KYC3 is growing – are you fit enough to join our team?

This is the career defining CTO opportunity you’re looking for!

Launching in 10, 9, 8, 7 … are you ready to drive the rocket ship to success with us? If you have experience with modern technologies like Apache Titan, Spark, Hadoop, OpenNLP, and Bootstrap then you should jump on board the KYC3 rocket now!

KYC3 has opportunities for Senior Software Engineers who will build and extend our state of the art technology. Join the core team behind innovative state of the art technology for real. We’re looking for full-stack developers who are passionate about innovating on big data and delivering great user experiences. You like to code and have an eye for clean, intuitive design. If you want to use your abilities to deliver the next generation of intelligence processing application technology, then join us to create engaging, easy-to-use, and visually delightful intelligence analysis applications that address complex user needs. Become instrumental in converting sales opportunities into deals faster working with our sales team. You and the technology team will be responsible for delivering solid production quality systems for KYC3.com and its enterprise and API clients.

KYC3 offers you a chance to get in a ground level, with equity options and a potential CTO position for the right candidate who can combine technical skills with business acumen in a readily accessible manner in front of clients and investors.

You should be motivated, very flexible, and able to work in an environment that constantly generates new ideas and new invention. Creativity and a willingness to take bold steps are a plus. Although some travel, mostly to Luxembourg and Switzerland, will be required, you can work form anywhere most of the time.

We’re looking for demonstrated full-stack experience in one or many of the following areas:

• Previous experience with Apache Titan, Apache Spark, OpenNLP, Hadoop, Elastic Search
• UI design including HTML, CSS, Javascript UI frameworks; e.g. Dojo, jQuery UI, Bootstrap, Flat UI, d3js,
• Web application (Model View Controller (MVC), My Virtual Model (MVM)) frameworks; e.g. Java Enterprise Edition (JEE), AngularJS, EmberJS, Sinatra, or Rails,
• Cloud computing environments; e.g. Amazon Web Services (AWS)
• Building applications using cloud APIs and Representational State Transfer (REST)ful services

Financial industry background or expertise would be a bonus.

Please express your interest via e-mail to support@kyc3.com with details of who you are and why you would make a great addition to the KYC3 team.

KYC3 is a startup with massive potential – we have won numerous awards and have offices in Luxembourg in the BGL BNP Paribas LuxFutureLab and in Geneva in the FintechFusion program – both prestigious accomplishments in their own. Our team collaborates openly and freely. We research new ways to approach difficult problems and quickly adopt new technologies. We work in cross-site teams and with customers in international settings.

https://kyc3.com
Luxembourg: LuxFutureLab, Boulevard Royal 59, L-2449 Luxembourg City
Switzerland: Fusion, Av. de la Praille 50, CH-1227 Geneva

Car Dealers: Do you know your KYC/AML obligations?

Luxury cars are often used to launder money

On March 6th, John Frank Mussari Jr., the owner of a luxury car dealership was sentenced to 2 years in prison for money laundering.

Cars, especially luxury cars, are often used to launder money.  Auto dealers routinely deal in transactions exceeding the AML regulatory limits, usually $10,000 or similar amount in Euros, Pounds or other local currency.

Mussari’s case is a very good example.  Mussari owned a dealership specializing in Ferrari, Lamborghini and other luxury cars.  Mussari developed a relationship with a “good client” who bought several sports cars from him.  Over the course of this relationship, he was paid $132,000 for a Ferrari 360 Spyder, $147,000 for a Porsche 911 Turbo Cabriolet and $320,000 for two Lamborghini Gallardos, among others.

In what could have been a scene out of Miami Vice, Mussari was stopped by Federal Agents leaving the client’s Fallbrook house in a yellow Ferrari.  Over the course of their relationship it became apparent to Mussari that the client’s source of funds was from drug dealing, yet he never reported any transactions to the authorities.  When this came to judgement in court, Mussari was found guilty and sentenced to two years in prison.

Clearly, it is important to have a reasonable KYC system in place in order to protect your business from the risk of money laundering.  Mussari probably only made a few tens of thousands of dollars on the sales, yet will spend two years in prison for it.  A basic KYC/AML procedure could have prevented this.

The first step is in obtaining the identification of the buyer and to have them declare the source of funds, e.g. savings, sale of another asset, or so forth.  Once this is done, some basic research should be conducted, such as checking sanctions and wanted lists.  If there is any hint of doubt regarding the client or the source of funds, a detailed media check should be made.  There are many tools available to do this, from self service KYC tools through to outsourced enhanced due diligence consultants who perform a full background check and provide a detailed report.

Mussari is a reminder that we should remember that auto sales also have an AML obligation that must be taken seriously.

Estate Agents: Are Your Clients Full of Dirty Money?

A poorly kept secret among those in the know, the Guardian has finally decided to expose the London property boom based on massive money laundering of dirty money from abroad for everyone to see.

The Guardian investigation revealed that more than 36,000 properties were bought in London area with hidden ownership and offshore structure companies, making this a haven for “billions of pounds” of ill gotten funds to be safely stashed in real assets.

The “how-to” sidebar describes a “corrupt official” who steals £30,000,000 from Russian taxpayers, layering the funds through a series of offshore and secretive jurisdictions using nominee shareholders and directors finally purchasing of one or more properties in London using an offshore company structure.

Aside from driving up prices in London with a subsequent adverse effect on honest buyers on the area, the lack of due diligence is allowing and encouraging corrupt behaviour by foreign officials and corrupt individuals in foreign countries with the obvious negative effect on the populations of those countries who often are in desperate need of infrastructure improvements and social services.

As long as the influx continues as it has in the past few years, there seems to no will in the UK to change the system, which only requires estate agents to conduct KYC due diligence on the sellers, leaving the buyer to be any corrupt official with cash to hide.

As a result, over 60% of the company owned properties in London are held by opaque offshore companies, mostly in the British Virgin Islands, Jersey, Guernsey and the Isle of Man.

Detective Chief Jon Benton, director of operations at the Proceeds of Corruption Unit, says,

In nearly all the grand corruption cases we investigate, we find – what we suspect is – proceeds of corruption being used to purchase high-value properties.

Even if KYC due diligence is not required on the current buyers, estate agents should already employ a robust KYC process in order to protect themselves today.  And when these shady buyers become sellers, we can anticipate some very serious due diligence problems to arise.

Estate agents would be wise to stay ahead of the curve and have an appropriate KYC process and tools in place before this happens.

Original article at The Guardian: London property boom built on dirty money

 

CBI Demands Less Anti-Money Laundering Regulation

Just today, the Confederation of British Industry said that the UK needs to come up with simpler and easier AML/CFT regulations or British business will suffer.  CBI boss, John Cridland, says that Britian will not meet its 2020 goal of 1 trillion pounds in exports because of current anti-money laundering (AML) requirements.

The CBI’s position is a blatant and crude display of the most longstanding problem for the compliance function: compromising to revenue interests.  In August 2014, FinCEN published a series of guidelines (PDF) regarding effective compliance of financial institutions.  One would hope that in the U.K. the FCA is issuing similar advice.  The second item in the FinCEN list is titled Compliance Should Not Be Compromised By Revenue Interests and it reads in part:

Compliance staff should be empowered with sufficient authority and autonomy to implement an institution’s AML program. An institution’s interest in revenue should not compromise efforts to effectively manage and mitigate BSA/AML deficiencies and risks, including submission of appropriate and accurate reports to FinCEN. An effective governance structure should allow for the BSA/AML compliance function to work independently and to take any appropriate actions to address and mitigate any risks that may arise from an institution’s business line and to file any necessary reports, such as Suspicious Activity Reports (SARs).

Relationships around CBI as seen by KYC3.com

Giving the regulator the benefit of doubt, if AML could be simpler without being less effective, it probably would be.  The regulations and guidelines are fairly clear and flexible.  The problem may actually not be with them.  Bank aversion to risk and to regulatory sanction may be driving the problem.  The problem may be in how banks and financial professionals have implemented their processes and the tools they have selected in doing so.  Client on-boarding and transaction monitoring are difficult to get right 100% of the time and can be very annoying when they go wrong.  Part of the solution is to provide business development and customer facing employees access to self-service KYC tools so that they can do a “sanity check” of any new client right on the spot and business can continue uninterrupted.  Customers never like “waiting for compliance”.

While anti-money laundering and counter terror finance controls are often an inconvenience, the potential gain in business may not outweigh the cost to society of invasive corruption, crime and terrorist funding that would follow relaxing KYC/AML regulations.

The SEC Wants More Suspicious Activity Reports!

SEC Headquarters in Washington D.C.

According to Andrew Ceresney, director of the SEC Division of Enforcement, the SEC is considering enforcement cases against brokerages that fail to report suspicious activity.

According to the SEC, many U.S. brokerages are simply failing to report possible money laundering.

Citing statistics of that put the average number of reports at just 5 reports on average per brokerage firm per year, it would seem the SEC has a point.

Indeed, it is hard to believe that with billions of individual securities transactions conducted amongst millions of counter-parties across the 4,800 registered brokerages in the United States, that just 18,000 to 25,000 total suspicious activity reports would be filed per year.

Ceresney confirms that the SEC is still trying to figure out why the firms are not filing SARs.  Could it be that their KYC/AML tools are not up to the task?  Or perhaps they simply don’t want to be bothered with the time and effort required to interact with the regulator in filing them… either way, when the SEC comes knocking, Ceresney made it clear that the action “will send a strong and clear message”.

Read more at Many U.S. brokerages fail to report possible money laundering: SEC official.