It was predicable in a number of ways. Iranian President Ahmadinejad gave a speech on Nuclear Weapons at the UN on Monday, that was by all standards fairly predictable. No one had been looking forward to hearing what the Iranian President had to say on the topic and for good reason, he had no plans on addressing his own country’s problems with nuclear weapons, but rather had a lot to say about everyone else. If nothing else this is a good lesson in deportment. No one really hears what you have to say if you always say the same thing, and no one wants to hear what you have to say if you are only going to condemn others.

If Governor Charlie Crist decides to run for Senator this year, the whole nation will once again be gawking at Florida politics and will probably be amazed by the result. Charlie Crist would be running as an independent and with a very good chance to win. The other two members of the race would of course have the backing of their party to back them up, something he won’t have, but that may hurt them more than help them.

While the whole story can be found on other places on the web, the short end of it is that a British Petroleum oil rig crashed and sank last week. The whole thing has been leaking since then and they are now sure of at least three spots from which it is leaking. The oil came very close to the shoreline, but Obama is doing everything in his power to get it cleaned up as soon as possible. The American people will not have to pay for the clean up, that bill will fall on the hands of BP.

Once in a while there is a great article, and for every person that article will be different. For some this is going to be one of them, and for others you will want to just set it aside and pretend you never saw it. Don’t just read the content though. If you don’t like Obama at least listen to the message. While it ends on a note of uncertainty, who can be certain with the political climate surrounding the Middle East. The point of the article though is that whether you agree with the plans or now, reaching this point in Obama’s health care plan shows that maybe, just maybe he does know what he’s doing and can follow and shape the long game. That is what it took to get him here. If you do like Obama, this is one more thing that gives you hope for his ability to handle the Middle East.

The Foreign Corrupt Practices Act has been under increased scrutiny, while at the same time practicing at an increased level of enforcement.  This is the same case for other such organizations throughout the world such as the anti-bribery, anti-corruption, and anti-terrorist financing agencies.  All of these organizations are working harder than ever in the effort to combat and control corruption, for the harder they work, the harder the criminals work.

Corrupt politicians, business CEOs, and foreign officials are becoming increasingly wiser to the ways of the investigators and are ever coming with with more devious, more intelligent thought out ways in which to commit the crimes they intend to commit.  This is in part due to just howsuccessful these agencies have been in the years following the terrorist activities surrounding and leading up to 9/11.  So it is incredibly important for the businesses and corporations, as well as the financial institutions and the governments of the world, to be diligent, and ensure that all those they work with, work for, and supervise over follow the laws and remain in compliance with the work demanding of them by theFCPA.

Should they be concerned if they are in compliance, they may hire a third party to come in and objectively assess their policies and procedures and determine whether or not those are effective in the first place, and if they are that they are being followed and enforced.   This is known as a field audit, and they will dig deep into the program, do a risk assessment, and create a plan based on what they consider to be areas of high or potential risk, in regards to possible FCPA violations. This is important because should a company be brought into a court of law, the “I did not know” defense will be tossed out the window.  It is each company, or country’sresponsibility to understand the policies and the laws, and to become informed about them if they do not.

Regulatory compliance,  in the United States, just means simply that a company and its employees are following through with the regulations and the laws that govern what is good, and ethical business practice.  In some cases these are just guidelines, in other cases they are laws that are subject to civil or criminal prosecution.  One way in which the president or the CEO of a company keeps track of this is thought the collection of data, specifically termed “compliance data”.

This refers to all the data, the books, the records of transactions, that could be used during an investigation, with the purpose of either confirming that corruption or scandal has taken place, or used to confirm that it has not, that the company was following all the rules or laws that they were responsible for following.  It gives relevance to either the government or the judicial system that will validate completeness and consistency.  Compliance.

During the 1990’s, the United States was experiencing a boom in the economy.  And then, what came to symbolize greed and excess in the corporate world happened, the Enron Scandal of 2001.  For six years running, 1996 through 2001, the Enron Corporation was sited in “America’s Most Innovative Company” list created by the Fortune magazine.  And not long after the list was published, in December of 2001, the Enron Corporation filed bankruptcy.  This was one of the United States’ largest filings for bankruptcy in United States history.  This demise of the company was the result of the failure for them to disclose certain information, for failing to be transparent and honest in their business practices.

Employees had taken part in falsifying the profit reports, in using methods of accounting that did not follow regulatory compliance procedures.   On both sides, internal and external, the profits that had been disguised for so many years had gone unnoticed, or unsuspected.  The management team of Enron had managed to take down their own company, and then left with millions of dollars in their pockets.  The regular employees however were not as lucky, as many of them fell into financial ruin as a result.  This resulted in many in the business community of the U.S. being a bit shaken up, and new laws were created so it would become more difficult for this to happen in the future.

How does corruption thrive and what will it take for the anti-corruption agencies to break the cycle?  This is a question that is difficult to answer.  Temptation and greed are two of the aspects that fuel corruption, they are human characteristics and therefore, just a bit unpredictable.  They need permissiveness in order to thrive.  In a system without a set and honest order of checks and balances in place, without a standard policy of the use of a suspicious activity report, wherein the distribution of wealth remains out of balance and where the decision making process is clouded in obscurity, corruption will flourish.

In many countries and societies today, even in those locations where the systems…economic, social and legal…are deeply entrenched, corruption is alive, and not only alive, but well.  Those who argue that the fight against towards corruption can not be won, are just stating the age old dilemma of one side versus the other, the north versus the south or the Hatfields versus the McCoys.  This is a thought process that over-simplifies the issues.  Some will say that corruption in the form of bribery,  such as gift giving, is just a mis-understanding between two different cultures.

This is perhaps a valid argument, were it not for the fact that everything, about every culture, every aspect and every norm can simply be looked up on the Internet, the claimed ignorance or mis-understandings makes the mind reel.  Yes, values and customs and norms are culture specific, but really, ethics and morality must play a part.  Each member of a culture is well aware of what is not only acceptable, but what is transparently honest behavior.  Regardless of cultural differences.

These differences are what prompted the formation of the Transparency International organization.   IT states that members of a society know what is customary to their own culture, and they know the kinds of actions that violate those customs.  These ‘differences’ can no longer be the defense in an argument where corruption is concerned.  And the formation of such anti-corruption organizations is one way to set about a comprehensive understanding among those from different societies, from different cultures.

The Gramm-Leach-Bliley Act of 1999 requires that regulatory compliance terms be followed in regards to the personal information of the customers of any give financial institution, and the protection of that information.  Insurance companies, banks, lending firms and credit counselors are among those in the business of providing financial services, and they are required by law to protect the data in their records and to enact implementations as needed that address the variety of and the access to the security measures that must be taken in order to ensure that information is protected.  The confidentiality and the integrity of the information and the records of each customer is the main concern of the act.

These aspects that are to remain confidential are the customer’s account numbers, their social security number, and their name and address.  Also covered under the protection is any additional information that is required to filled out on an application to open an account.  During all the phases of the lifetime of the account, these objectives must be kept in the minds of the employees and officers of the financial institutions, in order ensure that nothing is missed.  This may mean that over the course of time, various steps will be necessary to take regarding the testing and the implementation of the means of the deployment, or the modes of standard operational procedures.

It is important that compliance standards are met, as this will serve to protect the customer’s personal information from access by parties unauthorized to gait that access.  Records must be properly encrypted and that they encryption processes are regularly alternated.  The systems should be such that if necessary, they can be altered quickly and at a minimal expense.  Libraries and programs for such encryption should not be used as their are well known and easy to break into.  Those that are interested in breaking those codes have too many opportunities to learn how best to break them if they are standardized forms.  Understanding the policies of regulatory compliance can be frustrating, but is important to the customer and to the integrity of the financial institution.

Operation Green Quest has worked along side other governmental agencies over the last eight years, upholding the rules and the regulations set out by the U.S. Patriot Act.  Hundreds of investigations have been ongoing since the attacks on the World Trade Center in 2001, and have resulted in the seizure of millions of dollars laundered by terrorist cells, many arrests and indictments all relating to the activities of the financing of terrorist activities.  This organization was created in October of 2001 by the U.S Treasury Departments.  This is a law enforcement agency that combines the efforts of others in the United States as well as those agencies located in other countries.  It was created to enhance the efforts of anti-terrorism and brings the entire scope of the expertise of the various governmental agencies together to attack the individuals and the organizations that provide the means and the funding for terrorist activities.  Accounts are frozen, assets are seized and legal actions are taken against those organizations and individuals committing such crimes.

The U.S. Customs service leads the OGQ, and delegates analysts and agents from other agencies including the IRS, the ATF, the FBI and even the United States Postal Service.  The center for the organization is located in the United States capital of Washington, D.C.  The headquarters is also staffed with those members of the other agencies.  This is where most of the information is collected, managed, and disseminated to the agents in the field throughout the country.  This is where all the information is organized in order to ensure that one agency is not spending time working on the investigations and projects already in progress by one of the other agencies.  Since its inception, the Operation Green Quest has had an existing field unit in Manhattan.  This unit is made of investigators with experience in financial transactions and institutions.  This is the El Dorado Force.  More than two hundred and sixty agents of the IRS and the U.S. Customs office comprise one of the most successful task forces and one of America’s largest.  Seasoned analysts, regulators and special agents all working under one roof to ensure that what happened in 2001 will not happen again.

The term due diligence refers to the practice of thoroughly investigating and researching any business or individual with whom one is about to conduct business transactions.  It is the process of checking all the facts.  It is simply the steps that everyone should take before entering into a contract, a transaction or an agreement with another entity, be they an individual or a company.  What does this practice ensure?  It serves to ensure that all steps were taken to decrease the probability of harm caused to either the buyer or the seller, or the investor and the lender.

This concept is applied in many aspects of life, not just financial institutions and/or transactions.  It is applied by any person, taking the time for being responsible, to take care to know all the facts before signing on the dotted line.  This involves taking the time to investigate one’s records, financial and personal, to performance or in some cases the following through of legal requirements.  For example, should one company be considering the acquisition of another, financial records and assets are studied and performance levels are evaluated.  In this case, although the requirements may not involve the legal spectrum, they may just involve good business practices.

In the political realm, people in the general public practice due diligence in the days leading up to an election.  By knowing as much as they possibly can about the candidates, their decisions will be made based on the investigations into the character, the honesty, the integrity, and the intelligence of the individuals for whom they are voting.  For the individuals who are in the business of politics, due diligence must be practiced when deciding from where they will accept campaign funds, or who and what they will attach themselves with or to, in order to protect themselves and their party from scandal.

And in the financial sector, in banks and investment firms, due diligence is practiced in the development and organization of anti-money laundering agencies.  No respectable institutions wants to enter into business with those of the criminal element.  To know their customers is to protect not only the institution itself, but also the investments of the honest customers who may become secondary victims of the criminals involved in such acts.  Due diligence is just sound business practice.