John Pyrik, the web investigator, recommended the following websites for AML duties in the Exploring the Internet panel:

Wondering if a business exists?
http://maps.a9.com -- gives street level pictures of businesses
http://local.live.com -- a new tool from windows for maps

Dead links when doing due dilligence online?
http://archive.org -- a look back on web sites

Wondering if a person exists?
www.zabasearch.com -- gathers information from different public sources
www.birthdatabase.com -- has the archive for 120 million people
www.zoominfo.com -- a complete profile from Internet

Name check
www.arabdecision.com -- names from the arab world
www.rulers.org -- pollitically exposed persons directory

Another news article on yesterday's prepaid card panel from Bloomberg, Criminals using gift cards to foil police.

In the second panel of the day, Karen Burgess, Senior Adviser, Compliance Inspections, Examinations for the U.S. Securities and Exchange Commission (SEC), discussed common AML deficiencies that surface during broker-dealer examinations.

These are:

• Policies, procedures not approved by senior management, in writing
• No independent audit
• CIP deficiencies
• Suspicious activity detecting, reporting deficiencies
• Lack of SAR documentation
• No training of key employees
• Lack of correspondent account certification
• No OFAC screening, old accounts, third-party wire transfers

In fiscal year 2005, the SEC conducted 2,200 AML examinations in which 41 percent of firms examined by self-regulatory organizations and 58 percent examined by the SEC had AML deficiencies, Burgess said.

But by keeping some things in mind, you can improve those deficiencies, according to Stephen Gannis, Chief AML and U.S. Sanctions Officer at Fidelity Investments in Boston. Gannis discussed five elements to keep in mind:

1. Interpretation - The #1 rule is to come in with a command of the regulations and a command of your own business, said Gannis.

2. Coordination and impact of examines in different business units - You won't be able to produce AML information for regulators if you don't work with other business units. A compliance department can't answer AML questions alone.

3. Relationship of independent testing - Look at the test, at the results, and follow up.

4. Enhancement - Programs are constantly evolving. It's important to think about examintations and constant improvement.

5. Empathy toward your examiner - It's a "tremendous asset."

Experts focus on danger behind prepaid cards, from this morning's Miami Herald.

And from Reuters yesterday, US targets prepaid cards to fight financial crime.

Lisa Arquette, associate director of the new Anti-Money Laundering and Financial Crimes Branch of the U.S. Federal Deposit Insurance Corporation, shared advantages and disadvantages of relying on third-parties for customer identification and due diligence.

Pros

• Meets international standards (Financial Action Task Force and Basel)
• Reduces time, cost of obtaining, documenting CIP (customer identification program) information
• Streamlines account and transaction processing of known customers

Cons

• Indirect verification of customer identity
• Procedure may not comply with internal standards
• Relationship must be managed

Said by a speaker during an audits panel yesterday:

"My prediction is that the convenience store industry is going to end up designated [as a financial institution], and I hope I am not around when that happens."

- Tom Atkins, Senior Examiner of the Federal Reserve Bank of Dallas.