ABA Banking Journal - October 2010 - (Page 58)
compliance clinic | anti-money laundering due diligence
Inside the “bad guys” heads
Enhanced due diligence, fraud investigation, and SAR filings all hinge on this: understanding your adversary by steve cocheo, executive editor
ennis Lormel put up a PowerPoint featuring three characters: Bugs Bunny, Daffy Duck, and Lieutenant Columbo. Every American kid who watched Saturday cartoons knows Bugs always had the upper hand, tweaking Daffy until he sputtered. “The bad guy wants to be Bugs Bunny, and he wants you to be Daffy Duck,” said Lormel to bankers at the ABA Regulatory Compliance Conference. He participated in a panel discussion with Holly Ford, senior vice-president, Bank of Marin, $1.2 billion-assets, Novato, Calif. Lormel, now a mortgage fraud consultant, completed a 28-year career as an FBI special agent, including creation and direction of the Bureau’s terrorist financing initiative following
the events of 9/11. He’s interviewed more than his share of what he casually calls “bad guys.” While not cops or special agents, bankers frequently need to do their own investigating of prospects and clients. They do so in the course of executing enhanced due diligence prior to opening relationships; investigating suspected internal and external fraud; and following up on potential laundering and terrorist financing. Increasingly, panelists noted, fraud, money-laundering, and terrorist financing go hand in hand. Play “Columbo” and use crooks’ conceit To do this job right, bankers must get into the bad guys’ mindset, according to Lormel, president and CEO, DML Associates, LLC, Lansd-
| AbA bANKiNG JourNAL | october 2010
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