Bankers are always asking how to practice due-diligence and file a Suspicious Activity Report (SAR) and not subject their bank and the directors to a lawsuit by disclosing confidential customer information. This, of course, is not new, but due to the Foreign Corrupt Practices Act (FCPA), this is very serious business. The privacy of a customers financial records is a hot topic and worth checking over the rules and the required balance between the customers interests and law enforcement concerns.

In 2000, the SAR form was revised and is easily downloaded from the Financial Crimes Enforcement Network. New Changes incorporate information concerning computer intrusions and there are more ‘check boxes’ for a more accurate completion.  Figuring out when to file a SAR, is a financial institutions priority. Always file when there is a discovery of Insider abuse no matter what the amount; violations aggregating $5,000 or more when a suspect can be identified, or aggregating $25,000 even if there is no substantial basis for identifying a suspect, any transactions aggregating $5,000 or more that involves a potential money laundering or the violations of the Bank Secrecy Act (BSA), and any computer intrusion.

The SAR filing requirements cover situations that financial institutions may suspect , know or has reason to suspect a transaction has occurred and involves receiving funds from illegal activities, such as evading BSA regulations by structuring transactions to involve less than the $10,000 currency threshold that requires filing a Currency Transaction Report, or a particular customer is doing business that is not the sort of in which they would normally be expected to engage. If $10,000 is exceeded, both the CTR and a SAR must be filed no later than 30 days after the initial detection of any of the above violations. But, a report can be delayed up to 60 days in order to identify a suspect.

The anti-money laundering efforts, along with the fight against terrorism in Tanzania took a hit during the month.  During a meeting of the finance ministers, the government split when trying to come to an agreement about whether or not to allow a report to be approved, a report that confirmed the state of affairs for the country in regards to the corruption, which is not good.  They prevented the approval of that report, which disregarded the efforts of the fight.

The reports had been approved previously by the regional officials, who were organizing the fight against terrorism and they were expected to be approved on the Ministerial level, while South Africa submitted the reports, the region of Tanzania did not. The Financial Action Task force from France, was part of the inter-governmental organization over-seeing the council meeting and the postponement of the submission by Tanzania was a surprise stated the president, Paul Vlaanderen.

This has not only an effect on the fight against the corruption but may have serious implications for the banks, as now this too looks suspicious, and foreign banks may not want to continue having dealings with the unknown, the unknown being just how bad are the money laundering cases in Tanzania.   One of the reasons for this is that when a high percentage of a banks transactions involve cash, those transactions become hard to keep track off.

Tanzania is a developing country, and the norm in those countries is to deal more with cash than in countries that are developed.  As the global recession ()continues the people begin to lose confidence in banks and the financial institutions, this too causes more and more people to just deal with cash.  It is a cycle that is becoming hard to break.  It was shown in the report from Tanzania that on the island of Zanzibar the laws regarding anti-money laundering have not yet been implemented, and some of the officials are just turning a blind eye to the situation.  The finance minister of Tanzania stated that it was not what was in the report that caused them to postpone the approval, but that the report itself needed to be worked on, and rescheduled the meeting to so for this coming December.

Singapore is a pretty boring place. Let me explain, it’s boring because there are no school massacres, no corruption or scandals, not gang warfare and not much crime. The elections are low key and not exciting and are a pretty predictable fair. Even the private banks of Singapore are doing well with all the global economy in the tank. But, lately, Singaporeans have been treated to a bit of excitement. People are all a buzz about it and it’s getting wide coverage by the local media. The Internet is humming with all kinds of opinions and because it has a little bit of a religious element to it, this is why I’m discussing it in my blog.

It’s only today that I will address this, so don’t worry or stress out, because I will return to my usual subject tomorrow. There’s an organization called AWARE which has promoted women’s rights for over 26 years. Like everything you’d expect from a modern progressive women’s advocacy group. Well, last month, AWARE had their annual meeting and a large group of members who has only joined the organization last month, voted out all the old members and over took the running of the organization. What was more astonishing was that six of the eleven new officers all just happen to be members of the same religious organization. If you’ve been living in Singapore even just today, you will know which organized religious over took AWARE. I will not mention them and give them credit.

The new AWARE committee have publicly stated that they did not know each other previous to their election and that they haven’t yet decided whether there will be a new policy on gender issues and that they intend to keep their religious views in the background. After that announcement, my Singaporeans reported seeing pigs fly. I’ve heard rumors that the ousted committee has planned to do the same thing, become underhanded, dubious and even immoral in order to win back the organization. Now, stay tuned, tomorrow, I’ll be writing about my normal stuff, even though it’s not as exciting.

The Foreign Corrupt Practices Act was created in 1988 by officials from thirty three countries, including members of the United States Congress, in an attempt to bring an end to corruption, bribery, and extortion on the international business level, focusing on the financial institutions of the world. For many years official and military personnel had been extracting payments from foreign companies in exchange for securing business opportunities. This created not only corruption on the level of business but on the local level as well, for while these officials gained wealth and power in the acts of extortion, the economy and the people of their countries suffered greatly. One of the challenges of dealing with foreign cultures, is that they have different perceptions of what actually constitutes a bribe. Many counties practice gift giving in the form of favors or presents as a part of their customs.

However, in the United States this too is considered bribery. It is the act of giving one preferential treatment and opportunity over another, at the personal gain of the one extorting the favor, the gift or the payment. The regulations of the FCPA have served to take the weight of offending a foreign official off of the American officials and the financial institutions. The federal law of the United States is such that these forms of payment in exchange for opportunity are illegal and subject to fines and prosecution. By taking this out of the hands of those conducting business affairs it serves to not only ensure that no laws are being violated, but that the companies and those in the middle of the situation have a valid reason for not partaking in such actions. Since the years of the inception of the Act, authorities have prosecuted many criminals who were committing crimes of extortion, money laundering and terrorist funding. This is not only serving to make the world a safer place, but a more ethical one as well.

New Yorkers celebrated Gay Pride this last week, as did many people in cities throughout the world.  This was the 40th anniversary of the Stonewall riots that occurred in Greenwich Village in 1969.  On the morning of June 28, police raided the Stonewall Inn and what occurred was a series of demonstrations and riots.  This instance is the first in the history of the United States where those in the gay community fought and protested a system sponsored by the country’s government.  Those in the community had been persecuted for years, however on that morning they stood together and thus began the movement for gay rights, not only in New York, but in the entire country and throughout the world.

During the 50’s and into the 60′, legal systems in the U.S were extremely anti-gay, and some groups had the mission of proving that gays could become heterosexual through proper education.  By the end of the 60’s however many other groups were standing up for their rights.  This was the time of demonstrations against the Vietnam war, and the time of Martin Luther King and the Civil Rights Movement.  The influence and the power of these political movements, along with the fire of the recent riots in Greenwich Village, inspired those in the homosexual community to stand up for themselves as well.

During this time in history, many businesses did not welcome the business of gays. The few that did were often the bars or some of the smaller best restaurants.  New York City Mafia owned the Stonewall Inn, which was home to many young runaways, hustlers, and drag queens.  While the police regularly raided the bars in the Village and were well aware of the actions, they were not ready for what was in store for them at the Inn.  The situation quickly became elevated and out of control.  This incident began the movement, for within just a couple of weeks following the riots, gay newspapers were conceived and published, and groups were organized that would eventually make history.  In the way that tragedy does tend to motivate, the people were brought together as a unit standing up for not only themselves, but for others in the gay community as well.  The first Pride march occurred in 1970 in just two U.S. cities, Manhattan and Los Angeles.  Now, Gay Pride is a world wide event, a series of celebrations that end with the finale on June 28, commemorating the date, how far society has come, and how much further we still need to go.

The ten year old star of the award winning hit film ‘Slumdog Millionaire’  was awoken last week by policemen banging on his door.  The young actor was removed from his home just moments before it was demolished by bulldozers.  Many other small shanties in Mumbai met with the same fate.   The child actor, Azharuddin Mohammed Ismail stated that he was worried most about his kittens, who were lost in the hub-bub and the chaos.  The two young actors in the movie, have yet to see their lives changed in a positive way, even after taking part in a project that produced more than 300 million dollars in box office profits, and garnered eight Academy Awards in Hollywood.

They live currently, in the slums that are illustrated throughout Danny Boyle’s film.  For them, not much has changed.  The young female actor, Rubina Ali, shares a similar life style.  Far from the center of town, away from the city streets and five star hotels, Mumbai supports many people.  And the economy is just not secure enough for them to live in a survival-able habitat.  Both these child stars, spent the nights over the weekend, sleeping outside in the ruins of what was once their homes.  Water and sewer problems are always an issue.  Their homes were built illegally, and it is common for men to come in the middle of the night to tear these little houses down.

Officials in charge of the demolition stated that they were not aware that the two children from the movie were living in the shanties.  They have promised government housing for the families who just recently lost their homes.  Ashar receives gifts from fans around the world.  But sitting in the mess that was once his home, the young boy admits, that he just would like to move.  The filmmakers have issued statements, saying that the welfare of their stars is of utmost concern, and that trust funds have been set up for each one of them.  But it seems that no one, not even the parents of the children, are able to figure out just how much money is in the fund at this point.

Reporters are converging on Beijing to begin coverage of the 2008 Olympics starting  on 8/8/2008. To host the games, the Chinese government assured the International Olympic Committee that journalists and press from across the globe would have open Internet access, removing the effects of a firewall that censors numerous sites from public view across the country. The New York Times reports that despite initial denials, the Internet is being censored at the Olympic Press Centers.

This news comes as another unfortunate example of the Chinese government reneging on the pledges made to host the games in the first place. Clear blue skies and an improvement on their human rights record were some of the other pledges made. According to the Times article, President Bush has met with Chinese activists to discuss the situation. Many are boycotting the games to express their disapproval; however, the President has said he would attend the games and use the gathering as an opportunity to openly bring messages of freedom to Chinese officials and citizens.  With a little more than one week left before the games, it will take a miraculous effort on China’s part to win over the hearts of the world for the global games.