Suspicious Banking Activities: Possible Money Laundering by U.S.
Corporations Formed for Russian Entities (Letter Report, 10/31/2000,
GAO/GAO-01-120).

This report discusses possible money laundering by U.S. corporations
formed for Russian entities. It is easy for foreign entities to hide
their identities while forming shell corporations that can be used for
the purpose of laundering money. GAO investigated two Delaware
corporations that are suspected of participating in money laundering
activities, Euro-American Corporate Services, Inc. and International
Business Creations. Suspicious banking activity involved correspondent
bank accounts and wire transfers of funds from Eastern European banks
through U.S. banks to other Eastern European banks. Two U.S. banks,
Citibank of New York and Commercial Bank of San Francisco, violated
their customer policies by failing to close the accounts of clients who
did not comply with the bank's requirement to appear at the bank in
person within 30 days of opening an account. These banks facilitated the
transfer of approximately $1 billion from Eastern Europe, through U.S.
banks, and back to Eastern Europe by corporations formed for Russian
brokers. It is possible that these transfers were used to launder money.
GAO referred the matter to appropriate law enforcement authorities.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  GAO-01-120
     TITLE:  Suspicious Banking Activities: Possible Money Laundering
	     by U.S. Corporations Formed for Russian Entities
      DATE:  10/31/2000
   SUBJECT:  Banking regulation
	     Money laundering
	     Bank examination
	     Fraud
	     Internal controls
	     Organized crime
	     Financial institutions
	     Foreign corporations
IDENTIFIER:  Russia
	     Delaware

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GAO-01-120

A Report to the Ranking Minority Member, Permanent Subcommittee on
Investigations, Committee on

Governmental Affairs, United States Senate

October 2000 SUSPICIOUS BANKING ACTIVITIES

Possible Money Laundering by U. S. Corporations Formed for Russian Entities

GAO- 01- 120

October 31, 2000 The Honorable Carl Levin Ranking Minority Member Permanent
Subcommittee on Investigations Committee on Governmental Affairs United
States Senate

Dear Senator Levin: On February 25, 2000, you expressed concern that foreign
individuals or entities can create U. S. corporations, open bank accounts in
the name of the U. S. corporations, and use these bank accounts to launder
money through the use of correspondent banking services. 1 You identified
certain corporations that had engaged in suspicious banking activity
indicating possible money laundering. Each of these corporations had been
formed in the state of Delaware for unknown foreign individuals or entities.
The

suspicious banking activity involved correspondent bank accounts and wire
transfers of funds from Eastern European banks through U. S. banks to other
Eastern European banks. You initially requested that we investigate

these Delaware corporations to determine how they had been formed. We began
our investigation by reviewing relevant statutes regarding the chartering of
corporations in Delaware and records of the Delaware Division of
Corporations pertaining to the corporations that the

Subcommittee identified. We then contacted various registered agents for
these corporations and identified Euro- American Corporate Services, Inc.,
as a Delaware- registered agent that together with a related company,
International Business Creations (IBC), created corporations for Russian

brokers and established bank accounts for those corporations. We brought
this information to the attention of the Subcommittee. It focused its
request more narrowly on Euro- American and asked us to (1) describe how it
was formed and operated, (2) determine how Euro- American entered banking
relationships with Citibank of New York and Commercial Bank of San
Francisco, and (3) investigate the extent to which these banking

relationships resulted in suspicious activity. 1 A bank or other financial
organization that regularly performs services for another financial
organization in a place or market to which the other does not have direct
access is referred to as a correspondent bank.

We reviewed state of Delaware, Department of State, Division of
Corporations' files concerning the list of companies the Subcommittee had
provided to us. We contacted Delaware- registered agents for information
about those companies and interviewed the Division of Corporations'
Incorporation Section Administrator, who oversees corporation filings. We
also spoke with a member of the Delaware State Police Intelligence

Division. In addition, we reviewed relevant provisions of the Delaware Code.
Further, we interviewed officials of IBC, Euro- American, Citibank, and
Commercial Bank. The Permanent Subcommittee on Investigations, Senate
Committee on Governmental Affairs, issued subpoenas to obtain certain bank
records of IBC, Euro- American, the three principals of those corporations,
and IBC/ Euro- American- created corporations. We analyzed

those bank records. We conducted our investigation from March to October
2000. It was performed in accordance with the quality standards for
investigations as set forth by the President's Council on Integrity and
Efficiency.

Results in Brief Euro- American formed corporations pursuant to the General
Corporation Law of Delaware. The corporations were granted corporation
status by the

state after Euro- American- as the registered agent- prepared, signed, and
filed a certificate of incorporation containing very limited information.
For example, Delaware law, as in some other states, has no requirement that

the certificate of incorporation contain information about the principals,
the principal place of business, or the specific business activity of the
corporation.

We also determined that Euro- American had formed three of the Delaware
corporations identified by the Subcommittee, as well as approximately 2,000
others, for Russian brokers. From 1991 through January 2000, more than $1. 4
billion in wire transfer transactions was deposited into 236 accounts opened
at 2 U. S. banks: Citibank (136 accounts) and Commercial Bank (100
accounts). IBC/ Euro- American established those accounts for corporations
that it had created. Of the $1.4 billion, more than $800 million was wired
from foreign countries into IBC/ Euro- American accounts at Citibank. Over
70 percent of the Citibank deposits for these accounts was wire- transferred
to accounts in foreign countries. Of the remaining

$600 million deposited in Commercial Bank, over 50 percent was similarly
transferred into the U. S. banking system from abroad. In addition, most of
the $600 million was transferred out of the U. S. banking system. These

banking activities raise questions about whether the U. S. banks were used
to launder money.

Additionally, the two banks at which Euro- American established accounts
failed to implement “know your customer” policies for these
accounts. Implementation of effective know your customer policies permits
financial

institutions to understand the kind of transactions in which a particular
customer is likely to engage, to identify unusual or suspicious
transactions, and to report such transactions as required by the Bank
Secrecy Act. 2 We have referred the information developed to appropriate law
enforcement and regulatory agencies.

Background Forming a Corporation in The General Corporation Law of Delaware
permits “any person, Delaware

partnership, association or corporation” to form a corporation
“without regard to such person's or entity's residence, domicile or
state of incorporation” by filing a certificate of incorporation with
the Division of Corporations in the Department of State. 3 Every corporation
must have and

maintain in Delaware “a registered office which may, but need not be,
the same as its place of business.” 4

Each corporation must also appoint a registered agent to “accept
service of process and otherwise perform the functions of a registered
agent.” 5 The registered agent may be the corporation itself, an
individual resident of Delaware, another domestic corporation or other
domestic business entity,

or a foreign corporation or other foreign business entity that is authorized
to do business in the state. 6

2 The Bank Secrecy Act is codified in 12 U. S. C. sect.sect. 1829b and 1951- 59 and
in 31 U. S. C. sect.sect. 5311- 30. 3 Del. Code Ann. tit. 8, sect.101.

4 Del. Code Ann. tit. 8, sect.131 (a). 5 Del. Code Ann. tit. 8, sect.132 (a). 6 Del.
Code Ann. tit. 8, sect.132 (a).

The certificate of incorporation must contain the name of the corporation,
the address of the corporation's registered office in Delaware, the name and
street address of its registered agent at the corporation's registered
office in Delaware, and the name and mailing address of the incorporators. 7
Our investigation revealed that for all the corporations formed by
EuroAmerican

it was both the registered agent and the incorporator. With respect to the
nature of the business of the corporation, it is sufficient for the
certificate of incorporation to state that “the purpose of the
corporation is to engage in any lawful act or activity for which
corporations may be organized under the General Corporation Law of
Delaware.” 8 A certificate must be filed with the Division of
Corporations certifying any changes with respect to the corporation's
registered agent or registered address. 9

Bank Compliance Programs The Bank Secrecy Act requires banks to report
suspicious banking activity

Regarding Suspicious relating to potential money laundering to the U. S.
Treasury Department. 10 Banking Activities and

The Federal Reserve System, the Office of the Comptroller of the Currency
Know Your Customer (OCC), and the Federal Deposit Insurance Corporation
(FDIC) are the

Policies federal regulatory agencies that examine banks. To enforce the Bank
Secrecy Act, these agencies have promulgated regulations requiring banks to
implement programs and procedures for recording and reporting large

currency transactions and for detecting, preventing, and reporting
suspicious transactions related to potential money- laundering activity. 11

7 Del. Code Ann. tit. 8, sect.102. Additionally, if the corporation is
authorized to issue only one class of stock, the certificate of
incorporation must also contain the total number of shares of stock that the
corporation has authority to issue and the par value of each share or a
statement that all such shares are to be without par value. Del. Code Ann.
tit. 8, sect.102( 4). 8 Del. Code Ann. tit. 8, sect.102. 9 Del. Code Ann. tit. 8,
sect.133. 10 31 U. S. C. sect.5318( g); 31 C. F. R. sect.103. 21; see 12 C. F. R. sect.sect. 21.
21 (OCC). Money laundering is the process of engaging in financial
transactions with the proceeds of unlawful activity to conceal the
existence, nature, or source of those proceeds. Two criminal money-
laundering offenses are defined in 18 U. S. C. sect.sect. 1956, 1957.

11 See 12 C. F. R. sect.sect. 21. 21 (OCC), 219. 21- 23 (Federal Reserve), and 326.8
(FDIC)( 2000).

Regulators and most banks contacted during a previous GAO review 12 cited
know your customer policies as one of an institution's most important means
of detecting suspicious activity to comply with the Bank Secrecy Act. 13
Know your customer policies generally commit a financial institution to
verify a customer's identity, determine the customer's source of wealth,
review the customer's credit and character, and understand the type of
transactions the customer would typically conduct. Implementation of
effective know your customer policies permits a financial institution to
understand the kinds of transactions in which a particular customer is
likely to engage, to identify unusual or suspicious transactions, and to

report such transactions to the U. S. Department of the Treasury. Ease of
Foreign

We identified the registered agents for most of the corporations named by
Entities in Creating

the Subcommittee. We were able to obtain information from the files of seven
of those registered agents, including Euro- American, concerning U. S.
Corporations

approximately half of the corporations identified by the Subcommittee.
Engaging in Suspicious Although they did not provide specific numbers, the
seven registered Banking Activities

agents told us that a large number of the corporations in our investigation
had been formed at the request of foreign individuals or entities. Further,
an officer of Euro- American informed us that his company's clients consist
entirely of brokers in Moscow, Russia, who make requests for the formation
of Delaware corporations and that Euro- American had formed approximately
2,000 such corporations since 1996. In our review of documents filed by
Euro- American with the Delaware Division of

Corporations, we found that an officer of Euro- American had signed the
certificate of incorporation for each company it formed as the incorporator
of the company.

The records of the registered agents we reviewed generally contain the name
of the person or entity requesting the formation of the corporation but do
not contain the names of the corporation's principals. Thus, neither state
records nor the records of the registered agents contain the names of 12
Private Banking: Information on Private Banking and Its Vulnerability to
Money Laundering (GAO/ GGD- 98- 19R, Oct. 30, 1997).

13 While regulatory efforts to establish uniform know your customer
requirements have been discontinued, Congress continues to look for ways to
reinforce current anti- moneylaundering laws and, more specifically, to
promote due diligence in customer banking relationships.

the principals of the incorporated companies. Two registered agents informed
us that they often form corporations in blocks of 10 to 20 at a time to
accommodate single requests from foreign brokers. A registered agent also
disclosed that these corporations are sometimes sold by the brokers to
others, who may, in turn, sell them again.

In conducting our investigation, we reviewed Suspicious Activity Reports
filed by three banks concerning transactions by corporations formed by Euro-
American for Russian brokers. A question raised in the reports concerned
whether banking transactions by these corporations were part of money-
laundering schemes. For example, one report describes the following
transactions by two corporations formed by Euro- American:

Corporation A initiated a series of wire transfers of money on its behalf
through Absolute Bank in Moscow, Russia, to the Bank of New York in the
United States, which had a correspondent banking relationship with Absolute
Bank. The Bank of New York then transferred the funds to Republic National
Bank of New York, which had a correspondent banking relationship with Trust
Commercial Bank in Latvia. Republic National Bank, in turn, sent the funds
by wire to Trust Commercial Bank in Latvia where they were deposited into
Corporation B's account. Approximately $6. 8 million was moved in this
fashion from Corporation A to Corporation B during a 2- month period. Using
wire transfers, money was moved in large dollar amounts into and out of
accounts on the same day or within 1 or 2

days. 14 Relationship Between In 1991, a native of the Republic of Georgia
who was residing in the United States incorporated IBC in Delaware and
became its president. 15 IBC International Business

opened bank accounts in the United States for corporations formed in
Creations and EuroAmerican Delaware at the request of Russian brokers. To
expand his business, in 1996

Corporate IBC's president created Euro- American to (1) form corporations in
Services, Inc.

Delaware for Russian brokers and (2) serve as the registered agent for such
corporations and open bank accounts for them when requested. Two former IBC
employees serve as the officers of Euro- American. EuroAmerican began
charging a fee of $350 for each company it incorporated.

14 We have no information concerning either the origin of the funds wired by
Corporation A or the final destination of the funds after they were
deposited into Corporation B's account. Moreover, Euro- American could not
provide information about the owners or the principals of these
corporations.

15 IBC was also incorporated in New York in 1996.

Euro- American serves as its own registered agent and lists a street address
in New Castle, Delaware, as its registered address on its certificate of
incorporation. We found that it was the address of Executive Offices, Inc.,
a company that provides office space and reception services for business
tenants. An officer of Executive Offices informed us that beginning in
approximately 1997, his company provided a mail drop to IBC, which is

actually located in New York, New York. He later learned of the existence of
Euro- American after he received large quantities of mail for it. He
contacted the Delaware Division of Corporations and was informed that Euro-
American had established itself as a registered agent and had listed as its
registered address the mail drop rented to IBC by Executive Offices. He

also learned that Euro- American served as the registered agent for 708
corporations that used the address of Executive Offices.

The officer of Executive Offices informed us that he subsequently entered
into a rental agreement with Euro- American. Euro- American rents office
space from Executive Offices, although no one physically occupies the
office. As part of this agreement, Euro- American pays for the services of a

common receptionist shared by other tenants of Executive Offices. The
officer estimated that a Euro- American representative uses the office about
1 day every 3 months, which he opined was merely a “formality.”
Further, all telephone calls and mail are forwarded to Euro- American in New
York. An official of Delaware's Division of Corporations advised the officer
that this arrangement complies with Euro- American's obligations as a

Delaware- registered agent. Euro- American's Role

According to an employee of Euro- American, Russian brokers who obtain in
Forming U. S. services from Euro- American generally order the formation of
about 10 corporations at a time. Sometimes the Russian brokers furnish names
for Corporations for

the requested companies; at other times, Euro- American simply “makes
up” Russian Brokers and names for the corporations it forms. The Euro-
American employee

Opening Bank estimated that, since its inception, the company had worked
with between

30 to 50 brokers in Moscow for whom it had formed about 2,000 Accounts for
Such

corporations. According to the president of IBC and the Euro- American
Corporations

employee, Euro- American conducted no due diligence with respect to any
company it incorporated because state law does not require it.

On occasion, Russian brokers requested that IBC/ Euro- American open bank
accounts with wire transfer capabilities for corporations that EuroAmerican
formed. We have identified two banks at which Euro- American established
such accounts: Citibank of New York and the Commercial Bank

of San Francisco. Euro- American received a fee of $450 from the Russian
brokers for each bank account opened. According to records of Citibank and
Commercial Bank, IBC/ Euro- American opened approximately 136 bank accounts
for corporations at Citibank from 1991 through January 2000 and
approximately 100 bank accounts at Commercial Bank from 1996

through 1999. The president of IBC told us that the bank accounts were
formed to move money out of Russia. The IBC president told officers of both
Citibank and Commercial Bank that he had conducted investigations of the
companies for which he opened accounts. He admitted to us that he made such
representations to the banks but that he in fact had not investigated the
companies. He also told us that Euro- American is currently being liquidated
due in part to concerns about money- laundering issues that were raised in
1999 when the media

reported allegations that Russian organized crime had laundered billions of
dollars through the Bank of New York.

Relationship Between A Citibank account officer at a particular Citibank
branch told us that the Citibank of New York president of IBC first became a
Citibank customer about 10 years ago when

he established IBC. At that time, IBC's president informed Citibank that he
and IBC/ EuroAmerican assisted Russian business clients in opening bank
accounts in the United

States. When he established IBC's Citibank account, the president of IBC was
required to provide two forms of identification, such as a passport and
credit card, and documents relating to IBC, such as incorporation papers.
Between 1992 and April 2000, IBC had four accounts at Citibank into which
approximately $280 million was deposited through wire transfers. Virtually
all of these funds were subsequently wired out of the accounts.

The relationship between Citibank and IBC expanded in 1996 when EuroAmerican
was formed and IBC/ Euro- American began referring Russian companies to
Citibank for the purpose of opening accounts. According to the Citibank
account officer, the president of IBC vouched for the newly

formed companies and said that he knew the officers of the companies
personally, by reputation, or as a result of conducting his own
investigation. Citibank opened the accounts based upon the IBC president's
representations, with the stipulation that the customers would personally
appear at Citibank with appropriate identification within 30 days of opening
the account. A Euro- American employee served as a Russian interpreter for
those customers who personally appeared at Citibank to open accounts.
Citibank did not conduct due diligence regarding IBC/ EuroAmerican-

referred customers. 16 A Citibank official advised us that the bank closed
some of the accounts opened for IBC clients because the clients had failed
to appear personally at Citibank offices within 30 days after the accounts
were opened. He added that the accounts were fully functional for the
initial 30- day period, allowing wire transfer capabilities, and that all
transactions in and out of these accounts were by wire transfers. Although
we do not know the number of IBC/ Euro- American referred Citibank customers
who appeared personally at the bank, our review of records obtained from
Citibank indicates that no accounts of IBC/ Euro- American referred
customers were closed within 4 months of being opened. Further, more than
$800 million was deposited through wire transfer transactions from foreign
countries into IBC/ Euro- American client accounts at Citibank. Over 70
percent of

these deposits was subsequently moved out of the U. S. banking system
through wire transfer transactions to accounts in foreign countries.
According to a Citibank official, these deposits included funds from Russia;
and Citibank no longer opens accounts for clients of IBC/ Euro- American

because of concerns over suspicious account activity. 16 We previously
reported that Citibank's failure to enforce its know your customer policy
facilitated a money- laundering scheme that disguised the origin,
destination, and beneficial owner of the funds involved. See Private
Banking: Raul Salinas, Citibank, and Alleged Money Laundering (GAO/ OSI- 99-
1, Oct. 30, 1998).

Relationship Between As previously discussed, IBC/ Euro- American also
opened approximately Commercial Bank and 100 bank accounts at Commercial
Bank of San Francisco for corporations

it had formed for Russian brokers. We reviewed bank statements made IBC/
Euro- American

available through the Subcommittee's subpoena which revealed more than $600
million in wire transfers into these bank accounts. A Commercial Bank
employee familiar with the records provided to the Subcommittee stated that
over 50 percent of the wire transfers originated from foreign sources. The
employee added that most of the $600 million was subsequently wire-
transferred abroad. Our review of the bank records indicates that the
foreign sources included wire transfers into and from Eastern Europe.

According to the president of Commercial Bank, two Russians purchased about
9 percent of the bank's stock for $1 million in March 1995. One of these
individuals suggested that the bank hire him as a consultant to obtain new
business from Russian depositors. Consequently, the bank entered into an
agreement with East Industrial Financial Society, a corporation owned by
this individual. East Industrial became the only full- time contractor
soliciting business for the bank from April 1996 through March

1998. 17 This individual (hereinafter “the Russian director”) 18
became a member of the Board of Directors of Commercial Bank in May 1997.

The IBC president informed us that another Russian introduced him to the
Russian director in 1996. At that time, the Russian director suggested that
IBC open bank accounts with Commercial Bank for U. S. corporations that IBC
had formed for its Russian clients. As a result, in April 1996 IBC entered
into a contract with East Industrial. The agreement provided that IBC would
introduce potential banking customers to East Industrial, which would
establish accounts for them with the Private Banking Group of Commercial
Bank. 19

17 Under the contract, Commercial Bank paid a service fee to East
Industrial. 18 We have obtained information that indicates that this
individual has had a close relationship with companies associated with
members of the former Soviet Union's intelligence agency. 19 IBC was to
receive a service fee for business it introduced to Commercial Bank based on
a percentage of average daily deposits in customer accounts once certain
conditions were met. However, both the Russian director and the president of
IBC stated that no service fees were paid to IBC.

The Russian director, who also served as the Director of Private Banking and
the Director of the International Department at Commercial Bank, resigned
from the Board of Directors and his other positions with the bank in
December 1999, effective January 14, 2000. The president of Commercial Bank
informed us that, during the period that the Russian director was a

director or consultant to the bank, 40 percent of total bank deposits was
from customers referred to it by IBC/ Euro- American.

Commercial Bank officials stated that they had relied on representations
made by IBC's president that he knew the clients he introduced and that
Commercial Bank had conducted no independent due diligence concerning IBC/
Euro- American referred customers. IBC/ Euro- American clients were not
required to appear in person at the bank to open accounts; instead,

accounts were opened by mail. Commercial Bank officials also informed us
that the bank filed Suspicious Activity Reports concerning activity in
accounts of IBC/ Euro- American clients and that it stopped opening accounts
for IBC/ Euro- American in 1999 due to numerous instances of suspicious
transactions by its clients. We were also told that the International
Department would be closed due to problems relating to the suspicious
banking activities of its customers. The International Department closed on
June 30, 2000; and Commercial Bank was recently

sold. Conclusion It is relatively easy for foreign individuals or entities
to hide their identities while forming shell corporations that can be used
for the purpose of laundering money. Further, the money- laundering
provisions of the Bank

Secrecy Act require banks to identify suspicious activity and to report that
activity to federal authorities. While the banking industry points to
voluntary know your customer policies as implementing the requirements of
the act, in this case two banks violated the principles of those policies.
We previously reported similar violations by one of these banks. 20 The

violations by the two banks in our current investigation facilitated the
transfer of approximately $1 billion from Eastern Europe, through U. S.
banks, and back to Eastern Europe by corporations formed for Russian
brokers. These transfers raise concerns that the U. S. banking system may
have been used to launder money. We have referred the information

developed to appropriate law enforcement and regulatory agencies. 20 Private
Banking: Raul Salinas, Citibank, and Alleged Money Laundering (GAO/ OSI- 99-
1, Oct. 30, 1998).

As arranged with your office, unless you announce its contents earlier, we
plan no further distribution of this report until 30 days after the date on
this letter. At that time, we will make copies of this letter available to
interested congressional committees and others on request. If you have any
questions or need additional information, please contact Deputy Director
Ronald Malfi at (202) 512- 6722. William McDaniel and Woodrow H. Hunt, Jr.
were key contributors to this case.

Sincerely yours, Robert H. Hast Managing Director Office of Special
Investigations

(600715) Lett er

GAO United States General Accounting Office

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