean i call back and share this if anyone else is doing the question um um i used their website the last time for my paper as well um the fatf has a lot a lot a lot a lot a lot of information i mean they go they give you um excerpts on even if they make just one small adjustment there's a whole paper on that adjustment and outlines everything like all of the yeah every topic that we've done there's so much information that you could actually resort back to and that's what i do i use a lot of that to study and review too so just putting it out there um guys go to the fatf page there's so much information that you know you won't really have to stress about trying to find um examples or anything like that like the information is there and then sometimes you could just go into the once they give you the little um examples of what i tend to do is i just go to google or whatever and i start to type in the country or whatever there they talked about and then more information populates so like i say the website has enormous amount of info yeah and please in your own words you know we have seen a million of these um essays and we know somebody you don't even know some of these with your speech and then your copy and paste please read it analyze it and then put it in your own words and like i said don't copy uh ing to this paper and a large piece a paragraph or with the fatf3 you don't get any points for that okay in your own words because we're checking for comprehension okay okay so good very good clavia thank you for sharing um so along with all what is required we know what is required for identification so we want to talk about some of the issues that occur when we are identifying okay and again um you know in intro we talked about all the aliases um at royal ah account opening package on the wealth management side was 45 pages there were um places that you had to initial there were clauses there were general terms and conditions that had to be initiated however um remember now nobody walks into the bank to open up an account we have external asset managers all around the world so an external asset manager or business introducer would have been sitting in switzerland the customer would have seen them in switzerland the um eam might have gone out to their house and um you know had them signed the papers then they would have not checked and sent it to fedex to us we received it on our verification department and a lot of companies don't have a verification department they expect this work to be done by the compliance department okay but they should be a verification department that says section a b and c is not signed or it's not initial properly and this needs to go back to the client okay indira tell me why that need to go back to the client why we can't just fill it in for the client because you'll be lying correct and the client has it's copy right exactly so you have to fit it on correctly right because you'll be here liable and accountable right and so the whole purpose and i don't know why people don't get this the whole purpose of filling out this application is if something goes wrong we can show up in court with our copies exactly you agreed to this general terms and conditions do you want me to tell you how many more than 10 occasions we showed up in court where the customer brought its copy and we brought our copy and the customer could show i did not initial section three four and five because i didn't agree with that right on the bank side three four and five initial who write that tb in there take on the chair okay and so here it is on our tenth occasion of showing up in court for tampering with evidence of tampering with the documents the court of signing us and and saying they can shut us down because you see in the first occurrence how many you cannot fill in the blanks for the customers because these customers are very savvy they have lawyers they have accountants they know they know that um of their account will not be open if they don't sign but is we are negligent oh i just need this account remember a lot of the salespersons are on commission they don't get paid until that account is open right and so therefore they they initial in that their self okay and we allowing it okay and once they allow that god forbid something happens in no longer you're just camper you could go to jail now okay so please stop tampering if it's incomplete it's incomplete send it back let the customer confirm that um you know they agreed to this even if you don't want to send the entire document back by fedex you write a memo you have the customer sign a memo that i agree the terms and condition four five and six i inadvertently did not um sign or initial on that spot and therefore please accept this signature on this letter as the confirmation that i agree to those terms and conditions okay please you all stop filling in the blinds for these people okay you go to jail and you don't know if this person is committing fraud you know and they that they get a subpoena uh to produce and they come and they say well the bank committing fraud as well do we just they didn't even they didn't even sign um um um that section in the bank i would sign so it appears as if the bike even i'm committing for okay so you're please be careful with that okay um another thing is and i i think it was his class but we talked about edison sumner right was it this class are you familiar with that's the first class i think that's the first that's andrew we had a discussion on him how he was to when he's buying his bmw and signing and doing all these things on behalf of one customer right something like that yeah so on behalf of his company account um you know he his signature match and that's a lot would that's what we ask um look for when we um accept transfer requests first of all we get the transfer request by email we just check to see if the our signature match and then we process we check to see if we come from um the same email then we do a call back we stamp the call back and we send this money to buy this bmw okay do we ever check the profile of the account who who working in banking let's see shanda lynnae you're working in banking yes mom okay do you do you ever get a transfer request or send funds or you work on retail side um i want to talk about the um to do a wire for clients yeah to do a wire yeah but they would have to um complete a form for that request okay we could complete the form we could complete the form my signature match yes you could call back and say um is this edison sumner yes it is did you want this buyer to go to buy this bmw yes it is yeah yes please process it send the wire for my bmw okay what have we realized from this case that we have to check as well chandler before you send that wire you know about the case the question is he said he's purchasing for himself or for the company no for himself well um well with the invoice the invoice should be for him if it's coming from his account and also in terms of sending an email that person would need to actually sign for like an internet telephone and fox agreement that was recorded on file that's on fire he even bring he bring in the invoice he walk it in and you know that's him okay well we just have to check the details of the the um what is it called the potential activity um yeah the potential activity of the income and the money there this account was a company account it was first of all you have to you have to look at the natured account advice um to use monies because you sign on the account it's not yours correct correction and so are we checking those profiles to ensure that hey this is at this insomnia he is in the bank signature she's a signatory the money is on the account are we looking at those accounts to ensure that this is in the profile of the account when persons come in for the business um to do transactions those invoices should be for the business not the person itself it's not a personal account okay so if he says if if there's no invoice and he says debit um this account and send it to going places for tickets to disney world he can't do that by himself because yeah the second signature there two people to sign oh and and that's what happened he was banned for 10 years and the ceo was banned for life from the securities commission because they had opened this account they had sent persons down i think it was the scotia bank to deposit money for cryptocurrency however his office should have had an operating account right he should not have been able to buy a bmw her just to get to disney world buy a rolex watch from the cryptocurrency account if his office had an operating and account and they were the signatories and the shareholders agree then they could do whatever or if it's a sole ownership and that's what you want to do to your business account then you you know at some point your officer should call you and say you listen i see feel you've been the disney world of the company account was that for the staff or was that for you and your family because that is outside the profile of the account and especially when it's other person's money okay so when these companies come and open up this account more than likely it's other people's money they say this is for loans this is for cryptocurrency this is for investments then they cannot use that account to buy personal goods okay and so that's my whole point we have to carry out our due diligence properly okay we cannot only say the signature match will do the callback and the money there no is it within the profile is this his personal money okay and if it is his personal money then i i tell my customer who just says bullet i can't keep account all these accounts i said okay what i will do is please send a transfer that says you wanted to go to your personal account and then i'll buy a disney world ticket okay because within this profile it's for business purposes okay and that should be a suspicious transaction misspelled yes i have a question in reference to what we're talking about so in reference to edison's i'm the case um would his source of wealth come into question i mean knowing what his position was and all of that i'm quite sure that he was making some monies some dollars but would his source of wealth come into question when he would have actually asked for for that to happen well well guess what the [ __ ] at account opening his source of wealth should have been checked and that's another thing we ask for a job letter they bring it in we stamp a job letter on fire we don't corroborate it we don't say well mr summoner you only make two thousand dollars a month where you getting tender housing from right we don't we don't we just say job letter received we never even read it that job letter could say he never worked for us before and we just know a letter come in and we put it on fire don't let it be like two pages or we asking for financials we are not accountants we don't know how to read the financials and we definitely ain't going to account the department asks nobody to help us so we see if we don't even check to see if the account is um if the business is profitable or how much receivables they have outstanding to make a determination okay this business seems to have revenue however they have 10 000 or 10 million dollars in receivables that means somebody in this business is not doing their job properly and collecting the money so the next question you should be asking why you have receivables to this amount who owes you all this money and what's your standard are you collecting every 15 days or every 30 days how could these people owe you this money this long and your business still survive you know so again we are not properly trained to do these things and until something happens then we go through um these accounts and we we find out um that these people should have never even had the account so that would be an indictment on the company itself then yes on the bank that opened right proper due diligence right okay right so let me let me tell you so we i was hired to keep a bank open and when we started a review this account had been open for five years and they have specifically like on your walls for questionnaire for your corresponding banking account they ask you what's what percentage of your business is jason orwell what percentage is marijuana what percentages is illegal ography or whatever and so of course if if you go over 50 they don't do business with you and some companies will tell you or some banks will tell you oh no we don't do business with um marijuana so we can't even open this account to you so you have to be very careful when you fill out these forms and you talk about the products and services that you offer on your clients and whilst we were going through um the review of these accounts we found out that this um account was the platform the techno technological platform for hub okay so if we have in our aml directives that we don't do business with illegal with ography it's not legal in the bahamas or hub or whatever it's not legal in the bahamas but in the state where it's registered it was legal okay and technically this was not um hub itself but this was the platform you know and they didn't even know this and and that's how this money this money was coming in it's like this man has made a lot of money and so he was being paid for the platform that point out sits on you know he's just a computer guy okay and he decided he wanted to open his account in the bahamas so of course when we told the board you know in our board meetings we should be just like the advice you know that you know when our our client provides the platform for born up so all of the questions said oh my god close it out close it out that's illegal blah blah blah you know so in our appetite if you were gonna keep that account you had to ensure that it was a part of your appetite you have to ensure that all of the forms that you filled out say the type of client you have in their businesses that you you actually know and a lot of times like i said especially in new york in in retail world is much simpler but in the offshore world they don't know there's nobody have a chance we check the box um joining receive financial receive just receive signature sign we take a closer look we'll be very surprised okay so you can't have an account like that on your books if your risk appetite says we don't do illicit ography and ography is against the law in the bahamas okay so just so you would understand so you have to dive deeper and there are what should i call it there are controls now in place by the regulators where we have to give an annual aml return and so this helps us categorize our um clients better because you have to know what type of client you are and what businesses your clients um they are in okay a lot of times the forms always ask them you should put anything on it because we just knew that we couldn't say yes or the account wouldn't be open but now the regulators are checking banks are checking everybody is checking so you want to ensure that you what kyc know your customer okay that that that's the biggest problem surrounding customer due diligence we still check in the box we are not cooperating the information that we receive we just putting it on file because we happy we get the 25 pages every day inside close that file and move on to the next one let's put it in that regards you have to also know the customer customer as well you can't just rely on just knowing your customer but you need to know exactly what their customer dealing with in order for you to not be defrauded or used as careers yeah you have you you have to know and you have to ask questions and this is why it has to be relationship banking you have to build a relationship with those persons so they can trust you yeah you have to probe you have to know but what is happening in the banks now is that compliance is not customer facing compliance is background compliance should never speak to customers but right now compliance knows the customer better than the account office and people on the front line how is that possible because we we don't have a choice they just these people they simply don't do their work you know and the com the offshore world is so competitive the ease of doing business or you're gonna run away the customer or if you ask me um um if i got married i wouldn't want that i suppose i'm a personal um problem uh person i wouldn't want to tell you that i got married and then we had a gay customer who who married um a prime minister's son oh he's gay he doesn't want anybody to know that he's gay i can't i know he there are pictures on the internet with the president or i think maui son but i can't ask him that how could don't ask him then he's a pep marriage is legal in their country not nas what do you do okay but again like i say know your policy look for the gaps understand your job position and build a very close relationship with these persons so they'll feel comfortable talking to you okay and and you know you always blame the third person i understand you know these are doing business and i really wish i could make this easier for you but i have to have have you fill out this form okay let me sit with you and fill it out to make sure we get sufficient information so we don't have to come back a second time or third time you know so you have to just be savvy make the person very comfortable you know and they will shout at you they will say listen i could go down to del tech they won't have to ask these questions it doesn't take this long this is too much and you have to just find a way to appease them but these account officers they don't want to please them it's because you know cutting deals listen i can get pass on this bullet don't worry you just put this in there or your sign it's like they working more with the customer because they want this account so bad rather than you know being what should i say compliant okay but it's a double-edged sword that you have to strike a balance between front office and compliance we can't constantly be at war okay no accounts open you don't need a compliance department you have to be a very strong individual to work in sales because of the pressure they put on you to get those totals if you're not a strong person you can get yourself in problems yeah you will still and and one year um royal bank had left 134 salespersons go because they did not meet their targets and listen to me everybody probably wasn't realistic you have to be sensible when you set goals it has to make sense yeah yeah you can't just say well get 1.5 million each officer where in the head you can get it do you want to understand that yeah how are you going to get that yeah so let me tell you how you can get it yeah so we are we are fully aware and we are that that whole forecast is never realistic and we have put at least at my institution we put in place that forecast must come the compliance to be able approved before before it goes to the sales team and and we make sure that it's realistic it's a smart goal and it's achievable because i i'm telling you these we have had so many people um manipulate the system um another bank i ordered it we and i i think i would have told some of you this story where we were at um [Music] what is it um they have an agm meeting and we were there on the same page yeah and we everybody the whole entire computer said that's on this everybody's like three boys and the lady walked up and and collected a prize and of course immediately when we got to work monday we had more than 50 requests to check that the whole bahama sales team say oh there's no way but we even said it was no way she could have won in freeborn over nassau so yeah and she was manipulating her sister and yeah that i remember i remember we had a situation like that at sbl as well i every year i used to wonder how in the world naughty lutra a little branch cutting the big branches been awesome what they were doing down there the loan officer and the manager they were creating loans for dead people yeah yeah i was like are they walking squat free right now yeah yeah and there there's so many things so many if you see how creative you speak i say mine they said you don't need to open your own business yeah i would never imagine some of the things they did and they got away with it for years for years and years and years okay so be careful of that okay and when you become the client i'm complying to officer and there they live step steps like the sales is unreasonable and i'm afraid of my job check it in intervene and help them out because of course you know everybody's just looking at the bottom line and how much money we making so that's why um they change compliance they developed it from just compliance compliance risk and governance and they put a whole section in there about technical skills interpersonal skills and effects okay and building a strong culture where people make ethical decisions that you don't put um targets in place that cause people to compromise themselves okay you want to be very very careful with that okay um another thing with these company accounts like i said before the law used to say 25 or more interest you um um verify the customer and so we had persons saying they owned 20 and 10 percent now they decreased it to 10 interest you need to be verified so now we have people coming and saying they own eight percent as a company okay to me that's a red flag now you can insist that um they bring in information however you can we'll check them google them why this person will stay below the reader with what going on here okay when you open a company account there's a shareholders ready stream it tells you who the shareholders are and what percentage of the company that they use if you ever see bulletin code you have to then ask who does the code represent because that means as a company the law now requires there to be a natural person okay so it can't be an no one in co it can't be no normally it can't be anybody you have to then say there's another document a nominee agreement who's holding the shares who does bullying go represent i always say could be berlin ben laden right um another thing you want to look out for is what type of shares are there are these registered shares or are these are bearish airs and years ago if you're if your country offers bear shares it makes you a bit high risk however the bahamas stop offering bear shares but we still can open an account for bear share accounts and so for a little while i think up until 280 and we had a lot of panamanian accounts that were bearer shares so of course we had to re flag them and we had to call the customers and say say that panama now has no longer offers bearish shares so we need you to go and register your shares or you have to close on the account okay you want to ensure you know what type of shares that company is holding if it's bearer shares you want to check that okay bear a share a registered chair me is that a registrar somewhere would have verified you and it has your name telephone number and everything and undocumented you as the owner of the company a bearer share is a almost a certificate it'll come in clavia rule and you decide that i wanna um turn these shares over to bin laden until you just sign so that isn't even registered anywhere that you sold yeah share the ben okay and of course we won't open an account for bedlam correct so here it is this this account already open in your name and you've transferred ownership no registrar has documented that and of course if the registrar had documented it if it was a registered it's um cher and ben nadine walked in and said clavia just sold me his [ __ ] yes they would chase him away correct right and so that's the risk with bearish is that it could be transferred without you know to somebody who is not practicable okay and so bahamas law says if you have a better share account if you the company opens it there are two types of documents um that you have to do there's a letter undertaken from the person holding the shares and there's a letter of undertaking from the customer so clavia you have to write a letter and say i promise before i transfer these shares i will contact my financial institution and let them know that i am transferring these shares to bin laden give them the opportunity to agree that they want to keep the account open so of course we say okay claudia go ahead and transfer this ownership to bin laden we close in this account [Music] or we say we would have verified you transferred or over to demetria she's a reputable person let her bring in all our kyc information and you'll keep your account open okay and that's a big thing in switzerland because i don't know if i told you on this story whereas very young um investment managers are purchasing the goodwill of companies that would have been established for 50 years and that was i told you all about that story correct so we had an investment manager who was 24 years old coming to open an account with 99 million dollars 99 million dollars right so of course miss bullet was jealous right because she have no million so i turned that file upside down i said something wrong right off the top right we'll give this 24 year old boy 99 million dollars no way and so of course that says manager sat on my lap miss bullet and his account opened the day what i got to do what happened this is the jet pricing you don't have to check this check that i said okay just give me a second whilst he's standing over me i go through all the information and i say um he's 24 but did he get this 99 million dollars from oh this is an omnibus account um he um have investors into some type of cryptocurrency product or whatever and he is legit and whatever so each person gave me um 50 million and he has um some 50 clients and there's a portfolio or whatever so i say okay fine so i got to verify those 50 clients make sure they legit but i am concerned he is 24 um and his letters is opening let us say they've been in business for 50 years so i said um who was the previous owner of the uh the company and so they gave me say a pointer name and his name was royal so i was like so he doesn't have his father's last name i said is he taking over the business is his father retiring so they say no so i said how he's 24 how possible could you be in business for 50 years i say requests are on a reference from the bank whereas 99 million dollars is so they requested a letter same thing the account been open for 45 years in good standing and the balance is 100 and something million dollars and they are ready to transfer to 99 million or whatever i say wait a minute if this in his daddy account well how possible you you know who who what is relation to this man absolutely nothing he then we dig deeper and we find out that in order to open an account on the wealth management side they say two or three years right a financial history and so they are going into switzerland in different parts of europe and buying our companies that close down instead of a bank account and they use the name and the goodwill hoping that the new bankers do not pick it up and so they're going under like let's look at a mckinney bank often news they've been around for 40 years or hugs and johnson higgs and johnson been open for 70 years some knew young buck take it over i'm just using the goodwill of the name had already established and the bank account history you see and so legitimately it's not him who run the company who who that history does not technically belong to him you know and so we we said no we couldn't open our account and i i thought i was too bad i had to wear my bulletproof vest work but i said that it's not his money is it's not his money it's not his history and it's not you know what i mean so i said if he had another company that is already established like for two or three years he has to wait listen they must kill me i was afraid yeah so y'all be careful of that okay excuse me i'm my i'm experiencing some internet issues over on my side so i'm every so often i get knuckles if you don't hear me that's what's going on okay okay but just listen to the recording later okay so in the office yeah in the off show where that's a tactic okay so you want to make sure that this good history in this good will belongs to you or or your father or somebody who you inherit the business from not a total stranger who had nothing to do with you okay so so be be careful of that all right are we clear uh you're on the same page you're still there yeah okay and all of this falls under due diligence okay um you want a copy of the board resolution again um we had a messenger that stole some some um checks and of course he was a messenger so he would deliver company documents from one from the company to different areas and so he decided that he would just steal a copy the copy documents the company documents walked into a scotiabank open up an account and said that he was the signatory now the again you can't ever eliminate risk you can only mitigate it and meaning you put controls in place to help reduce the risk so after um this happened you know it happened a few times where persons who would not who just got a copy of the copy doc company documents rented banks open up accounts illegitimately um they put in place that you must have a resolution from either a director or a board of directors and so in your kyc package you ask for a copy of the you know a list of members and directors who who are part of the company and you check all their signatures along with that you want a and you get a certified copy now because anybody could go online and just make up an excel sheet okay along with that you get a board resolution if your company does not have an internal one and then you compare the signatures that it match okay so if jamal and lynnae sign on you want them to write a letter saying i approve this account to be opening and these are the approved persons to sign on this account okay so that means claudia cannot walk in the bank and say i open in a royal bank account and i say signatory so as he had checks to deliver he deposit the he deposited those checks to the to the account he had opened and all the bank checks he was just taking the money taking the money going in the bank and this is the county deciding off he was the um signee and so the teller was told what was right right the account officer did not do proper do the diligence okay so that board resolution is just another layer to try and protect persons from fraud okay and so um a person started calling and saying um you know or the person at royal bank was calling and saying listen i paid this this bill is outstanding for so many days and then they said no i paid this and then another bill is sold standing for something they said no we paid it and then they tracked the disabled way all these checks being cleared through the same bank in the same bank who account this is royal bank then they say send us the information and then we find this messenger it's the signatory and that's how we found out what happened almost a year later and uh more than a hundred thousand dollars okay so namaste clearly he does he he really don't understand how the clearance system works that's the easiest way to get caught if you steal and buy it yeah come on he get ready get away with it for you wonderful so what happened to him after it was discovered again he was let go he locked him up for them while buying for the reputational risk nature of the god because every time you show up the god is it across the newspaper that you start to see the people could take their money of the bankers to suffer steve too much okay and i don't know if it was this class i discussed it with but i said i'm very interested now but they stopped dragging the people across the tv so we don't even see anymore but the banks do not want the reputational risk however stealing and theft and fraud now fall on the money and laundering and so i'm wondering if they are going to not be able royal bank scotia buying all these banks that don't want reputational risk they will can't that pass on that money laundering charge you said i mean because the record will reflect that the banks did not do their part and after get somebody noticed it somewhere the court system did say hey we are being internationally watched these people saying being charged nobody would with with money laundering however we have 50 people charged with death and the banks never show up so i'm wondering now if they can avoid that risk any longer now that the crime falls on the money laundering so i am very interested to see how that's going to pan out right and i think that's the reason why i miss bullet a lot of persons who are scammers tend to do it all like you say employees who tend to steal because they know yeah they may get charged a little fine if all of that but they're going to get away with it because the reputational risk of the company anita you don't might get away with it monday morning day on a new job exactly okay when was bullet office first down it take me a year to find a job booty monday morning you hired as the assistant manager this is my manager okay so yes was bulletin never thief it was hard to see the private job right right i guess still understand okay be honest the honest ones always suffer yes always always but remain ethical remain yeah the lord you know god yes yes okay so um another thing is good standing um so a lot of companies they go a lot of you know entrepreneurs they go and open up a company and then they come directly to the bank and they open up a bank account you do not get a good standing until the first year after your company would have been open okay and so you have to make a note in this system that today is june 25th 2022 i'm opening this account next year i need to check for anita's good standing okay and she will get that good standing when she would have paid all her fees and wasn't struck off for any other uh conflict or dispatch or anything like that any suing or whatever the company okay another thing that we do is we never ever get outstanding by damage next year come we forget but a needle and we on to the next customers okay we need to get that good standing each year um it was another um fun administrator i ordered it my god company has been struck off and sued and shut down from 1998 and they allowing these people to invest in the market under the company name they've been struck off from 1997 okay and so as an administrator you are supposed to ensure that those fees are paid never paid the fee we was trying to sort that out for them um eighty thousand dollars i think the the registrar asked for um because the fees were not paid from 1997 the company had been sued all sorts of stuff you know and as the administrator the administrator never checked they never got a good standing all sorts of stuff happening not only after they pay that eighty thousand dollars um all kind of fees associated with it the amount of money is a crazy situation but you cannot allow companies and a lot of people they don't want their name especially politicians and neither don't want anybody to know that you in this seat file fund or this one or that next one right so she going on the sunshine investment company but sunshine investment company has to pay those fees every year if sunshine investment company is through it and they don't date bankrupt and they don't have no money then you have to shut down you struck off you can't still be operating on the sunshine investment company you cannot still have bank accounts okay so that good standing is very important overlooked again okay we don't have time for that let's bullet we have more than 100 companies you need more than 100 good standards okay you have to make sure that that company is fully operating especially if they operate in the market because if the us or the sec or any market they find our irs find out about that that company could get shut down yeah i even talked with the fines that they have to pay okay and the ceo every like i said they do us that's negligence okay so you have to be very very careful okay um you want to be careful with power of attorneys they they cease at death okay and what you'll see happen is um the people who have poa over the account they want their fears they want everything they don't wait for the 10 months for the probate to happen they want all their money right now so you'll see the money coming out the account that the person died like three days ago so you want to be very careful and ensure that you document the date of death um in the offshore world um we have countries like switzerland and france there are civil jews civil law jurisdictions the bahamas is common law if you're a client it's from a civil law jurisdiction they have this thing called a hair certificate where okay by a justice of the peace and you all know our justice to the pieces you give them twenty five dollars anything you guess now they never meet the person who didn't know you from 10 years or nothing like that so people hurriedly run to the bank would you say a certificate and take off the money and then the real executive or the real person who was supposed to get the money um the money done gone and they don't run off with it okay so if your client dies in the civil law jurisdiction and you know their laws are very slack in regards to the seize accounts if the account is in the bahamas bahamas is coming there hair certificate or even if they say well i probated in switzerland they have to be probated in the bahamas and i'm telling you i promise you i had about 15 accounts where this happened that people tried to run off with the money and even the account officer who sat in switzerland tried to defraud me and me worked for the same company i had to report him 10 times like why does this man keep asking for this money it's being probated in the bahamas and then the lawyers want to say oh we don't need a bahamian lawyer to probate we've already pro probated in switzerland and they don't want to pay oh they're trying to rip us off they have to pay now five thousand dollars to get it probated in the bahamas this is a rip-off but that is bohemian law okay so again if you work in the offshore world you need to know that and even so if you don't work in the offshore world if you may have a french customer who's just an expat or somebody from switzerland you have a lot of persons here and they have accounts okay so so you would know but forbid they pass away check the law of their country and check that probate if it's from a civil law it has to be probated here nobody wants to do it they will fight you and if you don't know they will trick you okay and that's why you're here so you would know these these various things okay um outside of that um cooperation okay and not only that from the onset of the account once that account is open high medium or low you will never know you know everything about a customer but you must be knowledgeable you must be able to speak to the customer on the background of the customer and so i always say i need an overview you know don't come with 50 piece of paper and expect me to put a puzzle together i always ask for an account open-end synopsis okay and not only that if it's pull it out for personal account and she on royal bank of canada account and she on our own company account i want a pyramid to show me every account that she connected in okay and that would help me to know her better and go develop a pattern and that's the only real way you can protect yourself but when she over here and you all know she have this account you know and if the structure is not in place that that happens the availability of information if if you don't know this is a european deat