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Focus (Forum & Focus)

Apr. 11, 2009

Banking on Compliance

If banks don't implement compliance programs in accordance with the Bank Secrecy Act they risk being accused of aiding in Ponzi schemes, writes Leonard L. Gumport.

FOCUS COLUMN

By Leonard L. Gumport

The operator of a Ponzi scheme typically needs at least one bank account. The operator uses that account to deposit duped investors' funds, to commingle them, to extract personal fees and operating expenses (including maintenance of the scheme's facade as a legitimate business) and to pay redemptions and fictitious profits to investors. When the scheme collapses, the operator is always insolvent and sometimes in ...

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