Have Latvian «pocket-banks» really cleaned up?

Here we go again, RIETUMU BANK in Latvia

Why have RIETUMU not had the same fate as ABLV?
ABLV that in 2018 was as stated as a bank of “primary money laundering concern” by the US and quickly forced to close down.

RIETUMU was fined in 2017 for AML deficiencies and for having been used to channel funds to the North Korean dictatorship (together with NORVIK BANKA) and recently fined in France due to AML. RIETUMU has business in Russia, Cyprus, Belarus and more.

To identify if your financial institutions have any current and or historical exposure to RIETUMU (or any other FI with AML deficiencies or known problematic transactions, regardless of country):

·        Add the SWIFT/BIC of the target FI (for RIETUMU add RTMBLV2X and any other related company SWIFT/BIC in their group in other countries) to your transaction- monitoring and payment screening system(s) to ensure that you will get “alerts” related to your customers transactions with customers of that FI.
·        Add some “smart” and relevant thresholds and pre-defined risk indicators.  
·        Initiate a post-transaction analysis, start with going back to the first time the bank was reported in news and media with AML deficiencies (3-5 years is recommended).
·        Look for both “classical” and “old” modus operandi covering risk indicators found in the payment of your customers with customers of the target FI that seems initially to be typically “offshore”, “onshore” and shell companies (i.e., LTD, LIMITED, LLP, LP, L.P., S.A., A.G., AG, SA, INC, CORP)
·        Look especially for USD transactions as this could potentially have huge negative impact on your FI if you have facilitated suspicious transactions and transactions related to OFAC sanctions evasions in USD
·        Look for the “classical”; even amounts and close to even amount transactions (regardless of currency)
·        Look for payment message/text information that seems to be “mass produced” (but don’t disregard the others)

The benefit of implementing these measures are:
·        Identifying your own customers that you didn’t understand the real risk of or have the real risk level assigned to, i.e., Low/Medium Risk customer that actually should be High-Risk due to their transaction risk
·        Act on any potential risks not previously identified that could involve your FI in any money laundering scheme or sanctions evasions scheme (you will still be hold responsible for historical transactions)
·        Understanding how old modus operandi has change and what is the current modus operandi and what could the predicted modus operandi in the near future

When it comes to RIETUMU, Wolfsberg CBDDQ is NOT enough!

#ofacsanctions #moneylaundering #laundromat #transactionmonitoring #transactionalanalysis #sanctionsscreening #sanctionscompliance #financialcrime