Morley Group, LTD. - Our Cedentials

The Morley Group, LTD.
Since 1985

Charles H. Morley
The Morley Group, Ltd.
(1985 - Present)

SAMPLING OF CASES

The Morley Group has assisted counsel in a wide range of criminal cases in its criminal defense practice. Investigations in which we have participated have included the following subject areas: Bank Secrecy Act civil and criminal investigations, reinsurance fraud against a major insurer, money laundering investigations, criminal tax cases, limited partnership fraud, health care fraud, commercial fraud, locating hidden or laundered assets, civil & criminal forfeiture cases, Customs violations, advance fee schemes, and bank fraud.

The Morley Group defense practice has traditionally involved unraveling complex financial transactions and reducing them to the comprehension level of a juror. This often involves developing trial books that include simple charts to explain otherwise complex financial transactions, summary appendices and exhibit files that support the charts, and witnesses’ folders.

In his criminal defense practice, Mr. Morley has been qualified as an expert on financial investigations in state and federal courts; qualified as an expert on money laundering in state, federal, and foreign courts; and qualified as an expert on money laundering sentencing guidelines in federal court.

GOVERNMENT CONSULTING

The Morley Group practice has included substantial assistance to U.S. and foreign government agencies. On behalf of the U.S. Government Mr. Morley has advised a number of Latin American and Caribbean governments on money laundering issues. He has been retained as a consultant by several foreign governments, and has testified before Congress and the United States Sentencing Commission on money laundering matters. Attachment #1 includes a sampling of governmental consulting services rendered by The Morley Group.

VIDEO PRODUCTIONS

Mr. Morley, on behalf of The Morley Group, Ltd. and The CGM Group, Inc., has written and produced a number of financial investigations and anti-money laundering video training programs for federal law enforcement agencies and for the financial services industry. Attachment #2 includes a listing and description of these videos.

PAPERS, ARTICLES, AND BOOKS PUBLISHED OR PRESENTED

Mr. Morley has published or presented a wide variety of papers, articles, and books on the subjects of money laundering, conducting financial investigations, anti-money laundering compliance systems and related matters. Attachment #3 includes a listing and description of these papers, articles, and books.

MONEY LAUNDERING/BANK SECRECY ACT COMPLIANCE SYSTEMS

The Morley Group has reviewed, designed, written, implemented, or modified a number of anti-money laundering compliance systems in financial institutions of various sizes. These projects often involved substantial investigations and risk assessments in anticipation of or in response to adverse federal regulatory or law enforcement action. Attachment #4 includes descriptions of a sample of these projects.

FINANCIAL INVESTIGATIONS TRAINING SEMINARS

The Morley Group has designed and presented a number of money laundering and financial investigation training seminars for U.S. and foreign law enforcement officials. Mr. Morley is currently the academic advisor to the Florida International Banker's Association. Attachment #5 is a sampling of agencies and organizations for which Mr. Morley has conducted money laundering and financial investigation seminars and courses.

PRESIDENT, CGM GROUP, INC.
(1985 - 2000)

The CGM Group, Inc. was the producer of the Dirty Money series of anti-money laundering training videos for the banking industry. See Attachment #2 for details of the videos Mr. Morley has written for the CGM Group, Inc.

CHIEF INVESTIGATOR
U.S. SENATE PERMANENT SUBCOMMITTEE ON INVESTIGATIONS
(1980 - 1985)

Investigations

During his tenure as Chief Investigator of the U.S. Senate Permanent Subcommittee on Investigations, Mr. Morley conducted investigations and Senate hearings on a wide range of subjects including: Home Health Care Fraud; International Narcotics Trafficking; Commodities Fraud; Criminal Dumping of Toxic Waste; Crime & Secrecy: The Use of Offshore Banks & Companies; Prevention of Drug Abuse Among Youth; The Role of the Entertainment Industry in De-glamorizing Drugs; Domestic Money Laundering: The Bank of Boston Money Laundering Investigation; and Domestic Money Laundering in Puerto Rico. Mr. Morley frequently testified before the Subcommittee during these hearings.

SPECIAL AGENT
IRS CRIMINAL INVESTIGATION DIVISION
(1969 - 1980)

Mr. Morley culminated his IRS service as the national office representative to Operation Greenback, the first large Treasury Department probe of international money laundering. Prior to joining the national office, he was a group manager for 12 years. He was an instructor and course designer in the IRS training division for 4 years prior to becoming a group manager. During this time he led a Special Agent Basic School redesign task force and a Special Agent Intermediate School design task force. As an agent he spent one year on the Newark NJ Strike Force investigating organized crime.

REVENUE AGENT
IRS EXAMINATION DIVISION
(1967 - 1969)

TOUCHE ROSS CPA FIRM
(1965 - 1967)

EDUCATION and MEMBERSHIPS

University of Maryland honors graduate in accounting and finance (1965)

Completed 61 quarter hours of law at University of Denver (evenings, 1971 - 1972)

Member of Florida International Bankers’ Association (FIBA)

Member FIBA’s education task force. Currently tasked developing a complete curriculum for FIBA/Florida International University certification for senior BSA compliance officers.

ATTACHMENT #1
GOVERNMENT CONSULTING

Central Intelligence Agency/GAMA Corporation (1990)

Mr. Morley participated in a strategic analysis session dealing with the current and future programs in international drug money interdiction. The 29 participants were drawn from senior levels of government and the banking industry.

U.S. Information Agency/State Department
International Narcotics Matters (1990 - 1996)

The U.S. Information Agency and the State Department retained Mr. Morley as a consultant to advise senior foreign government officials and private sector leaders on issues involving narcotics money laundering. Countries visited included Venezuela, The Bahamas, Costa Rica, Colombia, Ecuador, Paraguay, Brazil, Argentina, and Chile. Mr. Morley prepared and presented one to two hour briefings to the following categories of government officials: presidential, legislative and judicial commissions; legislators; supreme court justices and staffs; attorneys general and prosecutors; senior federal and regional law enforcement officials; central bank directors and staffs; bank examination staffs; and senior military officials. In the private sector, he presented briefings to senior bank executives, bank security officers, banking associations, industry leaders, and trade associations.

Mr. Morley has frequently been a sole or joint panelist on World-Net programs on money laundering to Latin America, Africa, and Europe (1992 - 1997). During these one hour programs he responded to live questions from selected listeners in the countries to which he was broadcasting. The questions covered a wide range of subjects related to money laundering, forfeiture, bank regulations, investigative techniques, and broad anti-money laundering policy issues.

Government of the Republic of Slovenia (1993)

In 1993, Mr. Morley was retained as an advisor to the Prime Minister and Parliament on certain issues relating to money laundering and complex financial crimes. During this engagement, he reviewed a complex international investigation conducted by Slovenian law enforcement officials in order to validate the thoroughness of their investigation. He met with staff of the Finance Minister and Minister of the Interior to discuss money laundering prevention systems relating to the banking sector and casinos. He also discussed the role a state taxation system could play in detecting and preventing money laundering.

Mr. Morley subsequently returned to Slovenia to meet with a select committee of Parliament to advise them on the need for strong anti-money laundering legislation.

Government of Colombia (1995 - 1996)

In 1995, Mr. Morley and two attorneys conducted a money laundering/financial investigations work shop for the staff of the Attorney General of Colombia.

In 1995, the attorneys and he, in cooperation with the Colombian Bankers Association developed and presented a two day seminar on money laundering detection and prevention for Colombian bankers, bank regulators, and government officials.

In 1996, at the request of the Banking Superintendent of Colombia Mr. Morley participated in a two day symposium attended by over 600 bankers. During this symposium he presented a detailed paper on know your customer and anti-money laundering compliance systems. Subsequent to the seminar he had several meetings with the Bank Superintendent and her staff on a number of anti-money laundering issues currently confronting the Colombian government.

Government of Peru (1997)

In 1997, at the request of the Banking Superintendent of Peru, Mr. Morley participated in a two day symposium attended by over 400 bankers. During this symposium he presented a detailed paper on know your customer and anti-money laundering compliance systems.

Government of Argentina (2002)

In March 2000, at the request of the Minister of Interior of Argentina, Mr. Morley held a number of seminars and small group consultations for prosecutors and senior government officials in Buenos Aires on the methods used throughout the globe to build money laundering prevention and detection systems at the government level.

Mr. Morley also conducted a two day work shop for senior law enforcement officials and agents from various branches of the Argentine police and customs offices. The work shop dealt with the detailed financial investigative techniques that can be used to prosecute money laundering and other white collar crime offenses.

At the request of the Argentine Bankers Association, Mr. Morley conducted an extended conference with key banking leaders on the issues surrounding money laundering detection and prevention.

Testimony before government officials

In 1989, Mr. Morley testified before the United States Senate Banking Committee as an expert on the subject of pending legislation requiring minimum documentation for wire transfers.

In 1993, he was asked to join the American Bar Association and the U.S. Sentencing Commission Money Laundering Working Group. As a member of the working group, he drafted monographs for the Commission recommending revisions to the money laundering sentencing guidelines. The Commission subsequently used his recommendations as a basis for revisions to the money laundering guidelines. (The revisions were passed by the Commission in 1995 but vetoed by Congress.)

In 1993 and 1994, Mr. Morley testified as an expert before the United States Sentencing Commission on the sentencing guidelines for money laundering and structured transactions. As a result of his testimony (and the testimony of others) before the Commission, the Commission amended the sentencing guidelines for structuring.

In 2007, Mr. Morley participated in a three-day seminar in Bogota, Colombia, organized by the U.S. Treasury Department Office of Counter-Terrorist Financing and Money Laundering.

ATTACHMENT #2
VIDEO PRODUCTIONS

Operation Buckstop (1996)

Mr. Morley wrote and produced this money laundering law enforcement video under contract for the U.S. Customs Service. The video is centered around live footage of U.S. Customs agents searching for, finding, and seizing currency being smuggled out of the U.S. by airline passengers and in airline cargo shipments. The video uses these examples and other footage to train Customs Service agents how to inspect passengers, luggage, and cargo to detect currency being smuggled out of the U.S.

Blue Skies and Black Money (1986)

Mr. Morley wrote and produced this video for the Central Intelligence Agency. The training video is a dramatization of the sophisticated methods narcotics traffickers use to launder money through Panama and other offshore secrecy havens.

DEA Financial Investigations Course

In 1988, the Drug Enforcement Administration requested Mr. Morley to write a series of training videos on conducting complex financial investigations. In these videos, Mr. Morley used dramatizations of investigations to demonstrate investigative techniques agents could use to solve financial crimes. During this project the DEA produced the following videos:

Computer Systems, Business Organizations & Attorney Coordination (1988)

Searching Public Records (1988)

Tracing Financial Transactions Through Banks (1989)

Tracing Stock & Commodity Transactions (1990)

Though Mr. Morley completed the following scripts for the DEA, the producer of the series transferred from the DEA training academy at Quantico, VA and his successor did not continue production of the remaining three videos:

Investigating Money Laundering (1990)

Using Indirect Methods of Proof (1990)

Seizure and Forfeiture of Assets (1990)

U.S. Secret Service (1993)

In 1993, the U.S. Secret Service requested Mr. Morley to write a video script to train their agents in the investigative methods used to locate, seize, and forfeit assets. Mr. Morley completed a script in 1994 based upon three cases: telephone fraud, credit card fraud, and bank fraud. After two minor revisions, the Secret Service approved the script; however, they were unable to release sufficient staff to produce the video.

Videos written and produced for the CGM Group, INC.

The CGM Group, Inc., is the producer of the DIRTY MONEY series of bank training videos. Mr. Morley wrote and co-produced the videos for his company. The videos include:

A Banker's Guide to Self-Defense (1985)

Recognizing Laundering Schemes (1986 in cooperation with INTERPOL)

Teller Compliance and the Bank Secrecy Act (1987; revised 1989;
revised 1996)

Exempting Transactions Under the Bank Secrecy Act (1987)

What the Feds Look For (And How to Find It First) (1989)

The DIRTY MONEY series was endorsed and licensed by the major U.S. banking associations. The series was standard training for the U.S. bank regulatory agencies, the banking industry, various U.S. law enforcement agencies, INTERPOL and several major foreign enforcement agencies. The banking series is now out of date due to changes in bank regulations. The CGM Group has decided not to update the series, due to other commitments.

ATTACHMENT #3
PAPERS PRESENTED AND ARTICLES WRITTEN

The Bank Secrecy Act

Bank Administration Institute 1986 seminar
The Institute for Strategy Development 1986 seminar

Bank Secrecy Act Compliance
and the Money Laundering Control Act

National Assn. of Criminal Defense Lawyers 1987 seminar
U.S. League of Savings Associations 1987 seminar
Bank Administration Institute 1987 seminar
Federal Financial Institutions Examination Council 1987 training class

The Illegal Use of Offshore Shell Banks

Federal Financial Institutions Examination Council 1987 training class

The Role of Wire Transfers in Money Laundering

Monograph and testimony presented to the U. S. Senate Banking Committee (1989)

The New Treasury Targeting Regulations, No Room For Error

Article for The Journal of Bank Accounting And Auditing (Winter, 1990)

Suspicious Banking Transactions

Article for Money Laundering Alert (1990)

What the Feds Look For (And How to Find It First)

Executive Enterprises, Inc. 1990 seminar

How a Drug Dealer Laundered $800,000
Through the Republic National Bank of Florida

Article for The Journal of Bank Accounting And Auditing (Fall, 1990)

The Financial Institution's Guide to Suspicious Transactions

Monograph for the 1990 ABA/ABA Money Laundering Conference

Chasing The Drug Dollars
(How Financial Investigations Are Snaring the Drug Lords)

Feature article for U.S. Information Agency world-wide distribution (1991)

Recent Developments in International Financial Fraud
and Suggested Preventative Techniques

Banker's Association of the Bahamas and the Central Bank of the Bahamas 1992 training class. Mr. Morley presented this day long training seminar to a large number of Bahamian bankers. The seminar was organized by the Bankers Association and the Central Bank.

Proposed Sentencing Guidelines for
Money Laundering and Structuring Offenses

Three monographs presented to the U.S. Sentencing Commission (1992-1993) (See Government Consulting at Attachment #1.)

How Banks Can Respond To Government Subpoenas

Article for The Money Laundering Law Reporter (1993)

Investigating, Organizing, and Presenting
Complex Financial Cases

Society for the Reform of Criminal Law, 8th International Conference (1994)

Thirteenth Annual Symposium on Economic Crime, Cambridge, England (1995). Over 600 participants from more than 50 countries attended this symposium.

Money Laundering, Does Your Compliance System Measure Up?

Article for The Bankers Magazine (May/June 1994)

Corporate Exposure to Money Laundering

Article for The Money Laundering Law Reporter (1994)

Money Orders and Money Laundering:
Patterns and Precautions

Article for The Money Laundering Law Reporter (1994)

Suspicious Transactions
and Government/Bank Compliance Systems

Venezuelan Bankers' Association 1992 seminar; Caracas, Venezuela. Over 300 Venezuelan bankers and senior government officials attended this seminar.

Colombian Bankers Association 1994 seminar; Bogotá, Colombia. Over 300 Colombian bankers and senior government officials attended this seminar. (See Government Consulting at Attachment #1 above.)

Logros & Objectivos 1994 seminar; Bogotá, Colombia
Dieg Portales University of Chile and Paz Ciudadana 1994 seminar; Santiago, Chile

The Effect of Money Laundering on State Security
The Illegal Use of Offshore Banks and Companies
Investigating Money Laundering Crimes
Investigating, Organizing, and Presenting Complex Financial Cases

Conference on International Narco-Trafficking and the Security of Caribbean States (1995). Representatives from each of the English speaking Caribbean countries attended this seminar.

Thirteenth Annual Symposium on Economic Crime; Cambridge, England (1995).

Willful Blindness: The Achilles Heel of Compliance

Joint Canadian, United States 1996 Conference on Money Laundering. This was the first joint U.S./Canadian conference on money laundering. Over 200 bankers, attorneys, and senior U.S. and Canadian government officials attended the seminar.

Corruption & Development: Abuse of Office:
Standards in Public Life

Fourteenth Annual Symposium on Economic Crime; Cambridge, England (1996). Over 900 participants from more than 50 countries attended this symposium.

Anti-Money Laundering Compliance Systems for Banks

Colombian Superintendent of Banks 1996 seminar; Bogotá, Colombia. Over 600 Colombian bankers and senior government officials attended this seminar.

Anti-Money Laundering Compliance Systems
for Casas de Cambio

Colombian association of Casas de Cambio (Asocambios) 1996 seminar; Bogotá, Colombia. Representatives of each of the licensed Casas de Cambio in Colombia attended this seminar.

Following Electronic Money
Using Personal Computers to Conduct Complex Financial Investigations

Fifteenth Annual Symposium on Economic Crime; Cambridge, England (1997). Over 900 participants from more than 90 countries attended this symposium.

Investigating Suspicious Transactions

FDIC New York Regional Training Conference (1999)

The Detection & Prevention of
Money Laundering Schemes

Conference of Offshore Life Insurance & Annuities (1999)

The Detection and Prevention of Money Laundering In Guatemala

A seminar presented to bankers, attorneys, and government officials in Guatemala City, Guatemala (Feb 2000)

Building Money Laundering Detection
and Prevention Systems In Argentina

A series of seminars and small group consultations on the methods used throughout the globe to build money laundering prevention and detection systems at the government level. This project was developed at the request of the Minister of Interior of Argentina. (March 2000)

Financial Investigations of Money Laundering
and White Collar Crime

A two day training work shop held for senior police and law enforcement officials of Argentina. (March 2000)

Money Laundering Detection and Prevention
Compliance Systems

A seminar held for senior banking officials of Argentina at the request of the Argentine Bankers Association. (March 2000)

Money Laundering Detection and Prevention
Compliance Systems For Casas de Cambio

A seminar presented in Buenos Aires for owners and managers of South American Casas de Cambio. (July 2000)

A seminar presented in Cancun for owners and managers of Central American Casas de Cambio. (October 2000)

Money Laundering Detection and
Prevention Compliance Systems

Preparation and presentation of a detailed course on the detection and prevention of money laundering (2001). This presentation is now one of the core courses in the McHari Institute’s Anti-Money Laundering diploma course.

Financial Investigations of Money Laundering
and White Collar Crime

Preparation and presentation of a detailed course on conducting complex financial investigations for McHari Institute, Bahamas (2001).

Money Laundering Detection
and Prevention Compliance Systems

A seminar presented to bankers, attorneys, and government officials in Caracas, Venezuela (2001)

Seminars presented to members of the Florida International Bankers Association, Miami FL (2003- 2007)

Three seminars presented to participants at the 2005 Conference for the National Association of State Credit Union Supervisors and the National Credit Union Administration

BOOKS PUBLISHED

Tracing Transactions Through Financial Institutions

Mr. Morley wrote Tracing Transactions Through Financial Institutions in 1987, at the request of the Police Executive Research Forum (PERF). The booklet presents a detailed and illustrated explanation of how law enforcement agents can trace transactions through bank records. PERF published this booklet in conjunction with its training programs in which Mr. Morley was an instructor. PERF presented these programs to thousands of federal, state, and local law enforcement officers and prosecutors throughout the United States.

Financial Investigations Check List
and Quick Reference Guide

Mr. Morley wrote Financial Investigations Check List and Quick Reference Guide in 1992 at the request of the U.S. Department of Justice, Executive Office of Asset Forfeiture. The booklet, written for federal prosecutors and federal agents, explains the documents they can access and use to conduct complex financial investigations. The booklet was distributed to and is used by all federal prosecutors and law enforcement agents, including the FBI, U.S. Customs Service, U.S. Secret Service, Internal Revenue Service, and other federal agencies.

Financial Investigations Source Book and Quick Guide

The Department of Justice granted Mr. Morley permission to publish the Check List under his own title for sale to state and local prosecutors and law enforcement agents.

Compliance Manual & Handbook for
The National Check Casher's Association

Mr. Morley co-authored the Compliance Manual & Handbook for NaCCA (now known as FiSCA) in 1994 (see Compliance Systems Projects at Attachment #4). The Bank Secrecy Act and anti-money laundering manual and handbook are used by all check cashers who are members of NaCCA.

The Anti-Money Laundering Resource Notebook

Two attorneys and Mr. Morley co-authored this comprehensive volume for banks (Spanish and English versions) in 1994. It covers a wide range of issues involving money laundering, and the international efforts to combat laundering.

DOCUMENTS PUBLISHED WHILE EMPLOYED AS THE CHIEF INVESTIGATOR
OF THE SENATE PERMANENT SUBCOMMITTEE ON INVESTIGATIONS

Crime & Secrecy: The Use of Offshore Banks & Companies

Senate staff study (co-author and co-editor, 1983)
Senate report (co-author and co-editor, 1985)

The Crime & Secrecy series has been one of the largest selling publications in the history of the Government Printing Office. The staff study and report have received world-wide distribution, and are widely considered to be seminal works on money laundering.

Laundering Money Through Offshore Secrecy Havens

FBI/DEA field supervisors' 1993 training class

IRS Criminal Investigation Mid-Atlantic Region 1983 training class

Battelle Memorial Institute 1984 & 1986 seminars

University of Maryland Law School 1985 seminar

ATTACHMENT #4
COMPLIANCE SYSTEMS PROJECTS AND RELATED INVESTIGATIONS

Reviewed compliance system for a multi-national bank

During this project, Mr. Morley reviewed the compliance system of a large, multi-national bank. He reviewed the bank’s systems for handling currency, bank checks, wire transfers, accounts, and private banking. Upon completing the review, he wrote a report in which he made appropriate recommendations.

Conducted major risk assessment, reviewed compliance systems,
and drafted recommendations for a major Latin American bank

During this project, two attorneys and Mr. Morley conducted an in-depth risk analysis within the bank. This included identifying many suspicious activities within a number of accounts, and tracing these transactions through other accounts and transactions within the bank. The team reviewed the bank’s compliance system and made significant recommendations for strengthening the system. They conducted training sessions for bank employees, and Mr. Morley drafted a script for an anti-money laundering training video to be produced in-house at the bank.

Designed, wrote, implemented, and audited
anti-money laundering compliance systems for a national bank

This project involved designing an anti-money laundering system from the ground up. During this project, Mr. Morley organized working groups to design specific compliance functions. Based upon the working groups’ decisions, Mr. Morley drafted detailed policies and procedures for the bank. After the procedures were implemented, he trained the entire bank staff in the policies and procedures. Six months after the bank implemented the procedures, Mr. Morley conducted an in-depth audit of the procedures to ensure they were working as designed.

In addition, Mr. Morley conducted comprehensive anti-money laundering training sessions for the entire staff of an affiliate bank.

Reviewed internal systems of a major funds transmitter

During this project, Mr. Morley conducted a detailed review of the funds transmitter’s internal systems and procedures. He prepared a detailed report consisting of many appendices and exhibits which clearly demonstrated the operating and compliance systems previously and currently in use.

Reviewed internal systems of a major Swiss private bank

During this project Mr. Morley conducted an in-depth review of the anti-money laundering system of a major Swiss private bank. The review encompassed all systems in the bank, with particular emphasis on the bank’s know your customer policies for foreign account holders, securities customers, and loan customers. Upon completing the review, he prepared a detailed report in which he made specific recommendations.

Reviewed compliance systems and conducted 100% review
of all customer accounts and loans for large, privately held international bank

This project began as a result of the United States indictment of one of the largest privately owned banks in the world. In accordance with a memorandum of understanding (MOU) issued by the U.S. Federal Reserve, Mr. Morley and a team of external lawyers led a team of bank personnel in a complete review of the bank’s compliance systems. As part of this review, the team reviewed each of the thousands of U.S. accounts and loans held by the bank in three U.S. cities. The team used criteria sheets Mr. Morley designed to determine if the accounts/loans reflected questionable activity. Mr. Morley reviewed those that fit the criteria, and forwarded the accounts with suspicious activity to counsel for their review. Many suspicious accounts were referred to the government as a result of this process.

After the review, Mr. Morley drafted specific recommendations to improve the bank’s compliance system. Mr. Morley next conducted anti-money laundering training classes for a large number of managers and partners from a “big six” accounting firm to enable them to monitor bank transactions daily, in accordance with the MOU.

Conducted risk assessment of small private bank

This project entailed reviewing all accounts and transactions for customers of a particular bank officer. Mr. Morley used specific criteria to select accounts for detailed review; disregarding those that did not fit the criteria. He identified a number of accounts requiring further review and additional accounts containing suspicious activity. He prepared a detailed report for the bank’s counsel and CEO, recommending specific action be taken to deal with the suspicious accounts and to further trace questionable transactions through the bank’s records.

Wrote compliance manual and staff training manual
for National Check Cashers Association

As a consultant for the National Check Cashers Association (NaCCA, now known as FisCA), Mr. Morley co-authored a detailed anti-money laundering compliance manual and a companion training handbook for employees for the association. NaCCA distributed the manual and handbook to all its members. Mr. Morley has since updated the manual to reflect new money laundering techniques and regulations.

Since writing the manual, Mr. Morley has conducted detailed training seminars at four national NaCCA conventions, and at state-wide meetings in New York, Illinois, and New Jersey.

Wrote compliance manual for major issuer of
money orders, and their agents

A major money order company engaged Mr. Morley to write a compliance manual for their company and a brief compliance booklet for their world wide network of agents. After writing the compliance manual, Mr. Morley conducted multiple training sessions; training all headquarters employees in anti-money laundering systems and procedures.

Wrote compliance manual for major
international funds transmitter

One of the world’s largest funds transmitting companies engaged Mr. Morley to design and implement a comprehensive money laundering prevention system for their world wide operations.

Conducted in-depth reviews of three years’ of transactions
of a major division of an international bank’s operations in compliance with bank regulator’s requirements and instructions

This investigation arose from a regulatory order that the bank retain an independent consultant to completely reconstruct all transactions in a major trade finance division of the bank. The investigation was to review for suspicious activities and possible violations of the requirements of the Bank Secrecy Act and other government regulations.

Directed and conducted in-depth reviews of
selected high-risk accounts of a domestic bank

This investigation arose from the bank’s initiative to review high-risk accounts for questionable transactions. The bank regulators subsequently incorporated the investigation in their “informal” requirements for the bank.

Evaluated the compliance systems of a major
Latin American bank, and three domestic banks

One of the larger Latin American banks engaged Mr. Morley to conduct an in-depth review of their anti-money laundering detection systems and make appropriate evaluations and recommendations. In addition, three domestic banks have engaged Mr. Morley to conduct similar reviews of their systems.

MONEY LAUNDERING INVESTIGATIONS INVOLVING FINANCIAL INSTITUTIONS

In addition to investigations conducted in conjunction with the above compliance activities, Mr. Morley has conducted a number of money laundering investigations that did not involve reviews or recommendations of compliance matters. The following are examples of these cases.

Conducted investigation of alleged money laundering activities
of officers of a large international private bank

This investigation arose from multiple indictments of BCCI and a number of BCCI’s officers. As a member of the criminal defense team, Mr. Morley analyzed a large number of complex transactions involving the movement of funds among many branches of the bank in a number of countries. He prepared detailed trial books for council, reducing the complex transactions to single page charts accompanied by appendices and exhibits documenting the evidence presented in the summary charts.

During the trial Mr. Morley assisted in the preparation of cross examination questions of government agents and experts and prepared instant analysis of evidence as it was introduced by the prosecutors.

Conducted investigation involving a civil suit by
a Latin American bank against a major European bank

This investigation arose from a civil suit alleging a major European bank conspired to assist an individual in laundering funds the individual obtained by defrauding a major Latin American bank. As part of this investigation, Mr. Morley traced transactions through a number of accounts held in the names of various companies. He prepared schedules and charts showing patterns indicating money laundering, and testified in federal court as to the results of his investigation.

Conducted investigation into the illegal use
of shell bank accounts held at a small Caribbean bank

This investigation involved Mr. Morley’s review of hundreds of accounts held in a small Caribbean bank in the names of various offshore shell banks. A significant number of the shell banks holding these accounts were being used for fraudulent activity including phony document schemes and advance fee schemes. After reviewing the accounts, Mr. Morley prepared a detailed report containing extensive documentation and recommendations for compliance systems to prevent future illegal activity through the bank.

Conducted investigations of allegations of officer
misconduct at two small, unrelated banks

Two investigations Mr. Morley conducted concerned fraudulent activity by two officers at two small, unrelated banks. Both investigations involved tracing a number of complex transactions to determine exactly what occurred in the banks. In both cases, Mr. Morley issued detailed reports with extensive documentation.

Conducted investigation of alleged money laundering
by a large South American bank and its senior officer

This investigation was part of a major international money laundering investigation by the U.S. Customs Service. Mr. Morley assisted defense counsel by conducting a detailed investigation of all transactions directly and indirectly related to the alleged money laundering transactions. He prepared a detailed and documented time line of events and two comprehensive documented reports of his findings. Mr. Morley also assisted counsel in legislative research and other matters directly bearing on the case.

Conducted due diligence investigation of alleged
major BSA violations by an officer of domestic bank

This investigation arose from the discovery of bank examiners of major non-compliance issues by one of the bank’s officers. The investigation involved a comprehensive due diligence of the banks BSA systems and other systems related to BSA and money laundering detection and prevention. The due diligence extended over a three-year period, and included examinations of customer transactions for suspicious activities. The investigation culminated in building the bank’s compliance system literally from the ground up as well as extensive meetings with Federal Reserve Bank enforcement officials and officials of the Financial Crimes Enforcement Network (FinCEN).

ATTACHMENT #5
MONEY LAUNDERING AND FINANCIAL INVESTIGATIONS
TRAINING SEMINARS/COURSES

The domestic and foreign government law enforcement and banking agencies for whom Mr. Morley has conducted seminars include: The Police Executive Research Forum; The National Association of Attorneys General; The Institute of Internal Auditors; Venezuelan, Colombian, and Bahamian Bankers Associations; Foreign Bank Fraud Working Groups; and Offices of District Attorneys.

A U.S. Government contractor has subcontracted with Mr. Morley to provide money laundering training for foreign law enforcement officials during their visits to the United States. Mr. Morley’s presentations included an overview of money laundering and the methods U.S. law enforcement officials and prosecutors use to detect and prosecute money laundering. Mr. Morley has provided these briefings to large numbers of law enforcement officials from Brunei, Czechoslovakia, Ghana, Greece, Israel, Kuwait, Nigeria, Pakistan, Uganda, Croatia, Italy, Bulgaria, Morocco, Saudi Arabia, Syria, Trinidad, Brazil, Panama, the United Arab Emirates, and Germany.

Mr. Morley, under the auspices and at the request of the Florida International Bankers Association (FIBA) has developed and presented a comprehensive course for senior BSA compliance officers. Over 120 officers have taken the course in Florida and California to date. Mr. Morley in conjunction with FIBA and the Florida International University (FIU) has since created and is presenting courses at both the associate and professional levels in Anti-Money Laundering. Both courses are taught world-wide, and the Associate course is available as web-based training in both English and Spanish. Both the Associate and Professional courses have been certified by FIU.