{"id":2619,"date":"2016-09-08T00:00:00","date_gmt":"2016-09-08T00:00:00","guid":{"rendered":"https:\/\/diskdrive33.com\/mks\/2016\/09\/08\/shell-shocked\/"},"modified":"2018-08-31T13:16:18","modified_gmt":"2018-08-31T13:16:18","slug":"shell-shocked","status":"publish","type":"post","link":"https:\/\/diskdrive33.com\/mks\/2016\/09\/08\/shell-shocked\/","title":{"rendered":"ACFE Magazine \u2013\u00a0Shell Shocked"},"content":{"rendered":"

\"Shell View PDF version of article<\/span><\/a><\/p>\n

The leak of the huge cache of offshore data in the Panama Papers reveals decades-old shell companies \u2014 many of which fraudsters have used to launder money and hide crimes. How can fraud examiners use the data? Will the revelations cause governments to overcompensate with overbearing regulations? Or will the expos\u00e9 ultimately be ignored because unethical systems are so entrenched?<\/strong><\/p>\n

The shelling continues. The Panama Papers have revealed scores of global politicians, business leaders and celebrities as beneficiaries of shell companies \u2014 some suspicious, others legitimate. On April 3, the International Consortium of Investigative Journalists (ICIJ), German newspaper S\u00fcddeutsche Zeitung and more than 100 other news organizations released a leaked cache of 11.5 million records from the Mossack Fonseca law firm in Panama (http:\/\/ tinyurl.com\/h22lx7c). Some 400 journalists secretly collaborated for more than a year to publish or broadcast the story on the same day.<\/p>\n

And on May 9, the ICIJ posted a searchable database of the nearly 214,000 offshore entities created in 21 jurisdictions \u2014 from Nevada to Hong Kong and the British Virgin Islands. The database also displays information about more than 100,000 additional offshore entities ICIJ had already disclosed in its 2013 Offshore Leaks Investigation (http:\/\/tinyurl.com\/hl3kzht). Just plug in a name, and find the dirt.<\/p>\n

We\u2019ve read all those headlines, but what do the Panama Papers mean for fraud examiners? Can we use these databases in our jobs? Will the release of this immense amount of information even incrementally nudge corporations toward greater transparency and encourage governments to greater regulation?<\/p>\n

Work for fraud examiners<\/h3>\n

\u201cFor those fraud examiners who have skills in investigating international money laundering, bribes, tax evasion and similar acts, it will present many opportunities for investigative work,\u201d says Regent Emeritus Bruce Dubinsky, CFE, CFF, CPA, managing director at Duff and Phelps, LLC.<\/p>\n

\u201cFor example, hedge funds that operate throughout the world should be examining the entities with which they\u2019re conducting business to ascertain if in fact they are mere shell companies,\u201d Dubinsky says. \u201cThe last thing you want if you\u2019re a hedge fund are the regulators \u2014 or worse yet \u2014 law enforcement showing up on your front step with subpoenas. That doesn\u2019t make for a good Monday morning.\u201d<\/p>\n

Dubinsky says multinational companies also need to take a close look at the list of entities with whom they\u2019re doing business for the same reasons.<\/p>\n

\u201cYou\u2019ll most certainly see an uptick in enforcement from the IRS and other taxing authorities worldwide. If you have a tax background as well, working with clients and assisting them with these investigations will be very important,\u201d Dubinsky says. \u201cMost law enforcement policy makers will tell you that using an independent outside party to conduct the investigation or assist during an investigation brings much needed credibility to a situation that already may be sorely lacking such credibility.\u201d<\/p>\n

Martin S. Kenney, CFE, managing partner of Martin Kenney & Co., an international fraud and asset recovery law firm based in the British Virgin Islands, says the Panama Papers will be helpful to fraud examiners as a source of leads and intelligence for investigations. He laments, however, that the ICIJ\u2019s release of names of the companies, directors and shareholders isn\u2019t helpful enough for fraud examiners.<\/p>\n

\u201cWe need access to the emails, the invoices, the payment records, and most importantly of all, the \u2018ultimate beneficial owner\u2019 (UBO) identification and knowyour- customer (KYC) documents collected on each company formed by Mossack Fonseca,\u201d says Kenney, the 2014 recipient of the ACFE\u2019s Cressey Award. But therein lies the crux of this massive information deficiency. Corporations (and shell company formation firms) should use their KYC protocols to identify the UBOs, but many don\u2019t do it for fear of what they might find. Or they just don\u2019t care.<\/p>\n

Shadowy shell games<\/h3>\n

Before we delve into the shady side, it\u2019s important to know that all shell companies aren\u2019t necessarily illegal. \u201cThe mere use of a corporate entity in jurisdictions that protects the disclosure on the actual owner or owners is not, in and of itself, a problem,\u201d Dubinsky says. \u201cFor instance, many celebrities use corporations and LLC\u2019s in these jurisdictions to provide proper privacy and for legitimate asset protection from potential lawsuits.\u201d<\/p>\n

Dubinsky says that shell companies, as the name suggests, are basically hollow. \u201cThey\u2019re legally formed entities that have no employees, no real operating business, no real assets \u2014 other than maybe money passing through them and in many instances, no real business purpose,\u201d he says.<\/p>\n

Kenney says the term \u201cshell company\u201d is vague. \u201cIf it is formed or used for benign purposes \u2014 such as to hold legitimately earned assets or to give effect to a lawful plan of tax avoidance \u2014 there is nothing wrong or improper about its use,\u201d Kenney says. However, if it\u2019s a company that\u2019s formed to conceal or wash the proceeds of a fraud, Kenney says, it\u2019s but a \u201cmask\u201d that a fraudster \u201cholds before his face in an attempt to avoid recognition by the eye of equity,\u201d or so said English High Court Justice Russel. [Jones v Lipman (1962) 1 WLR 832]<\/p>\n

Jeffrey Robinson, bestselling author and an expert on organized crime and fraud, says that law enforcement has to force the \u201cgatekeepers\u201d to recognize the UBOs even when the beneficial owner is 15 borders and 30 shell companies away. \u201cBecause once you know who\u2019s got the money and where it\u2019s coming from, you can say this is a politically exposed person or it\u2019s drug money or it\u2019s money laundering or tax evasion or it\u2019s just some guy trying to hide the money to keep his ex-wife from it,\u201d Robinson says.<\/p>\n

\u201cThese guys in Panama have been selling time bombs for the global economy because they know what these things are being used for and they don\u2019t care about the beneficial owners. They distanced themselves from any responsibility,\u201d he says. \u201cIf you sell me a shell company knowing that it\u2019s owned by another shell company and way on down the line you don\u2019t care who the beneficial owner of the money is, then you\u2019re aiding and abetting because you should be made to know. And that\u2019s how you change things.\u201d (Robinson says he exposed Mossack Fonseca in 1998. Listen to \u201cAn expert\u2019s take on the leak,\u201d ACFE. com\/panamapapers, a podcast interview with Robinson, by Sarah Hofmann, ACFE public relations specialist.)<\/p>\n

\u201cI\u2019ve worked on dozens of highprofile, offshore, tax-shelter cases both for the U.S. Department of Justice \u2014 civil and criminal \u2014 and the IRS over the past decade,\u201d Dubinsky says. \u201cIn every single one of the cases, offshore shell corporations were formed for the sole purpose of evading U.S. income and gift taxes. In many of the cases, the so-called corporate board directors used were the same names as in other unrelated tax shelters. \u201cAnd quite frankly, it\u2019s not just about offshore shell companies,\u201d he says. \u201cManyof the abusive tax shelters I\u2019ve investigated also involved the use of domestic shell corporations established in either Nevada, Delaware or Wyoming, all of which have corporate entity laws aimed at shielding the identity of the true beneficial owners of these entities.\u201d<\/p>\n

No shock and awe here<\/h3>\n

Despite this article\u2019s headline, Kenney, Dubinsky and Robinson aren\u2019t surprised what the Panama Papers have revealed. \u201cMossack Fonseca has frustrated some of my firm\u2019s fraud investigations in the past,\u201d Kenney says. \u201cThe firm had a reputation for not complying with KYC anti-money laundering [AML] rules robustly. Arguably, an apparent culture of non-compliance with AML rules represented the firm\u2019s competitive advantage.<\/p>\n

\u201cWhen the Panama Papers first broke, Ramon Fonseca was quoted on a national Panamanian TV news show as saying that his firm \u2018could bear no responsibility\u2019 for what its customers would do with the companies that it formed,\u201d Kenney says. \u201cHe likened Mossack Fonseca to an auto manufacturer where, he argued, \u2018no one charges the manufacturer with a crime when one of its cars is used as a getaway vehicle in an armed robbery.\u2019 This is a silly non sequitur. Mossack Fonseca has been a party to a bargain with its regulators for many years.<\/p>\n

\u201cThe Panama Papers reveal that in one two-year period, one offshore regulator requested the identities of the UBOs of 100 companies administered by Mossack Fonseca,\u201d Kenney says. \u201cIn only five of the 100 instances in question was Mossack Fonseca able to show the identities of the UBOs involved.\u201d<\/p>\n

Dubinsky says it\u2019s hard to know exactly what due diligence, if any, Mossack Fonesca conducted. \u201cThe fees earned by these so-called \u2018legal professionals\u2019 involved in providing services such as setting up complicated and often illegal off-shore tax structures \u2014 and frequently also finding directors and nominee shareholders who act as mere straw men \u2014 are exorbitant.<\/p>\n

\u201cI\u2019m not referring to the quick, online incorporators who charge $1,000 to set up simple shell companies. I\u2019m talking about those law firms that are charging tens of thousands of dollars for establishing complicated, multi-tiered, offshore structures used to assist people in evading taxes and sometimes even laundering dirty money.<\/p>\n

\u201cAs CFEs, we\u2019re all taught to look at things with a heightened level of professional skepticism and ask ourselves, \u2018Does this make sense?\u2019 In these cases, when \u2018legal\u2019 fees are such a distorted large part of the transaction costs, red flags should be popping up faster than a prairie dog crossing the field,\u201d Dubinsky says. Robinson says that those who can stop crooked shell companies in firms like Mossack Fonseca are the bankers\u2019 lawyers, accountants, company formation agents and brokers who are doing the money laundering. \u201cThe very ones who can stop it are the ones who have absolutely no incentive to stop it because they\u2019re making a fortune,\u201d Robinson says.<\/p>\n

\u201cNow, Mossack Fonseca throws their hands up and says, \u2018No, no, no \u2014 we\u2019re only making kitchen knives. If some woman goes into the kitchen, takes the knife and kills her husband, we can\u2019t be held responsible for that murder. We just made the knives for legitimate use.\u2019 They know what these companies were being used for.\u201d<\/p>\n

A specific scheme common to shell companies<\/h3>\n

Fraudsters often set up shell companies to perpetrate false billing schemes or account payable fraud, Dubinsky says. \u201cWith a laser printer and some basic wordprocessing software, a fraudster can create an invoice with a corporate name, address, phone, email, and even a federal tax ID number and submit a fake invoice for services to a company,\u201d he says. \u201cUsually assisted by an insider, the invoice is processed for payment, payment is made to the shell company, the fraudster withdraws the money from the shell company and divides the money with the inside accomplice. When the investigation leads back to the shell company, the company has no assets, the money and fraudsters are long gone and the trail many times goes cold,\u201d Dubinsky says.<\/p>\n

Kenney says false billing schemes rely on a weakness in internal controls over payments and procurement and the basic infrastructure designed to support such a fraud. \u201cIn most instances, this infrastructure includes a string of shell companies used to (a) issue false invoices for payment of phony goods or services and (b) another string of dummy companies through which to wash and conceal the fructus sceleris \u2014 or the fruits of fraud,\u201d Kenney says.<\/p>\n

\u201cHaving access to a plentiful supply of anonymous companies is crucial for a fraud of this kind to be sustainable. This is why companies are formed, ironically, in under-regulated incorporation centers like Nevada, Delaware and Wyoming. No information regarding the ownership or control of shell companies formed in these jurisdictions is collected or housed there.<\/p>\n

\u201cIn contrast, in the offshore world, incorporators of companies are required to collect and house this data for use by regulators and law enforcement,\u201d Kenney says. \u201cThis latter system breaks down though when a regulated offshore company formation agent doesn\u2019t embrace a culture of robust compliance. Mossack Fonseca is an interesting study because it\u2019s a traditional offshore Panamaian incorporator that also maintains company formation factories in the states of Wyoming and Nevada.\u201d<\/p>\n

Hopeless hand-wringing or helpful solutions?<\/h3>\n

The Panama Papers won\u2019t be the last time a journalistic association, a private nonprofit or a passionate zealot releases leaked data that demonstrates methods of unrestrained criminals.<\/p>\n

Regardless, when we again see such a black thread coursing through the economic markets of this tired globe, as CFEs we yearn to see how the private and public sectors might try to prevent and deter the stuffing of hollow shells with laundered cash that enable heinous frauds and other crimes.<\/p>\n

\u201cThe Panama Papers have given rise to some degree of hysteria on the part of Global Witness [globalwitness.org], The Guardian and other progressive- leaning media outlets or NGOs who have for some time now called for the closure of offshore financial centers,\u201d says Kenney. \u201cThe law of unintended consequences holds that these think tanks and media outlets will be shocked by what will likely happen if the regulated offshore world is shut down,\u201d he says.<\/p>\n

\u201cVoluminous quantities of valuable investigative material will be lost as fraudsters will migrate to under-regulated incorporation centers,\u201d Kenney says.<\/p>\n

\u201cIn today\u2019s world, facts are often not neutrally reported. The initial impact of the Panama Papers has been to cause some politicians in Europe to call for sanctions against offshore financial centers.<\/p>\n

\u201cThe leader of the Labour Party in Britain, Jeremy Corbin, has suggested that Britain should take the extraordinary step of removing the power of locally elected legislators in the British Virgin Islands \u2014 where my law firm is located \u2014 the Cayman Islands and other British Overseas Territories, and to impose direct rule from London as in the 18th Century model of imperial colonialism,\u201d Kenney says. \u201cThere are two sides to this debate, and there are many honorable people who live and work in offshore centers. Unfortunately like everywhere else, we have a minority of liars and cheats.\u201d<\/p>\n

Kenney says that much of the fallout from the Panama Papers has to do with confusion between tax avoidance \u2014 which is lawful \u2014 and tax evasion \u2014 which is criminal \u2014 and onshore tax policy muddled up with offshore tax neutrality and tax competition.<\/p>\n

\u201cThe offshore world has acted as the plumbing infrastructure for globalization, which requires the tax-efficient movement of capital from developed to developing nations,\u201d Kenney says.<\/p>\n

\u201cWhat we see from the Panama Papers is temptation seemingly run amok by reason of imperfections in regulation \u2014 coupled with a rejection by the regulated to accept the new normal \u2014 namely that \u2018bad business is not good for business,\u2019 \u201d he says.<\/p>\n

\u201cThe offshore world needs to improve its regulatory and investigative infrastructure,\u201d Kenney says. \u201cEqually, the onshore world must accept responsibility for its own money-laundering hazards: the unregulated incorporation centers of Delaware, Nevada and Wyoming, and the tendency of many lawyers, bankers and accountants to continue to possess willful blind-eye knowledge of obvious red flags of money-laundering risk. Fixing Panama without also fixing Delaware is like curing cancer to one side of the body and ignoring it on the other. A partial fix just won\u2019t work.\u201d<\/p>\n

Dubinsky says that when we witness an expos\u00e9 such as the Panama Papers, tremendous attention and scrutiny follows \u2014 first from the law enforcement community, legislative bodies and then a responsive effort from the private sector. \u201cI think we\u2019ll see more of shareholders\u2019 activism in which behaviors like this \u2014 certainly from public companies \u2014 won\u2019t be tolerated and once outed will cost the company and management dearly.<\/p>\n

\u201cWe\u2019ll also see new anti-money laundering legislation like U.S. House of Representatives Bill H.R. 4450, the Incorporation Transparency and Law Enforcement Assistance Act [http:\/\/tinyurl.com\/gwf8egu], which will ensure that persons who form corporations or limited liability companies in the U.S. disclose the beneficial owners of those corporations or limited liability companies, in order to prevent wrongdoers from exploiting U.S. laws for criminal gain and other purposes. The U.S. Senate has a similar version now pending, S. 2489 [http:\/\/tinyurl.com\/hpn6qr7].\u201d<\/p>\n

Dubinsky says he\u2019d like to see a balance between the right amount of government regulation and the ability to conduct business in a way that\u2019s legal and yet protects privacy and other legitimate business needs.<\/p>\n

\u201cThis is where the business communities affected need to come together with regulators and legislators to work together to create a business-friendly atmosphere that rewards those for playing by the rules and heavily penalizes those that don\u2019t,\u201d he says.<\/p>\n

\u201cI think the recent actions in some of the large U.S. Foreign Corrupt Practices Act cases that have been publicized show that the U.S. and some foreign counterparts are in fact upping the ante in the ongoing cat-and-mouse game of international fraud detection,\u201d Dubinsky says.<\/p>\n

\u201cStay tuned,\u201d he says. \u201cThere&rsqursquo;s a whole lot more to come. This is just the tip of the iceberg.\u201d<\/p>\n

Robinson says Guernsey is a \u201chuge success story\u201d<\/h2>\n

\u201cGuernsey \u2014 one of the Channel Islands \u2014 is a fascinating study because it\u2019s the one that got turned around,\u201d says Jeffrey Robinson, an expert on global fraud.<\/p>\n

\u201cMy friend, Geoffrey Rowland, who served as bailiff of Guernsey \u2014 the chief justice and attorney general \u2014 from 2005 to 2012, instituted a regime that drove out dirty money and corporate corruption in favor of one that would reward honest businesses with a sort of Good Housekeeping Seal of Approval.\u201d<\/p>\n

Robinson says in the early 2000s a competent outside law enforcement authority asked Rowland for information about a business licensed in Guernsey. \u201cRowland fully complied with the inquiry because he was sick and tired of having dishonest businesses tarnish his birthright, and he didn\u2019t want to allow that business to hide behind previously constructed offshore duckblinds,\u201d Robinson says.<\/p>\n

\u201cNext, he announced that Guernsey would turn itself into a transparent offshore entity by complying with any and all inquiries from competent law enforcement authorities,\u201d he says. \u201cAs a direct result, the dirty money fled to less-stringent, less-dangerous jurisdictions while the businesses that remained could brag that they had nothing to hide and were worthy of their clients\u2019 trust.\u201cIt\u2019s a huge success story. If you have a company in Guernsey everybody knows that you\u2019re a legit operation because you don\u2019t risk having dirty money there,\u201d Robinson says.<\/p>\n

\u201cYears later, Geoff told me that Guernsey made more money as a transparent financial center than they ever did as a typically opaque offshore entity.\u201d<\/p>\n","protected":false},"excerpt":{"rendered":"

What every fraud examiner should know about the Panama Papers<\/p>\n","protected":false},"author":2,"featured_media":3066,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[81],"tags":[],"class_list":["post-2619","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-opinion"],"yoast_head":"\nACFE Magazine \u2013\u00a0Shell Shocked - MKS<\/title>\n<meta name=\"robots\" content=\"noindex, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<meta property=\"og:locale\" content=\"en_GB\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"ACFE Magazine \u2013\u00a0Shell Shocked - MKS\" \/>\n<meta property=\"og:description\" content=\"What every fraud examiner should know about the Panama Papers\" \/>\n<meta property=\"og:url\" content=\"https:\/\/diskdrive33.com\/mks\/2016\/09\/08\/shell-shocked\/\" \/>\n<meta property=\"og:site_name\" content=\"MKS\" \/>\n<meta property=\"article:publisher\" content=\"https:\/\/www.facebook.com\/MartinKenneySolicitors\" \/>\n<meta property=\"article:published_time\" content=\"2016-09-08T00:00:00+00:00\" \/>\n<meta property=\"article:modified_time\" content=\"2018-08-31T13:16:18+00:00\" \/>\n<meta property=\"og:image\" content=\"https:\/\/diskdrive33.com\/mks\/wp-content\/uploads\/2018\/08\/ACFE-Jul-Aug-2016-cover.png\" \/>\n\t<meta property=\"og:image:width\" content=\"914\" \/>\n\t<meta property=\"og:image:height\" content=\"1220\" \/>\n\t<meta property=\"og:image:type\" content=\"image\/png\" \/>\n<meta name=\"author\" content=\"Nick Ryan\" \/>\n<meta name=\"twitter:card\" content=\"summary_large_image\" \/>\n<meta name=\"twitter:creator\" content=\"@mksolicitors\" \/>\n<meta name=\"twitter:site\" content=\"@mksolicitors\" \/>\n<meta name=\"twitter:label1\" content=\"Written by\" \/>\n\t<meta name=\"twitter:data1\" content=\"Nick Ryan\" \/>\n\t<meta name=\"twitter:label2\" content=\"Estimated reading time\" \/>\n\t<meta name=\"twitter:data2\" content=\"15 minutes\" \/>\n<script type=\"application\/ld+json\" class=\"yoast-schema-graph\">{\"@context\":\"https:\/\/schema.org\",\"@graph\":[{\"@type\":\"Article\",\"@id\":\"https:\/\/diskdrive33.com\/mks\/2016\/09\/08\/shell-shocked\/#article\",\"isPartOf\":{\"@id\":\"https:\/\/diskdrive33.com\/mks\/2016\/09\/08\/shell-shocked\/\"},\"author\":{\"name\":\"Nick Ryan\",\"@id\":\"https:\/\/diskdrive33.com\/mks\/#\/schema\/person\/8877ccebf0e078d75b8c4a820af7eff2\"},\"headline\":\"ACFE Magazine \u2013\u00a0Shell Shocked\",\"datePublished\":\"2016-09-08T00:00:00+00:00\",\"dateModified\":\"2018-08-31T13:16:18+00:00\",\"mainEntityOfPage\":{\"@id\":\"https:\/\/diskdrive33.com\/mks\/2016\/09\/08\/shell-shocked\/\"},\"wordCount\":3082,\"publisher\":{\"@id\":\"https:\/\/diskdrive33.com\/mks\/#organization\"},\"image\":{\"@id\":\"https:\/\/diskdrive33.com\/mks\/2016\/09\/08\/shell-shocked\/#primaryimage\"},\"thumbnailUrl\":\"https:\/\/diskdrive33.com\/mks\/wp-content\/uploads\/2018\/08\/ACFE-Jul-Aug-2016-cover.png\",\"articleSection\":[\"Opinion\"],\"inLanguage\":\"en-GB\"},{\"@type\":\"WebPage\",\"@id\":\"https:\/\/diskdrive33.com\/mks\/2016\/09\/08\/shell-shocked\/\",\"url\":\"https:\/\/diskdrive33.com\/mks\/2016\/09\/08\/shell-shocked\/\",\"name\":\"ACFE Magazine \u2013\u00a0Shell Shocked - 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