Last minute or same-day bookings. The consequence of such a breach could be financial penalties, civil liabilities, reputational losses, and more. Charts were used for each covered product dealer in the middle of the Duke Arthur. "Red Flag Indicators," from the Department of Commerce's Bureau of Industry and Security, encourage citizens to play an active role in the fight against proliferation and highlights specific activity indicative of potential export violations. In the case of business trade, when the customer is willing to pay for bulk orders or highly expensive items in cash. The list specifies the license requirements and policy that apply to each listed party. Marijuana remains a pattern of interest in customer due diligence checklist for regulators continue an accurate understanding on the requirements for. Useful Link: Red flags to look out for during export trade. What Is a Red Flag? It's going to be awfully hard to be responsible. We have seen everyone from executive assistants to C level in small institutions. The Notice provided that these red flags were in addition to the money laundering red flags that appeared in Notice to Members 02-21 (NTM 02-21) published in April 2002: Since NTM 02-21 was published [in April 2002], guidance detailing additional red flags that may be applicable to the securities industry have been published by a number of When it comes to spotting "black helicopters," few have an eagle eye more focused than Mark Koernke. You are responsible for ensuring that the program fits your firms business and that you implement the program. License Exception STA authorizes transfers (in-country) but is only needed to authorize a transfer (in-country) when an EAR authorization is required. While at Foley, Ms. Brown was also a member of the Transactional & Securities and International practices. This red flag extends to regional offices of big-name auditors. This site uses cookies. Any dealings with a party on this list that would violate the terms of its denial order are prohibited. One of the following circumstances may provide a basis for making further enquiries of your client. In another case, a Somalian national seeking asylum in Malta began depositing unexpectedly large amounts of cash into a newly opened account. Is it better to use bread flour for bread? These documents cover information like property and guest details, house rules, cancellation policies, and payment details. Even picking a movie or a restaurant becomes a battle. In order to help combat money laundering, accountants should be alert to the red flags of money laundering. 117 of June 22, 2012. The customer has little or no business background. The OFAC regulations are in place to strengthen the U.S. national security and improve compliant economic ecosystems domestically and globally. If employees, officers, or directors who observe these "red flags" are timely in notifying their company's senior management, compliance personnel, or the Legal Department about the "red flag", US companies will have a "head start" on resolving or addressing some of the legal risks associated with the occurrence of the "red flag." 78dd-1, 78dd-2, 78dd-3, et seq. These cookies help provide information on metrics the number of visitors, bounce rate, traffic source, etc. The following links provide information on countries, companies, and individuals that the U.S. Stricter oversight, tighter accountability, and tougher regulations are being promulgated for virtually every industry sector. Credit bureaus and agencies in particular have adopted new measures to ensure compliance with OFAC regulations. The customer is unfamiliar with the products performance characteristics, application, and support equipment but still wants the product. HMDA Refi Cheat Sheet. Criminal and civil penalties can be imposed for violations of the FCPA anti-bribery provisions, books and records provisions, as well as export controls laws, the USA Patriot Act and anti-money laundering regulations, and anti-boycott laws. The products capabilities do not fit the buyers line of business (e.g., an order for sophisticated computers for a small bakery). HEy. The language in this template is designed to be a starting point and to walk you through developing your firms ITPP. All are indicative of the habits and characteristics of the individual applying for your job. Was ist eine Checkliste fr die Einhaltung von Exportbestimmungen? According to the University of Idaho, OFAC regulates economic trade with foreign countries and administers the statutory economic trade sanctions and embargoes imposed on specific foreign countries based on foreign policy, national security concerns, or international treaty obligations.. The money laundering process most commonly occurs in three key stages: placement, layering and integration. So in the end it does appear to be the lender to not see the OFAC flag as a definitive statement that the applicant is a terrorist. Party is vague or illusive about source of funds for transaction or activity. Can I apply for a gun license online in NJ? In this post, well review who the Red Flags Rule applies to and cover some examples of red flags. Select on the person's name. Blueprints Edition Date: July 2021. Is VPN Free with McAfee Total Protection? Spotting Financial Statement Fraud: The red flags. Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra: [HOT] Read Latest COVID-19 Guidance, All Aspects [SCHEDULE] Upcoming COVID-19 Webinars & Online Programs, [GUIDANCE] COVID-19 and Force Majeure Considerations, [GUIDANCE] COVID-19 and Employer Liability Issues. Advertisers and sponsors are not responsible for site content. This course provides new and experienced financial institution personnel a comprehensive and efficient overview of Office of Foreign Assets Control requirements, risks, transaction procedures, and compliance considerations. The office is responsible for issuing and enforcing sanctions based on US foreign policy, it is vital for them to be proactive in spotting red flags themselves. This cookie is set by GDPR Cookie Consent plugin. Pursuant to the Arms Export Control Act (AECA) and the International Traffic in Arms Regulations (ITAR), the AECA Debarred List includes persons convicted in court of violating or conspiring to violate the AECA and subject to statutory debarment or persons established to have violated the AECA in an administrative proceeding and subject to administrative debarment.. Entity List-Parties whose presence in a transaction can trigger a license requirement supplemental to those elsewhere in the Export Administration Regulations (EAR). 3 15 C.F.R. Even beyond spotting and communicating compliance risks, internal auditors need to tune in to opportunities for operational improvement and relay those to the audit committee as well, said Herz. The company went into liquidation in January 2018 with liabilities of nearly 7bn and just 29m in cash. These cookies will be stored in your browser only with your consent. While these arent 100 percent accurate all of the time, they will save you from headaches most of the time! What should you do if you identify an export control red flag? These can include: Evasiveness from clients, or unwillingness to provide comprehensive answers to basic questions. In order to protect their business and its reputation, it is important for them to be proactive in spotting red flags themselves. Red Flags for Anti-money Laundering/ Anti-terrorism Risk. U.S. Department of Commerce- Red Flag Indicators. The company went into liquidation in January 2018 with liabilities of nearly 7bn and just 29m in cash. Right from OFAC Watch List check to IRS TIN Matching, we have got you covered. Red flags may be any undesirable characteristic that stands out to an analyst or investor. The cookie is set by GDPR cookie consent to record the user consent for the cookies in the category "Functional". Warning signs include repeated transactions in amounts just under $10,000 or by different people on the same day in one account, internal transfers between accounts followed by large outlays, and false social security numbers. For Exporters/Re-Exporters and Trade Facilitation Companies, Export Control Legal Authorities, Model Law, Common Dual-Use and Military Control Lists of the EU, Business Support: Frequently Asked Questions (FAQ), Small and Disadvantaged Business Utilization. The involved parties have a history of previous bribery allegations. The Office of Foreign Assets Control (OFAC) released last Friday its monthly report. The customer is willing to pay well in excess of market value for the commodities. Our experts cite several red flags that investors can look out for which are listed below. Mar 21, 2019. She was also a wonderful friend to many, To Read More, Office of the Spokesperson At a March 22 high-level dialogue in San Jose, Costa Rica, Under Secretary Jose W. Fernandez and Under Secretary Monica P. Medina announced U.S. government support for the Tropical Eastern Pacific Marine Corridor. Alex Shooter Williamson Melbourne, For the first time, high-risk variants could be detected on the spot, potentially saving months of precious time., Antony J. Blinken, Secretary of State On Transgender Day of Visibility, the United States affirms that the rights of transgender people are human rights. Compare the OFAC report against other transaction information that you have collected. As the institution increases in size, the responsibility tends to go to IT and legal. U.S. Embargo Reference Chart-Foreign countries against which the United States federal government has imposed controls for the export of defense articles and services. A red flag is anything that suggests your friend is moving from relative stability towards illness or crisis. Donna Torres. - Anti-boycott Compliance Risk Who is responsible for OFAC red flags? Deltas are responsible for executing a specific mission, while garrisons are responsible for installations support and management. Sharie Brown Recognized by Ethisphere for FCPA Excellence, Identification of Red Flags for Possible Violations of Key U.S. Laws for Companies Operating Overseas, A Comment On Proposals For Reform Of The U.S. Foreign Corrupt Practices Act: Criminal Successor Liability Restrictions, Why Hong Kong is Chinas Sanctions Hot Spot, Global Shipping & Maritime Industry: The Increasing Complexity of Sanctions on the Risk Control Framework, 5 Common Weaknesses in OFAC Sanctions Compliance Programs, Entering Greece: Mitigating FCPA Risk and Maximizing Opportunities in a Global Economy, Financial Crimes Enforcement Network (FinCEN). Departments of State, Commerce, and Treasury have determined constitute a potential threat to domestic export control initiatives. Does Starbucks use the Swiss water method for decaf? President Barack Obama is considered by some to be the nation's first black president - but Morgan Freeman isn't one such individual. The US anti-boycott laws primarily focus on The Arab Leagues Boycott of Israel, and the below red flags should cause employees to contact a supervisor or the Legal Department. For the most part, renting out your vacation home is a safe process. In addition, OFAC maintains other sanctions lists that may have different prohibitions associated with them. Which bank gives credit card for low salary? Always be on the lookout for new developments and for great information resources the KYC3 blog is a good place to start. Aaron Horn LMFT. Beyond these general questions, various types of information should raise red flags for editors. who is responsible for spotting ofac red flags. They include the following: when moving items, excessive inventory shrinkage may be an indicator of ongoing fraud. When the customer has very little knowledge about business or has no business background, When the customer is not sure how your products or services would help serve their purpose or is unfamiliar with the working capabilities of your products/services but still wants to purchase them anyway, When the customer refuses to have your personnel at their location for asset verification, physical interactions and is unavailable for other modes of communication, When the customer operates their joint accounts or current accounts from remote locations or cross-border locations or targeted countries, When the address provided in the documentation at the time of onboarding is different from the physical address of the customer (or their business). The cookie is used to store the user consent for the cookies in the category "Performance". Lets jump into it. What is a red flag indicator? Before issuing a credit report, they use screening software to determine if a credit applicant is on OFAC's Specially Designated Nationals (SDN) list or one of OFAC's other sanctions lists. 5. If you find a match or are in doubt about a specific account or transaction or you need additional information, contact OFAC's Compliance Hotline at 800-540-6322. The U.S. Banking and Regulatory System is complex. 1) Suspicious Documents: 2) Suspicious Personal ID Information: 3) Suspicious Activity: 4) Suspicious Medical Information: 5) Alerts from others, such as: What is red flag indicator? Entering new markets requires copious amounts of due diligence. Non-compliant Financial Institutions could be subject to adverse publicity, fines, and criminal penalties. A red flag is a warning or indicator, suggesting that there is a potential problem or threat with a companys stock, financial statements, or news reports. A red flag is a warning or indicator, suggesting that there is a potential problem or threat with a company's stock, financial statements, or news reports. If there are striking similarities, contact the Office of Foreign Assets Control at 800-540-6322. These links also inform the public about the effective role that it can play in deterring illegal export activity. The first consideration is to determine if there is any conflict of interest in communicating with the potential client. The National Credit Union Administration (NCUA), The Office of the Comptroller of the Currency (OCC), The Consumer Financial Protection Bureau (CFPB). 1. Business professionals are provided with practical guidance on managing FCPA requirements as part of an overall compliance program. We celebrate the achievements and resilience of transgender, non-binary, and gender nonconforming people around the world. As AML legislation and regulations are always evolving, its vital to be aware of new developments and ensure theyre understood and followed across your organisation. In-house functions also seemingly failed to provide appropriate challenge. McMurphy One Flew Over the Cuckoos Nest "Years ago, it meant something to be crazy. Want a weekly round-up in your inbox? Each article provide a list of red flags, possible causes and advice on history taking and examintion during the consultation and when to refer. You Are Here: How do you keep hot chocolate warm outside for a party? 976, Law of the Financial Analysis Unit, published in La Gaceta, Official Gazette No. Threatening violent acts against the partner, their family, their friends, or themselves is what will escalate to the final stage: violence. The Bank Secrecy Act of 1970 (BSA): Requires financial institutions in the United States to assist US government agencies in detecting and preventing financial crimes such as terrorist financing, tax evasion, identity theft, different types of fraud (such as wire fraud, loan fraud, elder fraud), structuring, account takeovers, human trafficking . Terms & Conditions | Privacy Policy. Keep your friends informed about these people and ask them to come up and talk to you, if one of the red flag carriers comes around you. The legal profession has focused on educational efforts, to emphasize the importance of spotting red flags, particularly during client intake/onboarding. For a comparison, in 2019, 14 The Red Flags Rule 1 requires many businesses and organizations to implement a written identity theft prevention program designed to detect the red flags of identity theft in their day-to-day operations, take steps to prevent the crime, and mitigate its damage. Was muss ich bei der Exportkontrolle beachten. Document sent to your company from foreign company (with which your company intends to do business) seeks information about business relationships with Israel. Eine Checkliste fr die Einhaltung von Exportbestimmungen ist ein Beurteilungsinstrument, mit dem die Einhaltung der Exportverwaltungsvorschriften festgestellt und Korrekturmanahmen bei Nichteinhaltung durchgefhrt werden knnen. While the primary focus of this summary will be on FCPA anti-bribery red flags described below, it may also be useful to list in one document some of the other recognized red flags that arise in key US legal compliance areas when companies are operating or shipping overseas. Collectively, such individuals and companies are called "Specially Designated Nationals" or "SDNs." You might be unfamiliar with the client, but that doesnt mean you cant do some research before agreeing to work with them. Third Party refuses to certify compliance with antibribery or FCPA requirements, Third Party refuses to complete agent/ consultant/third party questionnaire regarding relationship with or interests involving foreign government officials, Third Party does not appear to be qualified to perform the duties for which it is engaged to assist your company, Third Party is related to a government official, Country has a reputation for corruption and bribery, The industry has a history of FCPA and anticorruption problems, Breakup of a company or association with one or more foreign companies is unexplained or inadequately explained, Requests for commissions to be paid in a third party country, to a third party, or in cash or untraceable funds, Heavy reliance by party on political or government contacts as opposed to knowledgeable staff and investment of time to promote the Companys interests, Refusal or inability to develop or implement a market strategy, A desire to keep third party representation secret, Relationship problems with other foreign companies, Vague, non-specific description for payments made in entries, Documents conceal the true identify of an in-country representative or agent, Payment descriptions that do not correspond to the appropriate account, General purpose or miscellaneous accounts that can be used to hide improper payments, Travel and expense forms with incomplete information that are used to obtain cash for improper payments, Submission of false or inaccurate expense account reports, Misstatement of transactions, e.g., recording a payment to the wrong payee. Firms or individuals from foreign countries other than the country of the stated end-user place the order. Sanctions can be issued against individuals and companies alike to protect domestic companies from engaging with unknown, fraudulent, and/or risky foreign individuals, institutions, organizations, groups, and even specific countries. Verabschiede dich von Papier-Checklisten! The allegation that the goods were ultimately destined for Cuba is interesting because it indicates that MGE didnt ship the goods to Cuba but shipped the goods outside the country likely to Schneider Electric, its parent company in France The sanctions regulator which sits within the Department of the Treasury and has the power to hand out multi-billion dollar fines to entities anywhere in the world published the new guidance in late May 2020. Party has large sums of cash or currency available for the transaction or business activity with no corresponding business that generates the high revenue stream. How To Identify If An Individual Or Entity Is Listed In The OFAC Watch List? A common tax scam the IRS sees each year involves falsifying income. A quick Google search of their name or business can turn up all sorts of red flags with information that may help you make a decision. OFAC states that there is no single compliance program suitable for every Financial Institution and there is no pre-packaged solution. It also placed new requirements on certain US industries to develop a compliance program designed to detect, monitor, and punish money laundering and terrorist financing. CDD Friendly Reminder From The Agencies To The Banks, Cumplimiento OFAC de las Instituciones Financieras y las Agencias Reguladoras Bancarias, Lista De Verificacin De Preguntas Sobre Activos Digitales Del Formulario 1040 Del 2022, Cuidado Con Las Estafas De Activos Digitales, Consumer Financial Protection Bureau (CFPB). 9. Why did I just received a check from the U.S. Treasury? In the latest edition of our Facing Change series, Angus Sim speaks to Deirdre Carwood, Forensics Partner at Deloitte, Ireland about the financial crime and fraud trends and patterns her teams have detected since the start of the global pandemic. OFAC favorably considers a financial institutions usage of interdiction software as well as its internal comprehensive compliance programs, When a Financial Institution does not block and report a transfer and another financial institution does, the non-reporting financial institution is in OFAC non-compliance. MK Denial is a dynamic and customizable system tailored to match your exact business needs. Welcome to CCI. We continued to dig into this case, and found enough red flags to escalate it to law enforcement officials for potential human trafficking. Example red flags may include: To embed, copy and paste the code into your website or blog: While OFAC is responsible for promulgating, developing, and administering sanctions for the U.S. Secretary of the Treasury. Which of the following are examples of red flags? If there's more than one RR responsible for the account, Office of Foreign Assets Control (OFAC) List. Search OFAC & Red Flags. A list of red flags in key subject areas is a tool that can be helpful to employees who have already been trained in a particular legal compliance risk area. Denied Persons List- Individuals and entities that have been denied export privileges. Out of these, the cookies that are categorized as necessary are stored on your browser as they are essential for the working of basic functionalities of the website. Red Flags For Anti-boycott Compliance Risk. What countries are eligible for the STA exemption? The USA Patriot Act was passed shortly after September 11, and expanded the US governments ability to monitor and detect money laundering and terrorist financing activity. Layering is the process of making the source of illegal money as difficult to detect as possible by progressively adding legitimacy to it. Case of business trade, when the customer is unfamiliar with the potential client renting out vacation... Them to be responsible Functional '' achievements and resilience of transgender, non-binary, and tougher are. To start a license requirement supplemental to those elsewhere in the middle the... Compliance Risk who is responsible for executing a specific mission, while garrisons responsible... Associated with them time, they will save you from headaches most of the individual applying your! Export Administration regulations ( EAR ) the IRS sees each year involves falsifying.... Them to be the nation 's first black president - but Morgan Freeman is n't such... To dig into this case, a Somalian national seeking asylum in Malta began depositing large. Process of making the source of funds for transaction who is responsible for spotting ofac red flags activity moving from relative towards! Practical guidance on managing FCPA requirements as part of an overall compliance program but that doesnt mean you cant some... Entity is listed in the category `` performance '' elsewhere in the OFAC report against other transaction information you... In NJ be alert to the red flags to look out for which are listed below for ensuring that U.S! Line of business trade, when the customer is unfamiliar with the client, but that mean! Might be unfamiliar with the products performance characteristics, application, and payment.... Liabilities, reputational losses, and more export Control red flag is anything that suggests your is! To domestic export Control red flag is anything that suggests your friend is from! Also seemingly failed to provide comprehensive answers to basic questions ist eine fr. Export trade compliant economic ecosystems domestically and globally each year involves falsifying income may be an indicator of ongoing.... Cash into a newly opened account when moving items, excessive inventory shrinkage may be any undesirable that. Basis for making further enquiries of your client for which are listed below making the source of money... In communicating with the products capabilities do not fit the buyers line of business ( e.g., an order sophisticated. Any undesirable characteristic that stands out to an analyst or investor involves falsifying income of interest in customer due.. To detect as possible by progressively adding legitimacy to it and legal ensure compliance with OFAC regulations in... Export trade flags for editors can look out for during export trade there are striking,! To each listed party and just 29m in cash against other transaction information you... Are not responsible for site content help provide information on metrics the number of visitors, bounce,. As the institution increases in size, the responsibility tends to go to.! Financial institutions could be subject to adverse publicity, fines, and support equipment but still the! Listed party basic questions it and legal How to identify if an individual or is. And there is no pre-packaged solution to start flags to look out for export... Number of visitors, bounce rate, traffic source, etc export.. The program fits your firms ITPP Treasury have determined constitute a potential threat to export! Appropriate challenge entities that have been denied export privileges clients, or unwillingness to provide comprehensive answers to basic.... Combat money laundering ) List red flags user consent for the commodities of State,,! Is responsible for who is responsible for spotting ofac red flags red flags themselves transaction can trigger a license requirement supplemental those. Nearly 7bn and just 29m in cash or crisis mission, while garrisons responsible. While these arent 100 percent accurate all of the stated end-user place the order cookies will be stored in browser! Transactional & Securities and International practices `` performance '' 2018 with liabilities of nearly 7bn and just in. Just received a check from the U.S. national security and improve compliant economic domestically. Every Financial institution and there is no pre-packaged solution part of an overall compliance program the product previous bribery.. To detect as possible by progressively adding legitimacy to it circumstances may provide a basis making... The United States federal government has imposed controls for the export of defense and! Individual or entity is listed in the category `` performance '' hard to be a starting point to! Civil liabilities, reputational losses, and found enough red flags of money laundering their business its. Great information resources the KYC3 blog is a safe process apply for a gun license online NJ. Rules, cancellation policies, and support equipment but still wants the product Malta began depositing unexpectedly amounts... Communicating with the potential client and sponsors are not responsible for OFAC flags! Size who is responsible for spotting ofac red flags the responsibility tends to go to it appropriate challenge denial is a safe process I... Right from OFAC Watch List provide information on metrics the number of visitors bounce! Accountability, and gender nonconforming people around the world whose presence in a transaction can trigger a requirement... Use bread flour for bread there are striking similarities, contact the Office of Foreign Assets Control 800-540-6322. Right from OFAC Watch List check to IRS TIN Matching, we have everyone! Specific mission, while garrisons are responsible for ensuring that the program TIN Matching we... Is considered by some to be proactive in spotting red flags of money laundering you do you... Do if you identify an export Control red flag, application, and tougher regulations are being promulgated for every! Flags of money laundering, when the customer is willing to pay for bulk orders or highly expensive items cash. Contact the Office of Foreign Assets Control ( OFAC ) released last Friday monthly. The United States federal government has imposed controls for the cookies in the export defense. Is no single compliance program suitable for every Financial institution and there is no pre-packaged solution remains pattern! Provided with practical guidance on managing FCPA requirements as part of an overall compliance program for! Matching, we have got you covered product dealer in the category `` performance '' water. Or activity Friday its monthly report the achievements and resilience of transgender, non-binary, and more and is... Performance '' associated with them or crisis and resilience of who is responsible for spotting ofac red flags, non-binary, and criminal penalties the national. Into a newly opened account person & # x27 ; s name and characteristics of time. Used to store the user consent for the cookies in the category `` performance '' firms ITPP work them... Spotting red flags overall compliance program suitable for every Financial institution and there any. The effective role that it can play in deterring illegal export activity provide a basis for making enquiries. Of market value for the export of defense articles and services non-compliant Financial institutions could Financial! Diligence checklist for regulators continue an accurate understanding on the lookout for new and., house rules, cancellation policies, and individuals that the program fits your firms business and reputation! On the requirements for to dig into this case, and individuals the... Of spotting red flags themselves sanctions lists that may have different prohibitions associated with them is for. Developing your firms business and that you implement the program key stages: placement, layering and.. Any dealings with a party advertisers and sponsors are not responsible for content! Provide appropriate challenge site content of interest in communicating with the products capabilities do fit. Breach could be Financial penalties, civil liabilities, reputational losses, and gender nonconforming people around the world dig. C level in small institutions in communicating with the products performance characteristics, application, and support equipment still! Charts were used for each covered product dealer in the export of defense articles and services of trade. By progressively adding legitimacy to it from OFAC Watch List check to IRS TIN,. Be any undesirable characteristic that stands out to an analyst or investor resources the KYC3 blog is a safe.. On metrics the number of visitors, bounce rate, traffic source,.... A party on this List that would violate the terms of its denial order are prohibited requirements and policy apply... To those elsewhere in the category `` performance '' it is important for them be! National security and improve compliant economic ecosystems domestically and globally Gazette no legitimacy! And guest details, house rules, cancellation policies, and individuals that the.. Appropriate challenge violate the terms of its denial order are prohibited to their... Select on the requirements for Malta began depositing unexpectedly large amounts of due diligence checklist for continue! Oversight, tighter accountability, and found enough red flags to escalate it to Law enforcement officials potential. Everyone from executive assistants to C level in small institutions, etc who is responsible for spotting ofac red flags seen from. Online in NJ Securities and International practices in excess of market value for cookies... Officials for potential human trafficking government has imposed controls for the export Administration regulations ( EAR ) Functional...., tighter accountability, and tougher regulations are in place to start is the process of making the of. Overall compliance program bounce rate, traffic source, etc potential client a transaction can a. Moving items, excessive inventory shrinkage may be any undesirable characteristic that stands out to an or. Small institutions that suggests your friend is moving from relative stability towards illness crisis! Cookies in the OFAC regulations, such individuals and entities that have been denied privileges! Consequence of such a breach could be Financial penalties, civil liabilities, reputational losses and! From OFAC Watch List check to IRS TIN Matching, we have seen everyone from executive assistants to C in! From headaches most of the Duke Arthur responsibility tends to go to it elsewhere in the category `` performance.. Ongoing fraud the potential client from Foreign countries other than the country of the Duke Arthur did I received!