Miles Kellerman at False Positive:
It was just the type of document I was hoping to find.
Buried beneath endless layers of digital files, each poorly labelled and filled with unsearchable PDFs, was an organizational structure chart. The presence of this chart was not, in itself, surprising. It is one of the many documents financial institutions are required to collect when performing due diligence on new customers. What made this chart notable was who it named as the company’s owner. Namely: an individual with alleged ties to a ruthless terrorist group.1
I was not reviewing these files as a regulator. Nor was I a journalist chasing down some lead. Rather, I was supporting a corporate monitorship, an obscure but highly consequential tool of criminal enforcement. Monitorships arise when prosecutors determine that a company has broken the law at scale. Perhaps a bank has been failing to perform due diligence for years, allowing North Korean agents to launder stolen funds through riverboat casinos. Or maybe it’s a mining conglomerate bribing officials across central Africa. You know, that kind of thing.
More here.
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