Bloomberg provides a stunning overview of the laundering of over $1 billion in oil proceeds that highlight the importance of execution of basic AML principles.
Some questions to consider when placing this case study in context of your AML program:
- How is your organization handling secondary sanctions and associated risks?
- When analyzing originator-beneficiary relationships, how often are intra-bank transfers actually scrutinized?
- How robust is your third-party due diligence, and how might you prioritize by customer, product or geographic risk?
- Do your PEP and sanctions-screening programs account for secondary relationships and beneficial ownership through enhanced due diligence?
- Is your AML program aligned with your company's anti-bribery/corruption programs, to include information sharing?
In court, Zarrab laid out how he paid tens of millions of dollars in bribes to Turkish government officials and banking executives to win their assistance—and cover—for the money laundering operation. He dropped a bombshell on his second day of testimony, when he implicated Erdogan as part of the scheme, saying he was told Turkey’s president gave orders that two Turkish banks be included in the plot.