IIA Magazine Jun 2016 issue

A toxic culture is present when your work negatively affects your health – physically and emotionally. An example of such could be a change in management or management through fear and intimidation. The two options are to leave or to name the problem and discuss to make it better. Payroll should have continuous checks and balances. It is not good to report risks on an ad-hoc basis. Talent issues and development need to be addressed. There is a strong need to fight corruption. However, whistle-blowing hotlines might be underutilized, as employees fear retaliation after reporting. There are some companies which do not trust enterprise cloud deployments still.

The Fire Drill. Auditors can learn to deliver a focused message that results in management action. Effective planning of our work is the key. For instance, we can look at past audit findings. Next, one should compensate with competence, meaning backing up observation with data and experience. Sell with the passion of a champion. Findings should be sold to address a control weakness that is causing an unacceptable risk. One needs to communicate the big risks well. In the end, we need to deliver a focused message that can result in management action.

The Tech-Savvy Auditor. Effective use of audit technology can enable audit departments to provide valuable insights. Most IA staff are not familiar with IT or have weak IT backgrounds. This is not acceptable. Technology can lead to a more efficient audit and also might cut fraud losses. There is a need to improve the audit software. There should be a data analytics centre in-house. There is a need to review software usage.

Integrating Key Risks and Performance Indicators. IA can leverage its risk knowledge to improve operational performance and reduce risks exposures. IA can provide assurance on the achievement of objectives. IA can encourage the formalization of KPIs and KRIs. KRIs can serve as an early signal of increasing risk exposure. There needs to be a formal project charter. There needs to be a KPI framework with proper planning, reporting, monitoring etc. The key metrics need to be identified and a dashboard can help to present graphically the results. The KRI should be closely linked to the KPI.

Toxic Leaders, Toxic Culture. IA can identify unhealthy behaviors that may undermine the organization. Culture will affect an organization’s success. Therefore, identifying the toxic leader is important. Toxic leaders want power and control. These tend to be autocratic leaders. They could have a strong sense of entitlement and focus on themselves and not the organization. Exerting power through fear can undermine morale. They do not like to be challenged and seek to manipulate others. Closed-minded leaders think of ‘My way or the highway’. There is no need to confront the toxic leader. IA can refer the person to compliance or legal counsel. One can use behavioural psychology to analyse. For a more objective method, one can look at the reasons for turnover and examine turnover rates. One can also look at employee engagement survey results. One needs to use experience and facts as much as possible.

Analytics and the small audit department. No matter the size of an audit function, analytics can be implemented for big gains. How to go about using analytics? Some simple ones to consider are benchmarking, variance analysis, ROA, turnover etc. The analytics must have goals and performance measures. Selecting the right data source is the key and there is a need to verify the accuracy of the source. Brainstorming can help to identify key data. It is crucial to have a plan that will allow IA to continue to improve its analytics capability. It is important to attain small wins in analytics.

Business Risk. Keynote speakers for this year’s IIA International Conference identify emerging risks facing organizations. Cyber risks is at the top of the priority list for many. Ransomware is a big threat to hospitals nowadays. Other threats include politics, the economy and terrorism. Social media risks sometimes aren’t within an organization’s control. Auditors should use corporate culture to work in their favour. An organization must monitor the external environment closely. There should be a common understanding of what the risk appetite and risk cultures are. Audit needs to adjust fast and invest continually in education. IA now also needs to learn to be innovative.

An Anti-corruption Check-up. Capability maturity models can help organizations assess the effectiveness of the anti-corruption programs. This model was developed at Carnegie Mellon University. One can use the model to identify strengths and weaknesses. There are basically 4 levels of maturity. There are 7 components that form the basis of anti-corruption maturity model. There is a need to tally the scorecard too.

Craft Our Role. IA should create the role for themselves that is best for both the organization and their own personal development. IA needs to be ingenious, use creativity and resourcefulness when developing their role. Do not limit the scope to be too small. It is important to be familiar with the business in order to value add properly. The control environment needs to be evaluated properly. One can develop business acumen. It is crucial to ask the right questions. IA should network more with the other departments to build rapport and also to get a feel about the management style in the department. Learn to practise combined assurance. One can work with another dept for a joint review. This is the way to maximize external resources.

Fraud and related-party transactions. IA can identify red flags and reduce the risk and impact of related-party fraud. IA need to be able to recognize related-party fraud risks. Providing loans at below market rates is a red flag. Failing to disclose the related-party nature of the loan is a red flag. IA should try to identify related party transactions. Try to identify whether employees have link to companies that transact with the organization itself. It is also possible to compare cost variations among vendors to see how they differ from the average cost. The organization should not pay costs significantly above market prices.

Communicating Results. Sharing audit observations is one of the most important tasks auditors perform. Communicating properly can help enhance rapport. Make sure the observations are correct and are not challenged by management. Plan the timing of issue dissemination, which is as soon as possible. Try not to surprise management at the end of the audit. Write clearly. Exercise diplomacy.

‘One of the quickest ways to lose management’s respect is to make it clear that IA does not understand what is has been auditing. The answer is to take the time to learn the business, processes, and risk associated with the audited area.’

Care and Feeding of The Company’s Culture. How can IA help to ensure a healthy organizational culture? Auditing culture is certainly work examining. Healthy organizations should have guidance on norms and expectations and a healthy tone at the top. Transparency is important. Management should think long term and have a sound strategy. Ask yourself whether the root cause is behavioural or cultural in nature. The problem with culture is that it is not clear cut and might be hard to evaluate. Those who are toxic in nature might be held accountable and be responsible.




IIA Magazine Feb 2017 issue

IIA Feb 2017 Issue

Internal Auditors need to provide maximum return on investment and audit the right things. They need to understand the company’s strategic mission, objectives and KPIs. More auditors need to base their work on the International Standards for the Professional Practice of Internal Auditing.

The 5 emerging threats are (i) global economic uncertainty; (ii) increased regulatory burden; (iii) significant industry changes; (iv) business model disruption; (v) cybersecurity threats. Global economic uncertainty seems to a bigger risk in 2017 as compared to previous years. In the compliance space, with the new US administration, enforcement areas could see some change. Trump could change the legislative, regulatory and executive actions under Obama’s reign.

Although most companies feel that they could detect a sophisticated cyberattack, many of them do not have an adequate communication strategy in the event of a significant attack. Also, some of the BCP might be lacking. The continuous monitoring of cyberattacks is also a challenge.

Data Mining. By leveraging data, internal auditors can address issues beyond the reach of traditional analysis techniques. It involves making use of data which had previously no formulated relationships, patterns. Artificial intelligence, machine learning, statistics and database systems all come into play. Some of the techniques auditors can use are predictive modeling (IF), data segmentation (data clustering), neural networks (artificial intelligence), link analysis (links between records), deviation detection (red flags). The use of email mining can identify red flags in fraud etc. Social network analysis is also possible. IA should continue to look for ways to innovate their audit testing.

Intelligent Assessments. Use cognitive technology to help identify high-risk areas. These are intelligent computer systems that can aid in the performance of risk assessments. For instance, this tool can extract and analyze text from audit reports and analyze trends and high-risk areas. Natural language processing (NLP) has the power to tap into every sentence of every report to churn out more information. The machine will convert text to a certain structure and add meaning to the text and teach the computer to understand audit concepts. Words like ‘fraud’, ‘finding’, ‘auditee’ can be flagged out.

Turning Up the Heat on Fraud. A fraud risk assessment can help auditors take the organization’s ethical temperature. There are many ways to do it, example, through surveys, focus groups, workshops etc. The focus is mainly on fraud risk. It works best in small brainstorming sessions with operational management. Using the ACFE’s Fraud Risk Assessment Tool can be useful as it provides a structured approach. Risk assessment is about identifying where fraud might occur and the potential perpetrators. IA can do surveys to measure the ethical climate and voting can be anonymous. The results of the survey can be discussed with management. If there are high risk areas with fraud risks, IA can pay more attention to them.

The Accidental Discovery. Small or remote locations can be more susceptible to embezzlement, especially when they are not audited regularly. Confront someone after the facts have been reviewed. Look at the big picture. Controls that aren’t operating effectively are as good as them not being there.

Auditing what matters. Add value by selecting audits that contribute to achievement of strategic objectives. Auditors now should start looking at this area. Look at where the company spends the most money, what their main programmes are etc. Find out who is responsible for the strategy and make them IA’s stakeholders. Traditional audit activities can move towards strategy too. IA should use the COSO ERM framework in its entirety. The aim is for IA to a strategic partner to management. Don’t fear failure and find out more from the auditee by talking to them. The trick is to engage with processor owners easy and evaluate control design. IA should do the following: (i) Identify and define the risks; (ii) rate the risks; (iii) address risks in detail. Getting management buy-in is also important. The CAE must convince the AC to highlight the need for a strategic approach. Most IA wants to be a trusted advisor.

Core Principles and the QAIP. The new IPPF in 2015 can be incorporated into the QAIP to show that the IA is aligned with the mandatory IPPF elements. Learn to develop a concept and approach that is easy to understand. Core principles are a mandatory element of the IPPF. IA need to have general conformance with the Code of Ethics and Standards. The 5 steps are (i) establish a maturity framework (ineffective, partially effective, effective, sustainable, world class); (ii) map core principles with the standards and code of ethics; (iii) Define characteristics of maturity in 3 aspects of standards and QAIP characteristics, infrastructure and process characteristics, core principles and specific characteristics; (iv) perform internal and external assessment consistent with requirements of QAIP; (v) Evaluate and report maturity levels for core principles.

Champion of Trust. By modelling high standards of ethical behaviour, IA can help shore up faith in the organizations they serve. How can IA be a trusted advisor that is well respected? One way is via ethical commitment. IA needs to model ethical conduct in everything they do. IA must have the courage to sound off before things get in trouble. Ethical commitment is the key to a well-functioning IA. Ethics should come naturally to all. We also need to build ethical resilience (integrity, courage, honesty, accountability, trustworthiness).

Infusing IT Auditing into Engagements via a three-phase approach. The tech sector is growing at a rapid rate. Internal auditors also need to develop IT-related capabilities. IA needs to think about the future of integrated auditing. For a start, IA can incorporate IT perspectives into current audit engagements. This can involve documenting down what are the IT automated controls. One can also read IT policies or those on change management. One should also identify resources and pinpoint where they are stored (example: servers). Map core IT resources and data to key business objectives. Respond to IT risks and identify audit objectives that can add value. An integrated audit can help in this. In the middle term, IA can build an IT audit team, understand the IT framework like COBIT, perform IT audits and also foster relationships with IT and management. In the long term, IA can leverage on data analytics and obtain professional certifications (like IIA and CISA).

Breaking Down The Standards. With the right strategy, practitioners can divide conformance into bite-size, easily digested portions. The standards consist of attribute standards (series 1000 to 1322) and performance standards (series 2000 to 2600). Some IA may neglect the attribute standards and focus on the performance standards instead. However, both are very important. IA should perform an assessment of how well they are conforming to the Standards. An external assessment must be conducted once every 5 years. The audit work program needs to be reviewed and approved by the CAE before engagement commencement. Ultimately, conforming and understanding the principles behind the Standards are important.

Auditing Organizational Governance. IA has an integral role to play in improving the organization’s strategic performance. This area is becoming increasingly important in recent years. Governance reviews can help prevent governance failures. Less than 1 in 6 IAs conduct reviews for their organization’s strategy. Sometimes, it might be difficult to conduct a separate governance review. Rather, it might be easier to incorporate it as part of routine audits. One can focus on both the governance structures as well as the organizational culture. Some of the soft controls can include management competence/style; mutual trust and openness; strong leadership; high performance and quality expectations; shared values and understanding; high ethical standards. However, for some of these measures, there are no hard data to analyse. Hence, it is important for IA to read the signs. IA can also provide a more advisory role, which is educating board about developments and trends in the industry and governance best practices. In terms of strategic reviews, IA has much to work on. There is a tendency to focus on weaknesses in financial reporting etc.

Good Governance is All About Quality. The 5 quality rules are (i) customer focus; (ii) management leadership; (iii) Teamwork; (iv) Measurement; (v) Total commitment to continuous improvement.



Anti-Money Laundering in a Nutshell by Kevin Sullivan

Awareness and Compliance for Financial Personnel and Business

Many AML personnel like to check and select a box without understanding why. You need to understand the nomenclature of AML. Understand what is causing alerts in the AML system. It is crucial to understand the Bank Secrecy Act. The major players are the financial institutions, the regulators and law enforcement. These players need to work together in a dynamic environment.

What is Money Laundering?

Laundering is a method of ‘cleaning’ the funds so that it would not appear to be suspicious. The gangsters created businesses like Laundromats so as to ‘gamble’ and to ‘wash clothes’. This was to avoid suspicion as to how the funds came about. This term has been around since the beginning of the 20th century. Why does a bad guy need to do it in the first place? If you have drivers who are paid to carry suitcases from one vehicle to another without knowing what is in the suitcase, chances are that it is hard to prosecute such people. These are known as mules. The trick is to employ the mules without them knowing what is going on. So when they get caught, they have little they know which they can reveal. AML is often very tactical and you may not know that it is happening. The industry is suspected to be about US $2 billion a year. In early stages, it is difficult to tell whether the source is for tax evasion, funding for terrorists etc. The aim is to ‘clean’ the source and make it appear legitimate. This could be done via ‘smoke screen’ transactions. Banks will perform due diligence on its customers, such as examining transaction timelines and transaction activity compared with similar businesses out there. There needs to be a predicate offense to initiate an AML case. The 3 stages are (1) placement; (2) layering; (3) integration. Placement is the act of talking bulk cash proceeds and bring it to a bank. This isn’t easy. Carrying a wheelbarrow of cash isn’t a good idea. The right way is to use a small denominations and use a business vehicle that is reliant on cash. However, law enforcement requires suspicious activity reports, currency transaction and cross-border declaration rules. Layering is where the launderer needs to make many small transactions. This is to avoid people from tracking him. One way is to use shell companies or move the money to other jurisdictions. Another way is to buy large value items and then sell them subsequently. Transactions above $10,000 must be reported to the Treasury Department. FATF has created an AML template to follow. If law enforcement wants information from a bank, they will need to send a subpoena. However, this requires time and the money might have been moved away already. Integration is where the funds are assimilated into the financial system. This is hooray for the launderer. Launderers often engage in transactions which are less than $10,000 at one go. Greed is a common cause of laundering. Terrorism is a possible cause as weapons cost money. Lastly, some criminals have an unbalanced mind. Every part of the AML team is important and plays a defined role.

Money laundering is the practice of integrating the proceeds of crime into the legitimate mainstream of the financial community by concealing its origin. – Kevin Sullivan

Methods of Money Laundering. There are only 3 ways: (1) through the legitimate financial system; (2) physically moving the money; (3) physically moving goods. For the first way, structuring deposits over a period of days, with each less than $10,000, is an example. One could hire other people to make deposits through different bank branches but to the same account. This is known as ‘smurfing’. Another way could be bringing the cash off shore into a country with strong secrecy laws. Cash can be hidden in funny places and then smuggled out. Domestic wire transfers are a type of means too. Gold is a method of laundering, and so are money service businesses (US Postal Service). Common money transfers are made through western union, Amex etc. For MSB, customer anonymity is usually maintained. However, MSBs are required to report suspicious transactions to the Treasury department recently. Records of wire transfers must be maintained for transactions above $3k. It is generally more difficult to track cash in a country with strong banking secrecy laws. SWIFT is the international message service that FIs use to send their messages for wire transfers. For SWIFT, you need to provide information like the International Bank Account Number (IBAN). SWIFT is the system that allows the transfer and transmits information signifying the transfer of funds. There are many fields of information required before a wire transfer can take place. Casinos are a way of laundering money. Casinos are required to file currency transaction reports. However, casinos have brushed up their AML programs in recent years. There are 3 methods of trade-based money laundering: 1) over and under-invoicing; 2) black market peso exchange (commonly used); 3) hawala (underground banking system). Hawala has no regulatory requirements and is ethnic in nature. In addition, there are no money trails available. Understand the red-flags of money laundering. Always ask for documentation, and use authentication when dealing with third parties. Cyber banking via the Internet is getting more common. Some cyber banks do exist. However, note that they do not have deposit protection and that once the bank folds, your funds are gone. A launderer can lease ATMs to other people and they will in-turn lease to others. This reduces the level of due diligence that is applied on them. Most pre-paid cards do not require identification and launderers can maintain anonymity. This is a viable way for launderers, although it is slow. Vehicles are often purchased in the integration phase of AML. It is difficult to launder money using credit cards. Laundering via purchase of real estates is getting more common. For LLC, it is difficult to determine who the beneficial owner is as an LLC can be owned by sub-LLCs, which in turn might be owned by sub-sub-LLCs. For a cash intense business, laundering can be easy as once the dirty money is comingled with clean money, it is difficult to trace. Life insurance products can be bought using dirty money and then cashed out prematurely. Digital currency is a big thing and can be manipulated by launderers. They are not regulated and depositors can maintain anonymity. There are a huge variety of ways in which money can be laundered. As long as there is crime, there is a need for AML personnel.

Federal Regulations – The Laws, Rules, and Guidelines to Fight the Good Fight. We need to stop bad guys from laundering money. The Bank Secrecy Act requires FIs to keep AML programs. There are many legal tools in the fight against AML nowadays. Any cash transaction via an FI exceeding $10,000 must be reported on a currency transaction report (CTR). This must be filed with the FinCEN. There is also a need to maintain a suspicious activity report. If the cash or bearer instruments are brought out of the US, a report needs to be filled as well. Wire transfers are not under the CTR scope. A CTR is important in the investigation. In some countries, their limit is $15,000. For non-FIs, cash transactions more than $10,000 need to be keyed into the 8300. It is a crime under the Money Laundering Control Act to further criminal activity, conceal ownership of property etc. The Financial Crimes Enforcement Network (FinCEN) was launched in 1990. The Annunzio-Wylie Act in 1992 requires banks to complete and report a suspicious activity report (SAR). Several high-risk geographical areas were identified as ‘high-intensity financial crime areas’. The Patriot Act in 2001 gives Treasure the power to deal with US FIs for foreign AM. Enhanced due diligence for correspondent accounts that are maintained for certain foreign banks must be instituted. Banks should share information on terrorism and money laundering with one another. For KYCs, comparisons must be made with known or suspected terrorist or terrorist organizations generated by government agencies. FATCA helps combat tax evasion by US taxpayers who have assets outside the US. The next chapter will discuss on how to build an AML program.

Build a Quality AML Program. Sometimes, AML falls under the Compliance Unit. FIs may hate regulators because of too much regulation. Regulators will say that there are not enough regulations and that FIs compliance unit must be beefed up. Regulators have power to sanction your organization if you are not performing well. Once something bad happens, heads will roll. Fines can be heavy and banks should never try to cut corners. Regulators can only conduct random inspections on the bank. Law enforcement can make recommendations. An AML systems need to achieve 1) prevent money laundering and terrorist financing; 2) to report suspicious activity; 3) to train all personnel on legal and internal procedures. Educate staff on the importance of AML. Compliance training is important and it should be on-going in nature. Internal procedures must document risk and the controls to mitigate risks. It should document due diligence checks. KYC guidelines must be established. Policies must be put in writing and cannot be documented in the head. Policies must also be approved by the board. Policies should be updated on a yearly basis and there should be documentation on what triggers alerts in transaction monitoring. An organization must have a designated compliance officer. There needs to be a process to update the regulations and the training programme must be addressed. An independent audit should be performed on the AML system. High-risk accounts must be reviewed thoroughly. All employees must be trained in AML. Training should be conducted annually. It should cover all pertinent regulations. Identify the risk, which can be customer related or issue-related risks. Risks analysis, management and risk review needs to be conducted. Risks can include product risk, legal entity, business type, country risk etc. For high risk clients, increased level of due diligence and monitoring needs to be instituted. High customer risks include foreign FIs, PEPs, foreign corporations, shell-companies etc. High product risks include trade finance, private banking, electronic funds transfer, lending etc. High geographic risks include any OFAC sanctioned country, jurisdictions of primary money-laundering concern, offshore financial centres etc.

AML is not an income-generating component of the institution. An AML unit can be quite expensive, and, in and of itself, there is no return on investment. Hence, that alone is reason for some FIs to be hesitant to invest and develop a compliance unit any more than the bare minimum. – Kevin Sullivan

KYC and Customer Identification Program. The terms can be used interchangeably. It means identifying your customer, monitor his transactions and update his files. These pieces of information must be reviewed too. Customer identification is the first step, followed by KYC. KYC must be done at the onset of the customer relationship. The officer needs to verify the identity of the person and maintain records of his identity. Documentation as to what type of records will suffice should be written too. Account Opening documentation must be kept and maintained. Be wary of shell companies. OFAC maintains a free list of names, entities that have been sanctioned. The transaction monitoring unit will clear the alert and see if the risk can be accepted. A due diligence actually means a background investigation. Basic due diligence is needed in order to satisfy the regulations. EDD is usually needed for high risk customers. A checklist should be used for Due Diligence. Evidence must be collated. Documentation is important when it comes to an investigation. KPIs should not be set on how cases per day etc. Do not put a time clock on investigation. Never put time limits on AML investigation. If you outsource your DD, you should have thorough oversight on the vendor. Some banks might outsource this to third world countries. Sometimes, when there is a material change in customer information, an EDD is required. The good guy may not be able to catch the bad guy because the good guy only studies problems which are already known. Trust your gut. Cultivate an investigative mind by learning to ask why. When you sense something is not right, please ask why. Keep abreast with the latest industry developments. Make use of new sources and technology. Justify, articulate and define everything. Learn to create risk-based due diligence. It is very important to ask ‘where is the source of funds?’ Risk ratings might vary over time. If the customer is too high risk, it is advisable not to deal with him/her. Learn to allocate a risk scoring methodology. Gather intelligence sources and check against that. Obtain public records. You can even pay for certain databases. It is important to purchase good transaction monitoring software. If you clear it in the system, there needs to be a reason for it. Ensure that the system is not generating too many false positives. Understand your correspondent bank’s AML processes. You have to trust that they have performed the DD work. PEPs can be a senior political figure, a member of his immediate family, or a close associate. Understand some of the KYC red flags.

If you think it stinks, it probably does. You do this job every day, and you work with people who do this job every day. If for some reason the hair on the back of your neck stands up, then go with the feeling. – Kevin Sullivan

A Suspicious Activity Report (SAR) is born. Some banks file more than necessary to avoid being questioned by regulators. The FFIEC prescribes standards for supervision of financial institutions. Writing a complete SAR is very important. How do you identify what is suspicious? When should you file an SAR? Sometimes, the system can help you flag out suspicious cases based on set criteria. The amount of the transaction doesn’t really matter. There are 30/60/90 filings. SAR must be reviewed before they are sent to FinCEN. There is also a narrative that must be written when the SAR is filed. Be short and brief. Don’t leave blank boxes. Use language that people can understand. The auditor will hammer you if you are supposed to file but failed to. Law enforcement will pick particular SARs of interest for further checking. Law enforcements usually need subpoenas before they can request for information. FinCEN will compile statistics of SARs. It is useful to understand trend analysis.

Tips for Law Enforcement and Financial Crimes Investigators. Profit is an essential aspect of most crimes. This chapter is dedicated to the law enforcement investigator and the FI investigation team. An individual does not need a CPA to perform an investigation. Law enforcement personnel need to have the right training to perform their role well. The compliance unit of the bank will be involved. The investigator should talk to the law enforcement agency. There are numerous regulators for the different types of FIs. FIs take regulators seriously. Law enforcement look out for criminal activity while regulators look at whether the guidelines and standards are being adhered to. Some of the regulators are the SEC, Securities Exchange Commission, Federal Reserve bank etc. Not all law enforcement agencies have access to the FinCEN portal to view SARs. SARs help provide leads for law enforcement agencies. SARs are confidential and information should not be simply shared around unnecessarily. You may be able to obtain KYC documents from the bank. Most of us do not think like bad guys. Once a bad guy using a fictitious ID, it can foil your plans dramatically. Explore the internet for possible sources of new information. Use your instincts. Always learn to be suspicious. Discover the facts as best as possible. If your hair at the back of your neck stands, it probably means something is wrong. Consider different type of hypotheses. Read the Association of Certified Fraud Examiners (ACFE). Learn to invest in your career and develop your career. Don’t be afraid to spend money and time on educating yourself. Financial crimes are growing.

The Importance of a Global Approach to Money Laundering. Many crimes are transnational nowadays. Money laundering is an issue that affects everyone. The FATF consists of many member countries. There is also the Basel Committee on Banking Supervision. Wolfsberg helps to develop and shape guidelines for banks and regulators. The IMF has also been incorporating AML concepts into its procedures.

The New Financial Crime Model. You can contact law enforcement immediately after you file an SAR. There is an increasing trend of fraud and AML units combining and joining forces. Fraud and AML personnel should be cross-trained. However, do take note of the confidentiality requirement of the cases. 95% of all criminal activity is committed because of greed. There are various ways in which a fraud can be conducted. Please understand the red flags for AML cases.

handcuffs money

Dating Tips 106

Dating – Romantic Relationships, and Finding them in the Modern World by Adam Chorley

We live in a free world where online dating is rampant. However, marriage rates are decreasing and some people feel that relationships are not worth the effort to invest in. Modern people do not have good role models in life to learn from. The book will provide a guide on how you can find the right one and form a romantic relationship with. You can learn from others with poor past relationships. Do not hesitate anymore and commence your dating life.

Finding your Ideal Partner. The relationships that last are those between like-minded people. Research has shown this. Think hard about those people you have loved before. You have to genuinely like the whole person and not just certain parts of the person. You must really look forward to spending time with her. You and your partner should make dating fun and exciting in nature. Spend time with a person because you enjoy doing it. Always ask whether you are attracted to the person or not. Always seek to improve yourself.

People that stay together tend to be of a similar age, have a similar level of education and intelligence, have similar religious or political beliefs, and are in synchronicity about other things. – Adam Chorley

It’s all too common to date or lust after someone just because it’s convenient or because you’re afraid of being lonely. The reality is that you don’t really want to spend time with this person. – Adam Chorley

Rather than being a hunter looking to capture people he finds attractive, you need to be someone that is trying to enjoy and improve themselves while being open to love. – Adam Chorley

Where to Meet a Partner. You need to put yourself out there. If girls could pick guys up, where would you rather be to maximize your chances of being picked up? The place should allow for good and easy conversations. An art class is certainly a possibility. The best way to meet someone is through shared experiences. The trick is to find like-minded people. Venture out of your comfort zone and try new activities.

You can try a site such as meetup.com to find groups or clubs that meet regularly to talk and mingle. You could also try going to things that will have like-minded people attending such as music, sporting or art events. – Adam Chorley

Making a Connection. This chapter will teach you how to make a connection. If there are no girls at the events you attend, maybe you should stop. However, do not approach the girls immediately during classes as this might seem creepy and all. Try to be friendly at the start. Do not be shy and learn to ask for a girls’ number. You must look attractive and dress well. Sincere confidence is the best trait at your disposal. Hygiene is really important. Hair and clothes are important as well. Clothes should fit snugly so as to make you look attractive. However, do not try to be excessively vain. Be comfortable with who you are. Give your opinions when they are due. There is no need to blindly agree with the girl. Try to ask more questions if you are an introvert. Simply make observational remarks when you see her. There is nothing wrong with expressing your interest in them. Build rapport by spending more time with them. Have lunch with them etc. Be positive during conversations and talk about shared interests. Give eye contact and touch another person to flirt with her. However, test the waters first before touching her. Lean forward and try to sit closer to her if possible. Flirting should be natural once you are attracted to someone. You need to assess the vibe first.

If you can’t see anyone at your chosen event that is appropriate for you, don’t give up just yet. You might meet someone through a like-minded friend found at this event. – Adam Chorley

Be warned that summing up the courage to say hi to someone on the street or in a bar require very different approaches to meeting someone whilst doing an activity. – Adam Chorley

Flirting should not be used as a way of testing whether someone likes you or being used intentionally to try and seduce someone. – Adam Chorley

Getting a Date. There is no right date on when you should go on a date. It is all dependent on how you feel etc. Dating should be hassle free if she already likes you at the start. Dating should not be stressful especially if you have already met her in previous events. If you are confident, you can ask the girl immediately out on a date. Have a plan as to where to go works. You might ask her about her availability. One trick is to ask what are they doing later and if they are free to hang out or not. Asking over online chat works too. Walk and talk dates are good too. A park/gallery should be good. Picnics are possible too. Visit the botanic gardens or something. Your first date should give you time for chit-chat. Keep your first date organic and cheap. Do not ‘bribe’ the girl into liking you.

Don’t worry about rejection… If you do get rejected, avoid putting too much energy into mulling it over or trying to convince them they were wrong. If they aren’t interested, it wouldn’t have worked out long term. – Adam Chorley

Realistically where you go on your date won’t matter too much if you are on a date with a person that you enjoy spending time with. – Adam Chorley

Do be firm with your plans and avoid confusion or the dreaded feeling of not knowing how to kill the rest of the evening. – Adam Chorley

Having a Good Date. Don’t be too judgmental during a first date. Wear nicer clothing during the date. A gift is optional. Do not be late. Try to seek common topics where both of you will enjoy immensely. Spice them up with tough questions to keep them on their toes. Make the effort to be funny. Compliment the girl easy in the relationship. Do not touch excessively. There is no need to end the night with a kiss. Go wild with the girl. Do not treat the date that seriously. It’s just a date. Do not reveal too much about yourself or the negative bits about yourself.

People tend not to enjoy whining or repetition too much. If you talk about work, tell interesting stories or try to be positive. Don’t tell them too many negatives about yourself or why you hate your job. Do talk about your passions and ambitions. – Adam Chorley

If you wish to drink, drink enough to let conversation flow, but avoid getting drunk and doing things you will regret. – Adam Chorley

Making it Long Term. Learn from bad experiences during dates. There is no need to be too clingy after your first date and text immediately. Yet, do not text after 2 days or so. That is really not advisable. You have to judge whether she had fun during the date. The more time you spend with each other, the luckier you will get.

A good tactic is to make sure you have talked about things you are interested in doing during the date to make a follow-up message easy: if you talked about a film you are both interested in seeing then go see it. – Adam Chorley


Dating Tips 105

The 10 Laws of Alpha Male (How to Become Alpha Male and Attract Women) by Jason Travis

This book will teach you what it takes to be an alpha male. This book will highlight the concept of alpha male. If you aren’t in control of your life and you tend to follow others, chances are you are beta. Beta and omega men aren’t attractive to girls. An alpha man is assured and leads and will take control of the situation. He does not ask people for permission to do things. He calls the shots. He doesn’t hesitate and takes action immediately. He is the guy who everyone else looks up to. You must become the alpha male.

Purpose of Life. They know what they want and lead fulfilled lives. All that matters is that you have a purpose and are driven towards it. Take steps towards it. Arnold Schwarzenegger is an example of a guy who took up bodybuilding when he was very young. There are 3 steps you can take to move in this direction. Step 1: Work Out What You Want to Do. Look at your life and see what motivates you. You must dream big. Step 2: Write Down your Purpose. That thing will become real once it’s written down. Step 3: Move Forward Every Single Day. You will reach your goal if you keep moving forward towards it one step at a time. Keep working at your goal. People will be able to tell that you have a goal and it will have a huge impact of how others perceive you.

Confidence. Don’t let insecurities get in your way. They harness nervous energy and use it to their advantage. The alpha male doesn’t care what others think and he simply walks over to talk to a girl he likes. He doesn’t care about what others think of him. You must think that she is beautiful and that you must get to know her. Alpha males do not let emotions control them. Harness the negative energy to your advantage.

Masculine Energy and Presence. Women find it attractive. This is defined by being assertive and using of logic/analytical thinking. They like men who take control of the situation. Alpha males feel good from the inside and do not need any external validation from others. Masculinity should come natural to men. If you let situations control you, women will not find that to be attractive.

Alpha Communication Skills. The key is to use a deep and manly voice. Also, slow down your rate of speaking. Steer the conversation in the right direction if you have to. Inject humour into the conversation. Also, you can laugh at yourself so as to make others feel better and more comfortable. Give genuine compliments. Give eye contact and adopt a strong posture. Most of the US presidents are alpha males who are supremely confident. Allow time for others to speak and chip in with their contributions. Alpha men compliments others and have no ulterior motive.

Alpha Social Skills. Don’t compare yourself to others. Also, don’t have that feeling that you need to feel superior to others than you are speaking to. You already have the permission to talk to anybody you want. Stop competing with others and try to match their achievements. If you want to talk to someone, just go do it. Let nothing hold you back.

Alpha Male Style. Dress well and carry yourself as the alpha male. Your clothing must fit properly. Get T-shirts to fit snugly around your arms and to make you look bulky. Get a few pairs of jeans. However, do not get skinny jeans. Buy a couple of suits. Also, buy a great timepiece. You need to feel comfortable in your own skin.

The only accessory you need is a watch, a good quality masculine timepiece can make you look more alpha than ever! – Jason Travis

Body Language. Displaying the right body language is the key. Stand with an open chest, straight back and neck and with legs apart. Walk with slow balanced steps. Take medium length steps. Give with your body open and do not fold your arms.

How to live life on your own terms. The alpha male makes his own decisions. Grant yourself permission to do something and never wait for anyone. Sometimes, you need to say ‘no’ so that you have time and energy to pursuit your own hobbies etc. Keep working at your hobby until you realize that you are too old. The key is to be alpha and do not let anyone take control of your life.

Developing an Attraction Mind-set. You must have the mind-set of attracting the perfect woman. Do not settle for less. Keep telling yourself and project the image that ‘I am attractive to women’. Always be ready to attract women. Develop the abundance mentality. This means not to act desperate in front of women as you know that there are many out there. Be calmed and relaxed about things. The alpha man lives for the moment. Go out and embrace life. Always keep yourself in an open state to attract women.

The beta male always live for what might happen tomorrow: he puts off asking a girl out in case she says no, he puts off trying new things and having new experiences in case he doesn’t enjoy it, and he spends his life wondering ‘what if’ rather than looking back at the things he’d done. – Jason Travis

Living the Alpha Male Healthy Lifestyle. An alpha male has a fit and toned body. He desires to look good and feel good about himself. This sends out a good signal. Learn to eat well and exercise well. The harder you work, the better your results will be. It definitely helps to look good as this makes you more attractive to the women out there.


Dating Tips 104

Fifteen Easy Ways to Approach Women, Be Confident and Find Love by Michael Mayweather

Dating Advice. Approaching women can be tough. Men sabotage themselves when they have a fear of rejection. Sometimes, you may forget what to say etc. Some men have limiting beliefs, such as believing the girl is too attractive for you. You have to let go of these beliefs. Women like confident and charming men. Certain tactics work better for certain situations.

Coffee Shops. This is not the ideal place to pick up women. There may be people studying. Sit down beside a cute girl when you see one. You could ask her anything, like what is she working on etc. Start off the conversation in a light hearted manner. Later, you can find out more about her likes/hobbies etc. Flirt and then get her number at the end of it all.

Bars. Your guy friends group can approach a group of girls. Try to listen in and laugh when they cracked a funny joke. Try to get close to their group first. Ask the girl you like for an opinion on something. Use your friends to distract the other girls who you are not interested in. Try to isolate her from the group after you first made contact with her.

Clubs. The noise is too loud. Therefore, you need to rely on body language and physical presence. To get her attention, offer to buy her a drink. Tell a joke or tease her at the bar area. Later, offer to dance with her. At the dance floor, you must be a great dancer if you want to pick up women. Emanate confidence and pull the women to dance with you. Try a dance-off if you are good. When the opportunity arises, pull her away from the group.

House Parties. You can play games with girls and guys. These will make the girls more attracted to you. If there is a quiet area, start talking to her and ask her who she knows.

Events. Talk to the girl about the event in general and why you are attending such an event. Don’t let the opportunity pass you. The good thing about events is that you already have something in common with her. Therefore, one should not let the opportunity slip.

Concerts. Try to approach her in between songs. Dance with her when the music starts again. Tell her how much you like the band. Get hyped up when you approach her in between band sets. Later, suggest to her that you want to appreciate the music together with her.

The Dog Park. Women can’t resist if you are walking a cute dog. The dog is your greatest wingman. Draw the girl in and get her to play with your dog too. Alternatively, you can play with her dog too.

The Beach. This is challenging as there might be hot guys as competition. Approach 1 on 1. Look at her face and not her body as much as possible. Do not make your intentions clear. Invite them to play ball with you in the water.

At Work. Rely on your charm. Complement her and make a joke about someone else. Tell her that she is cool and then ask for her number.

The Street. This is one of the toughest ways to approach someone. Think fast and be witty. Comment about what she is wearing or carrying. Compliment her dress/attire. Probe deeper to find out more about her. The other tactic is to tell her that you only asked her because you wanted to talk to her and wanted to get to know her more.

Public Transport. It is difficult as the train might be crowded. You must not worry about what others might think. Just talk to her about anything. Tell her how cramped the train is. Ask her about her work. Make her feel comfortable and you must be friendly. Do not start with flirting as things might get awkward.

The Grocery Store. Ask the girl for a recommendation for a product. Be creative and simple. You can also recommend a recipe for her. Keep the conversation flowing at the check-out. The key is to ask for her number after the checkout.

The Gym. Girls don’t like to be hit on when they are exercising. Flash the girl a genuine smile. If she smiles back, it is a sign that you can chat with her. Ask her how her routine is going .You can leave her alone next time, but this gives you the window to continue talking to her in future. Talking after is preferred.

Fitness classes (like yoga, pilates) are actually a great workout alternative which I’d recommend to anyone anyway, but as a bonus they’re typically dominated by women. If you spot a cute girl in a class you’re taking, you can chat to her either before or after class – never during. – Michael Mayweather

Girls in Groups. The trick is never to express interest in the girl you want right at the start. You must disarm the dominant alphas. Tease the group and talk to the men first. Disengage them so that they won’t think you are ‘creepy’. Ask about her friends. Finally, close by moving her to a quieter spot.

Using a Wingman. Flirt openly with her. Use a wingman to help you to distract the other girls.


Dating Tips 103

Why am I single? How to find the love of your life by Bill McDowell

This book contains proven strategies. Learn to look deep at the problem. There are 11 chapters to this book. There are just so many reasons why people are still single. Singles are becoming increasingly common in this modern age.

You have high standards. You can set criteria but the thing about love is that you may just fall in love with someone completely opposite from your set criteria. If you are waiting for Brad Pitt to come, chances are that he will not. The issue is when you have an actual list of standards. Sometimes, you might break up with someone over a little squabble. This is very unfortunate indeed. You might feel too superior to go out with the person. Real people are not actors and actresses. Your friends are telling you that you are too picky. It is one thing to have good self-esteem but another to have high standards in women. In this case, it is necessary to adjust your requirements. Talk to people and actually make a genuine effort to know them.

Being single is a defense mechanism. Some of them might have poor past relationships and do not want to try for a new one anymore. Your past might hold you back from wanting to be in a relationship. However, there is a need to let go of your past. Go for a long holiday and let go of the past so that it will not haunt you anymore.

Low self-esteem. Some people stay away because they do not want to be hurt. Always try again. This often indicates a lack of confidence in relationships. You always blame the other party for the relationship’s failings. You crave for attention and do things to test whether he likes you. Some people are guarded and do not want to share things about themselves. There is a chance you might become overly obsessed with the person. You look for someone who is financially wealthy. You might look for necessary insecurities which might not be even present at all. Intimacy scares you. You should learn to stop pretending to be someone you’re not. Understand that it is okay to make mistakes. Learn to help others who are in need. Trust that you have made the right choice. Learn to be responsible for your actions.

If you choose to be with a person, do not be half-hearted about it. If you decide to do something, immerse your whole self into it. Do not stop until you achieve something. If you decide to love someone, give him or her your all. Do not worry about what could happen or if you are meant to be. – Bill McDowell

Arrogance. Extremely high confidence leads to arrogance. You may start to contact your partner without giving her eye contact. Arrogant people feel that it is okay to be late. You feel like you know it all. You blame your partner for everything. You start being condescending towards others and put them down. Be sincere and compliment and exercise empathy towards your partner for the relationship to work. Ask them whether they are okay and tell them it is okay to share their problems with you. Admit your wrongs and understand that fighting might not be necessary all the time.

It is all about financial security. Some men like to spend on themselves. As a result, they like to remain single. Ambition is good. Do not worship money. Do not feel like your partner is a threat if she earns more than you. You don’t have to choose between money and a lover. Chances are that you do not know how to spend wisely.

You are a gold digger magnet. Some guys are gold diggers. Learn to stay away from them. Gold diggers tend to hang out amongst other gold diggers. They like to ask a lot of questions on your financial background. If the girl refuses to pay for dates, chances are that she is a gold digger. She often receives favours due to her skimpy dress sense. They use other people as stepping stones. Do not use your status to attract women. The ideal case is to find someone who will love you despite your economic status.

You are obsessed with the wrong person. Learn to move on if this is the case. Do not simply obsess over one person. Humans are never easily contented creatures. We are hardwired to love what we cannot have. When you wake up, tell yourself that you can overcome these obsessive behaviours. Learn to divert your energies into other hobbies and make yourself become a better person. It is okay to ask for help. Pamper yourself by going to the movies and giving yourself a treat.

Past Abusive Relationship. There are different types of abuse. One of it is physical abuse. The other is emotional abuse. There are also verbal, economic and mental abuse cases. People who have suffered before then to close up and be reclusive in nature. This can be very dangerous indeed. The solution is to seek comfort in your friends and loved ones. Learn to care for yourself and pamper yourself. Do things that make you happy in order to recover. Look out for warning signs of abuse and be careful who you choose in future.

Wrong Location. Are you in the wrong city? Online dating is convenient and it is bringing people together. Be honest in your online dating profile. Don’t reveal everything online. Learn to be patient and do not send aggressive messages. Know when to stop and do not harass the other person. Learn to take the relationship offline. Embark on an adventure and sweep them off your feet.

You are not trying hard enough. Try to lure the potential partners in. Always say yes to chances where you can meet new people. Hang out at trendy places. Do not flirt unnecessarily. It is better to be friendly rather than flirty. Be mysterious and let the girl invest in you.

Take care of yourself and put some effort into looking good. Even if it is a regular day at the office or the gym, make sure that you look your best and you always smile because you never know when you are going to run into your soul mate. – Bill McDowell