This one needs to be at least 2 pages per answer

1. You are the chief compliance officer at Bank ABC. You have decided to create an internal bank “Financial Intelligence Unit” (FIU) as suggested by James Richards.

Creation of the Unit. Review the Week 8 course reading by James Richards. How can your staff use Microsoft Excel, the Internet, pivot tables, the surface web, the invisible or deep web and the historical web to respond to money laundering threats? Discuss the potential uses of each one of these in anti-money laundering compliance by your new unit.

How will your internal FIU compare and contrast with the recommended FIU of James Richards? How will it be similar and how will it be different?? How will it be better? What resources and training will you provide for your aml/compliance staff? How will you integrate available computer anti-money laundering software to detect money laundering with Internet and media searches, demographic data, “clusters” of ml indicators, news stories, marketing data/studies (from the bank and elsewhere) and data from the anti-fraud unit of the bank so as to limit the number of false positives? How will your internal FIU resolve the aml/compliance issue of reliance on technology (software that produces so many false positives) and/or human review (that is time consuming) to detect money laundering?

Staff Training. Take the case of a gas station owner who deposits about $55,000 in cash per week. Is this money laundering? Many persons, e.g. a compliance officer, would simply plug the owner’s name into Google and hope for the best. However, you want your FIU staff to develop both technical skills thinking skills. How will you train your staff to be aggressive and courageous in using the resources that you provide them? What incentives will you provide?

Bank Management. Some bank officers and members of the Board look upon the Compliance Unit as a high-cost and low-yield unit within bank operations. How can you justify your new unit to the bank management and the Board of Directors? What data will you provide?

2 .Briefly summarize the AML legal regime as perceived by Professor Richard Gordon (Week 8 reading). How does he prove that the AML regime is ineffective? What criteria does he use? Do you agree or disagree? What is his proposed solution? Will it work? Do you see alternative solutions? What are they? Will they work? What are your criteria?

The following two readings were part of your Week 8 research and reading:

Navin Beekarry, “The International Anti-Money Laundering and Combating the Financing of Terrorism Regulatory Structure: A Critical Analysis of Compliance Determinants in International Law”, 31 NW.J.INT’L L. & BUS. 137 (Winter, 2011).

“Losing the War Against Money Laundering: Rethinking Global Standards on Preventing Money Laundering and Terrorism Financing,” Richard K. Gordon, 21 DUKE JOURNAL OF COMPARATIVE & INTERNATIONAL LAW, 503-565, (Spring 2011).

Based on your readings of Beekarry, Gordon and others, do you see an evolving grand alignment and regime against money laundering and corruption or half-hearted steps? How do you see technological changes affecting the future of the regime(s)?

3. Schroth on “Termites” (one of the readings in your course) presented serious criticisms of the UN Convention against Corruption. What were his criticisms? Do you agree or disagree? Does the UN Convention against Corruption constitute an effective response against corruption? What should the international legal community do next? What mixture of national and international responses will be most effective?

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