THE GAZPROM FILES ROME IN THE SUMMER

Size: px
Start display at page:

Download "THE GAZPROM FILES ROME IN THE SUMMER"

Transcription

1 THE GAZPROM FILES ROME IN THE SUMMER In october 2003 Poland Monthly and Rzeczpospolita revealed secret offshore bank accounts linked to National Insurer PZU. But new files show a much deeper scandal that affects an entire decade of PZU Executives. Nr indeksu ISSN X ISSN X PRICE: PLN (incl. 7 percent VAT $5.95US / $7.95CANADA _ 3.95UK / C5.95 FACE TO FACE WITH GRZEGORZ WIECZERZAK

2 Art by Aleksander Rokicki PZU: WHERE THE MONEY WENT In october 2003 Poland Monthly and Rzeczpospolita revealed secret offshore bank accounts linked to National Insurers PZU and PZU ycie. But the investigation since has revealed that this was only the tip of the iceberg. The island is picturesque. Long, sandy beaches, fishing cottages and beautiful countryside gradually meld into bustling luxury shops and restaurants reminiscent of Monaco or Cannes. Sheltered by the coast of Normandy, the island boasts pleasant winds, seaside restaurants, and every summer the population of 60,000 leaps to 120,000 or more, as the vacation spot is deluged by the British, the French and just about every other nationality within or outside of the European Union. It is the rare northern paradise with a catch. It is also the base of operations for money launderers siphoning money out of major firms in Poland and Russia. When maverick French MP Arnaud Monteburg called the United Kingdom a money launderer s paradise, he may well have been thinking of the island of Jersey and more specifically, the town of St. Helier. If not, he probably would add the island to the list after reviewing documents, computer disks, taped phone conversations, bank transfers and accounting statements accumulated by Poland Monthly during its 18-month investigation of top players in Poland s largest insurance company, PZU. Managed by British national Alan Evans, the Warren Trustees Group, a loosely structured outfit of lawyers and accountants specializing in offshore deals, aided and facilitated what appear to be illegal offshore trust funds, accounts and transfers for PZU officials. These included not only the controversial and now infamous pair of PZU and PZU Życie presidents Władysław Jamroży and Grzegorz Wieczerzak, but other PZU executives as well, including former PZU President Krzysztof Jarmuszczak, former 22

3 PZU Vice President Krzysztof Baca, PZU board member Janusz W., and former PZU President Roman Fulneczek. Finally, the accounts did not stop there. Trust funds and bank cards were set up for a number of other persons, who were not only indicted in the PZU investigation, but whose dealings were also noted in a 1999 Deloitte&Touche audit, entitled Project Cobra. The tip of the iceberg... The actions of Evans, a director of the Warren Trustees, would be questionable simply because until Oct Poles could not legally set up individual private bank accounts in other countries unless they were currently residing there. Exceptions were made only with a special permit issued by the National Bank of Poland, and not once in the thousands of documents pertaining to the Warren Trustees is there any mention of such licenses. Moreover, Evans and others linked to Mr. X a man who cannot be listed by name, thanks to a long-running gag order against Poland Monthly that still awaits a decision by the Polish court of appeals ( The Third Man /Poland Monthly/Oct. 2003) created a pipeline of money out of PZU for PZU executives and for a number of other Polish nationals as well. Yet the controversy does not stop there. Documents and computer disks obtained by Poland Monthly reveal what appears to be evidence of tax evasion in the United States and insider trading on the Australian stock market not to mention still more secret accounts and private bank cards for Russian and Ukrainian nationals linked to Russia s Gazprom and Chimprom companies (see related story, The Gazprom Files, p. 28). Moreover, the amounts of money are hardly negligible. On one account alone, the Warren Trustees listed more than EUR 21m in bank movements for 2001 and this appears to be only the beginning. Finally, many transfers as well as payments from PZU went through the accounts of, and were facilitated at least in part by, British Liberal Democrat Robert Woodthorpe Browne Poland first The story of the Warren Trustees is filled with the sort of intrigue usually reserved for spy novels. Unmarked packages sent to hotels apparently contained secret credit cards and cash. Corrupt deals were hatched and rehatched. Players were double-crossed, phone conversations taped and some persons were apparently threatened or bullied into keeping quiet. Yet this story, which culminates with the Jamroży and Wieczerzak affair, actually played out over a full decade and appears to have begun in Poland during the reign of Jarmuszczak and then-vice president Krzysztof Baca in the post-communist photo by Wojciech Hajkiewicz The home of controversy... The first door into the secret offshore accounts came when documents were revealed detailing irregularities in the construction of the PZU tower. chaos of PZU. At that time the company was underfinanced and few in Poland would have predicted that only 10 years later the insurance company would post profits of close to PLN 1bn for the first half of Reinsurance was a necessity, but in spite of the company s still unpredictable future, the possibilities at PZU did not go unnoticed by at least some British reinsurance figures, who managed to work their way into the company through reinsurance and green-card programs. That said, it appears that by 1993 a relationship between the Trustees and Jarmuszczak and Baca was apparently firmly in place so much so that the Warren Trustees, through the direction of Evans, set up accounts for both men in the form of Global Financial Investment Holding Limited, one of many trust funds that would be based in Jersey or the Bahamas. It was a strange, if not inauspicious, beginning. Seemingly straight out of the freewheeling money-laundering schemes of the 1970s, Jarmuszczak and Baca both received Barclays Bank cards. Soon after Global would be layered into a series of trust funds a technique both effective and traditional in money laundering circles that would see Baca s trusts mutating from Global Financial Investment Holding Limited to European Risk Management Consultants Limited to European Risk Management Consultants (UK) limited. Jarmuszczak s trusts would mutate into Financial Engineering International Limited to Thameside Risk Management. Whether or not money laundering took place, the setup was strange and apparently a precedent: The Warren Trustees would use the same formula for PZU officials for a decade, including both Jamroży and Wieczerzak. And whether or not Jarmuszczak s and Baca s accounts were indeed funnels out for PZU cash, it appears that the Warren Trustees had clear doubts about what they were doing. According to notes taken from a meeting at Charles de Gaulle Airport in Paris France in 1993, Baca, as well as a man labeled RWB would agree on the eventual structure for both Poles. At this time as was the case until October 2002 (and technically even now) such offshore accounts were illegal for Poles, and it was clear that both Baca and Jarmuszczak preferred to keep the accounts secret for many reasons. There were notes taken showing that both were reviewing options for citizenship in Portugal and Eire (Ireland), but a note attached to the bottom of the document is perhaps the most revealing. It says the following: Note: Both KB and KJ have had senior positions in the communist and post communist periods with state insurance company. As a consequence they have attracted some suspicion and it is presumed that they will have benefited personally in some way during the communist era. Their future cross border commercial dealings and investments in Poland, especially relating to foreign currency, must be carefully planned and their visibility limited. Visibility may have been limited, but both Jarmuszczak and Baca do appear to have benefited personally from the get go. According to a schedule of financial reimbursement, dated 13/10/1993, $300,000 was disbursed to Global, $300,000 went 23

4 photo by Jacek Turczyk/PAP Out on bail... Former PZU President W adys aw Jamro y was released on bail in August. Like former PZU ycie President Grzegorz Wieczerzak, Jamro y had been jailed for years. to Financial Engineering, $199,776 went to European Risk Management Consultants Limited and another $100,000 went to the Warren Trustees. Yet the cash did not stop there. Jarmuszczak benefited from a US Dollar Company Barclays bank card (No XXXX) throughout the 1990s, picking up cash collections from a certain Tracy Brennan at Barclays' 147 Holborn address in December of 1998, according to correspondence sent by Alan Evans through yet another trust company, Allied&Provincial Limited. Such cash collections were sent to various Barclays banks, including those located in Jersey, as late as January 2001, and company minutes listing Warren Trustees George Alan Evans and Paul Jackson as present, noted that loans were granted to European Risk Management, Financial Engineering and Global Financial Investments that totaled more than $640,000 in A further $273, was loaned to Baca in the spring of the same year, with July 4, 2003 minutes listing the reason for the disbursement as allowing him to complete the purchase of shares in Bank Śląski, which was already listed on the Warsaw Stock Exchange. Meanwhile, according to a fax dated Jan. 23, 2002, Evans set up additional bank accounts for Baca s European Risk Management Consultants, including one in Barclays Wall Street branch in New York. When contacted by Poland Monthly neither Fulneczek nor Jarmuszczak would discuss anything about the accounts or anything else, saying that as a result of a brutal press campaign that was begun against us, we must inform you that we do not intend to have any correspondence or discussion [on the matter]. Both did threaten legal action, however, if any libelous articles appear in the press. In fact, the no-comment strategy reigned supreme. Baca did not respond to faxed questions. Evans did not return phone calls and Browne did not answer the phone or return inquiries through his political party, the Liberal Democrats. Meanwhile, only one day before this article went to print, Poland Monthly was informed of an apparent criminal investigation that could potentially have this correspondent severely punished for publishing The Third Man (Poland Monthly/October 2003), for reasons that remain unclear, but surely violate press freedom standards the world over. Passing on benefits But silence or no silence and regardless of the nature of the Ochota district prosecutor s investigation into the circumstances surrounding The Third Man the secret accounts hardly stopped when Jarmuszczak stepped down. According to Warren Trustees files, Evans soon set about establishing a secret trust fund for Jarmuszczak's successor, Roman Fulneczek, who took over PZU in Although there seems to have been some difficulty in finding a bank to issue a card for Fulneczek, on Sept. 8, 1995, Evans convinced Ian Bastable of National Westminster Bank in St. Helier, Jersey, to issue a business card (company reference No XXX) that could draw on Narai Limited, which was registered for Fulneczek himself. Again a middleman was present, with faxes sent to him in 1996 at the Vienna Plaza Hotel stating that Narai Limited already had DEM 3,546,774 and $403,851 on its accounts. The fax concurred with Narai Limited minutes, but moreover, documents seized and stamped by the French fiscal authorities from a residence in France included National Westminster Bank business card accounting statements addressed to Evans but with Fulneczek s company reference number that further detailed sundry expenditures, including stays at the Vienna Marriott and purchases in Vienna. Yet the chain of PZU secret accounts would continue after Fulneczek. By Fulneczek s abdication of the PZU throne in 1998, a certain PZU board member, Janusz W., had already been given power of attorney to represent Ultra Overseas Holdings Limited, a company registered in the Republic of Ireland, according to Warren Trustees files. The appointment is damning in itself. Janusz W., who could not be reached at presstime, is currently indicted for a multitude of sins allegedly committed while at PZU. Moreover, in the Deloitte&Touche Project Cobra audit, he and his brother Roman W., who also could not be reached at presstime, actually have the honor of having an entire section ded- 24

5 icated to their work with PZU Development and PZU Development President Wojciech D., who was also indicted (and who also has his own trust through the Warren Trustees, but also could not be reached at presstime.) And it would appear that the Deloitte&Touche report hit right on the money. According to Ultra Overseas documents, $723, was in the accounts as of June 23, 1998 only days before Janusz W. s appointment to the trust and oddity in itself as most trusts do not come complete with full bank accounts. In any case, the money went awfully fast. By April 14, 1999 the amount had diminished to $230, The scandal hits For years the trust funds and accounts were known only to a few individuals. Yet Fulneczek s retirement from PZU meant the end of dealings that were completely outside of the public eye. Allegations of mismanagement and missing money would hit the press with PZU President Władyslaw Jamroży, who was later indicted for purchasing property at a loss and acting against the interests of the company (and recently released on PLN 1m bail). Again, it is hard to disbelieve the allegations, as Jamroży who would not return calls to Poland Monthly appears to have convinced Evans and the Warren Trustees to set up yet another offshore account, The Portland Trust, for his own use. Detailed in Poland Monthly s article, The Third Man, Jamroży would later commission the construction of PZU s current headquarters in Warsaw, using Warren Trustees related companies to build the towers. Funds diverted through various companies some involved in the tower project had three or four mirror companies in Jersey, Vienna or the United States appear to have gradually made their way to Jamroży s account. Poland Monthly was able to verify that that the trust had been established as Portland Trustees Limited and registered in Jersey on Nov. 24, 1997, as well as Pinnacle Trustees, set up much earlier, yet also later linked to the former PZU president. More shocking, Jamroży s account listed a whopping total of $4,308, in January 2001 not to mention the relatively paltry sums of DEM 419, and EUR 1,001,535 on the same account. And whether or not money ever moved through the Pinnacle Trust, secret accounts and Barclays cards were set up The Wieczerzak saga Equally interesting was the evolution of the Fountain Trust, a trust fund set up for Grzegorz Wieczerzak. As detailed in Poland Monthly s October 2003 issue, Fountain was set up by the Warren Trustees through Jamroży s Portland Trust. At a press conference in May Wieczerzak confirmed the existence of Fountain (Poland Monthly/June 2004/No.28), but claimed it was inactive. Later, he confirmed that he did set up the account, but that either his signature was falsified or his account was misused without his knowledge. Whatever the case, the account was hardly inactive, although the first recorded monies sent to Wieczerzak actually were sent to Midland Bank s offshore department in St. Helier, to the account of A.R. Wieczerzak (Barclays account No. 8303XXXX) to the tune of $930,000 only weeks after Wieczerzak s appointment as president of PZU Życie. Like Jamroży, Wieczerzak was recently released on bail after being held for years on charges of acting against the interest of PZU Życie. In mid-august, the courts also ruled that he could not be prosecuted for income tax evasion, as there was apparphoto by Tomasz Gzell/PAP for Jamroży and former PZU board member Jacek B. through Linfield Consultants Limited and Ellenton Investments Limited. Jacek B., who was listed as sitting atop yet another Warren Trustees trust, Rednap Limited, was assigned cards through the help of Warren Trustees Karen Bradley and Evans. According to Trustees files, the card accounts were canceled and returned by September 2002, but Ellenton Barclays accounts were active indeed. Yet the fun does not stop there. A glance into the history of Ellenton reveals that both Wojciech D. (PZU Development) and Bolesław D. received Barclays cards through Ellenton Investments, with Wojciech D. being listed as one of the founders of the trust. While letters indicate that Wojciech s card (No XXXX) was cancelled by April 5, 2002 (ironically, not long before limited offshore accounts would become legal), there was also a note taken in June 2003, where it was resolved to pay Bolesław D. $14, for services rendered Sept. 27, Bolesław D. is later referenced as being active in insurance sales in Poland. Wojciech D. s PZU Development was yet another company under investigation for suspicious activities during the construction of the PZU tower. Wojciech D. was also arrested (although, like the others, still not convicted) when the authorities Free and controversial... Former PZU ycie President Grzegorz Wieczerzak contested the existence of some accounts and that money was ever sent to anyone in his family. moved in on Wieczerzak for alleged misdeeds. According to Warren Trustees files, as of Jan. 20, 1999, Ellenton investments listed $123, on its accounts. In fact, the web of accounts and funds is so extensive with regard to the PZU tower that it is surprising that some parties did not try to find other ways to invest their money. After all, one serious leak such as that of documents given to Poland Monthly in 2003 could eventually jeopardize the entire scheme. Moreover, the Rednap accounts are more than incriminating, with massive amounts of money bouncing from bank to bank and country to country. One transfer, referenced Rednap Limited hit Lloyds TSB in Jersey in April 2001 to the tune of $424, Still more money, $300,000, was transferred to an account, labeled Softwired Technology, at Raiffesien Bank Polska in Warsaw only four days later on April 6, 2001, which would seem to indicate that at least some money had made the journey full circle, out of Poland and back in again. That said, Jamroży has remained the centerpiece of the PZU investigation. Needless to say, with such monies in Jersey accounts, posting bail in August was simply not much of a problem. 25

6 photo by Preston Smith ently not enough evidence to convict either Wieczerzak or his wife. In a phone interview Wieczerzak pointed out that the account could not be his, as he had no idea who A.R. Wieczerzak could be (and that Poland Monthly should try to find that A.R. Wieczerzak ). When told that the initials stood for Anna Renata (later there are other names listed, including Anna Marie), he said that he knew no-one with that name, although he did admit that his wife s name is Anna when Poland Monthly obtained court records stating this fact. Additionally, money that was sent in the name of another family member also matched. Yet Wieczerzak did seem genuinely surprised to learn of other accounts, and the discrepancy with Anna s middle name creates even more questions. This becomes even more intriguing, as Wieczerzak s accounts were hardly inactive during his incarceration. Fountain Holdings (Barclays account No. 7258XXX) may have been the first in the stable of offshore trusts, but it was soon joined by Hestia and Stofield Developments, with GBP 287, hitting Hestia s books in April 2002, according to notes from a board meeting, chaired by none other than Evans. Small amounts left the trust, ostensibly to pay for a private school for Wieczerzak s children although he also challenged this point. Later GDP 276, was transferred to Stofield Developments. Yet, as if the private accounts needed a bit more mystery, a letter sent to a certain Tom Hart in August 2001 indicates that Stofield Developments Where it all began... St. Helier, Jersey is similar in style and feel to Monaco or Cannes. Shown above is National Westminster Bank, which also granted bank cards to the Warren Trustees. was at that time bidding on land at Aston Down, Gloucestershire land belonging to the British Ministry of Defense. It is unclear as to whether or not money from Wieczerzak was involved, but the tendency of the Warren Trustees to borrow indiscriminately from other accounts and the size of the bid (GBP 6m) are troubling indeed. What about the cops? Yet perhaps the most troubling aspect of the Warren Trustees money-laundering scam is not that it runs so deep other files showed secret accounts and transfers for a number of other Polish nationals (see related story, The Other Files p. 26) but that it has lasted so long and has not been hindered the slightest by revelations in the press. After Poland Monthly (and, we admit, more importantly) Rzeczpospolita, Poland s second-largest daily, revealed that offshore dealings existed in October 2003, statements were issued from the Polish prosecutor s office that seemed both serious and bizarre. According to a statement made to Rzeczpospolita by press spokesman Zbigniew Jaskólski, Polish authorities had contacted the Jersey attorney general s office, although Jaskólski stated at the time that the Polish prosecutor was not happy with the level of cooperation. Additionally, Polish Attorney General Karol Napierski stated that if monies were proven to be in Jersey, the authorities would set about retrieving them. What has happened since October 2003 remains a mystery, however. A spokesman for the Jersey attorney general s office was all but cryptic, saying that he would neither confirm, nor deny, that Polish authorities had been in contact with the Jersey office, adding only that it could have been the case that the Poles had not followed proper Jersey procedure, and thus no progress had been made. Gary Godel, director of enforcement for the Jersey Financial Services Commission, refused to comment on the specifics of the Warren Trustees allegations, although he did say that trust directors would be obligated to notify Jersey police if they were suspicious about the origins or nature of money passing through trust fund accounts (see related article). When pressed he also admitted that a situation where one director was orchestrating hundreds of companies around the world was not the norm and that high-profile corruption cases, such as Gazprom or PZU, should set off alarm bells for company directors. Moreover, intentionally overlooking suspicious dealings could mean jail time for such directors. At least on the surface the authorities seemed to be taking allegations or theoretical allegations seriously. Yet something appears to be amiss, if not in the UK then in Poland. A member of the UK s fraud squad told Poland Monthly that such allegations, if placed by the Polish authorities, would mean a full investigation. In the event of wrongdoing, British authorities would trace the money to the ends of the earth. But most shocking was an official statement by Nicholas Troy, acting head of the Financial Crimes Unit in Jersey. Troy sated that at the present time the States of Jersey Police has received no request from the Polish authorities for assistance in any inquiries they may have on this matter. This statement would seem to imply that if Polish authorities did indeed contact Jersey the cooperation did not last long or run very deep. Simply put, in spite of a supposed ongoing investigation into PZU, PZU Życie, the antics of Wieczerzak, Jamroży and a host of others, it is questionable as to whether Polish authorities tried to find the money at all, much less retrieve it. In fact, it appears that the only concrete reaction to the October 2003 headlines has come from the Polish courts in the form of a gag order and PLN 1m lawsuit upheld by a Warsaw court against both Poland Monthly and Rzeczpospolita. So why the long-running gag order? It could be simply the result of Poland s 26

7 creaky, slow-moving legal system. Even so, it would seem that the public deserves the right to see such documents for itself documents that include puzzling letters and faxes to Jamroży that likely affected negotiations during the PZU privatization process. In fact, the gag order and the release of indicted PZU executives is even more difficult to understand when the Deloitte&Touche report is taken into account. The Project Cobra report, published on Dec. 19, 2001 by Deloitte&Touche, details multiple misdeeds, with the construction of the PZU tower taking up a major section of the audit. Apparently, the Deloitte team, headed by Deloitte&Touche Partner Dereck Davey, had more access to the inner workings of PZU than anybody before or since yet the company has not participated as a witness or an expert witness in the case against the indicted PZU executives. Moreover, Davey, who is regarded by due diligence experts to be top-notch, also managed to list Warren Trustees companies and members as questionably active in the construction of the PZU tower. The report itself would seem to be enough for a prosecutor to go on although some questioned the resources available to the attorney general s office. When contacted by Poland Monthly, Deloitte&Touche confirmed they had published the report, although the company would not comment on cooperation with the prosecution. That said, other companys have also shown that they would be interested in working with the Polish prosecutor. Brian O Brien, a director with PricewaterhouseCoopers Investigations and Forensic Services noted that it was important to have the right resources to perform such an investigation, which was both complex and jurisdictional. This case ranks right up there with some of the more high-profile cases in Western Europe, and it must be addressed appropriately by the Polish legal system. The publicly reported comments to the prosecutor by the judge lead us to question whether the prosecutor has the resources available to manage the complexity of the case, so that the facts are finally presented in a court of law. O Brien also questioned whether appropriate resources were being committed to recover the assets that were allegedly misappropriated. Back to Jersey But could there be deeper, more sinister motives? Poland Monthly learned unofficially in August that the Jersey regulatory board for financial transactions was long ago made aware of allegations involving the Warren Trustees, yet apparently by press time no official move had been made to investigate Evans or the actions of other individuals involved with the scheme. Strange news as new money laundering legislation in the UK has become incredibly stringent. Moreover, under the law a broker, lawyer or person such as Evans or any of the trustees has the obligation to notify authorities if there is even the suspicion of wrongdoing, questions regarding the source of monies or doubts about a specific transaction. In short, not only did Evans and other trustees blatantly avoid reporting suspicious transactions at one point Evans and a Jersey lawyer, David Le Cornu, traded correspondence on Wieczerzak s criminal proceedings even though money continued to be paid out through Hestia but the regulatory commission failed to move on both stories published in the foreign press and accusations by the spouse of one person involved, who claimed in Jersey courts that actions taken during the construction of the PZU Tower amounted to fraud and money laundering. Some pointed out that the regulatory group was simply being cautious, but others, including a noted Jersey lawyer said he was stunned at the lack of action. The articles should have triggered the regulatory commission into action, he said. The entire island is talking about the case simply because it threatens the offshore industry in Jersey itself. I have no doubts that this is going to end Jersey as we know it, said the lawyer. The United States, in particular, has long been frustrated with money movements here, and many feel that Jersey is already on its last legs, thanks to concerns linked to money laundering and terrorism. This is so blatant, however, that the courts are going to have to deal with it. Considering the fact that Warren Trustees files also contain secret accounts for Turks, Americans, Poles and Russians, the problem may be more shocking that anyone ever expected especially as the Russian accounts lead to Russian giant Gazprom and Chimprom, both of which have been the subject of chronic scrutiny (see related story, The Other Files, p. 26) Smoke and mirrors Yet Jersey is always the coquette. Mystery and secrecy are the island s strong point, and as if to prove this it appears that some sort of investigation is actually under way. Although Jersey law prevents police from confirming current investigations, a BBC journalist confirmed that Jersey police had offered at least one person protection under a witness protection program. Another Jersey official said cryptically that the police are very interested in this. With regard to protection, it may indeed be necessary, as other sources recently in contact with Poland Monthly voiced fears of revenge or retribution from what was described as a web crossing borders and possibly even penetrating government intelligence agencies. Such talk might seem fanciful or fantastic, yet the Warren files which match previous documents obtained more than a year earlier by Poland Monthly, not to mention letters signed and received by Jersey legal offices do leave plenty of room for conspiracy. This case ranks right up there with some of the more high-profile cases in Western Europe. Brian O Brien, PricewaterhouseCoopers Poland What is on paper happens to implicate an entire line of PZU presidents, vice presidents and board members from 1993 until the arrival of PZU President Zbigniew Kostkiewicz, who was given the unenviable task of cleaning up something that seems much more organized than most could have imagined. That said, there is evidence to suggest that Kostkiewicz was only partially successful and considering the organization stacked against him, this comes as no surprise. And considering the secret letters, secret accounts, the political ramifications and the efforts to shut up the press there can be no other conclusion: The PZU/Warren Trustees conspiracy runs deep. The real question remains: Is there anyone in the Polish authorities with the integrity to do anything about it? Preston Smith, 27

8 The Gazprom Files The Warren Trustees had more on its ledger than just Polish accounts. Files linked to secret commissions show money being funneled out of Russian Gazprom. The PZU affair may seem huge, but then there is Gazprom. Files, documents and accounting records belonging to a Jersey offshore services company, the Warren Trustees Group, indicate that much more was afloat than just setting up accounts for former PZU and PZU Życie presidents Władysław Jamroży and Grzegorz Wieczerzak. Apart from setting up secret offshore accounts for a host of other PZU executives and apart from aiding in questionable money transfers out of the country money appears to have been siphoned out of both Gazprom and from Chimprom, one of Russia s largest 200 companies. More shocking, files and Barclays bank cards directly linked the Warren Trustees and British Liberal Democrat Robert Woodthorpe Browne with questionable bank transfers in the form of insider commissions paid to Vladimir Denga, the former director of Gazprom s insurance-oriented subsidiary, Sogaz. Just the link to Gazprom is enough to raise eyebrows. Called Russia s Enron although it is not going bankrupt anytime soon Gazprom hit the press in 2002 when it was revealed that PricewaterhouseCoopers had apparently overlooked millions of improper deals due to what has been kindly described as lax accounting methods. According to reports in Businessweek International, former Gazprom CEO Rem Vyakhirev had run the company as his own fiefdom up until This changed when Vyakhirev was ousted by Putin, replacing him with Alexei Miller, whose mandate was to clean up what had long been Russia s largest and most controversial company. And one of the first tasks Miller had to look into was a bizarre gas-for-tax barter deal in the Yamal-Nenetsk province worth at least $200m in taxes and potentially $5.5bn in pretax profit. The Denga transfers were questionable for a number of reasons, most importantly because Denga was dismissed by Sogaz s Board of Directors April 1, 2001, although Denga later claimed he resigned because of the changes in Gazprom management that came in Yet long before his resignation The Warren Trustees had set up the trust fund Rendale Limited as a Bahamas-based company (in September 1998). Company notes state that all correspondence should go via Robert Browne & Co in London. Also, connected companies included the shell trusts Bellerwick Limited, Kinsey Limited, Hervey Limited and Rexberg Holdings, and transfers designated for Denga were more than large. On Oct. 21, 1999 FF 300,000 was sent to Denga s Monte Carlo Account, with similar sums (up to $450,000) going to other accounts in Monaco, New York and Vienna at least until Equally interesting, Rendale sent RRI Risk Research International invoices for massive amounts of money based on profit commission due on reinsurance placements, reinsurance commissions on satellite risk cover in respect of launch of Yamal 1 & 2, and premiums due on reinsurance placements that were often more than $100,000 and sometimes more than $300,000. In short, it appears that Browne s company reinsured or gave reinsurance advice to the president of Sogaz, who then invoiced Browne for commissions from a company set up by the Trustees, whose correspondence all went through Browne s hands. This latter point becomes clear when company minutes are examined: Browne s company, RRI/ Risk Research International Limited, acted as an intermediary for Rendale Limited, both trusts apparently operating out of the same Union Street address as the hundreds of other companies managed by the Warren Trustees. (Although RRI s address was technically in London, Warren Trustee Alan Evans seemed to control billing to and from both companies.) Yet this seems to be only the beginning. Other companies, including Astra, Kinsey, Bellerwick, Hervey and Caltron all functioned in similar fashion, with Browne s RRI acting as the ultimate go-between for The Secret Hub of Jersey The Warren Trustees/PZU/Gazprom/Sogaz case is not the first scandal to rock Jersey. But the real question is: Just what are the authorities going to do about it? The PZU/Warren Trustees case is hardly the first time that the Channel Islands and more specifically, Jersey have hit the radar of the press and international authorities. In March 1999 the Russian Central Bank was accused of bypassing a law passed in April 1995 that would send half of the bank s profits to the government. Instead, it turned out that a whopping half of Russia s currency reserves had been invested offshore where the profits disappeared. So where did they go? According to a Washington Post Foreign Service investigation, Russia s reserves were turned over to a small, little-known money-management company by the name of Financial Management Co. Ltd., or Fimaco, which was set up in 1990 in Jersey. Although the chairman at the Central Bank at the time, Viktor Gerashchenko, claimed that Fimaco belonged to Paris-based Eurobank, it turned out that Fimaco actually belonged to Ogier Nominees Ltd. And Ogier Secretaries Ltd., two unknown offshore groups that had been kept secret by the Central Bank. It was, to be sure, a high-profile case. Yet in spite of this Jersey was not included on a list of uncooperative tax havens created by the OECD in April 2002, which included Andorra, Liberia, Liechtenstein, the Marshall Islands, Monaco, Nauru and Vanuatu. Yet this list seems to be somewhat incomplete, with international lawyers routinely complaining that tax havens basically still exist in Vienna and Switzerland. Moreover, Jersey may not have been named in the list, but an agreement orchestrated by US Treasury Secretary Paul O'Neill that called for more transparency and cooperation between US 28

9 PAP/EPA his doorstep in mid-august. Authorities stated that Bondarenko had opened the door only to be handcuffed and then shot dead at his apartment Aug. 11. Officials said they suspected that the assailant had wanted access to a computer program that would give access to Russian tax information. Poland Monthly was still not able to determine at press time, however, if the deceased Bondarenko was the same man involved in the Rendale transfers. Cleaning house... Russian President Vladimir Putin discusses the future of Gazprom with Gazprom President Rem Vyakhirev, who was later kicked out by Putin in all companies involved. Astra installments arranged on behalf of Sogaz Insurance company ran at more than $200,000 a pop for commissions sent to Astra by RRI (there were at least 11 installments), and it appears that the money was thus sent to trust fund holders, all of whom were Russian nationals, including Vladimir Bondarenko (Bellerwick) and Sergey Medvedev (Caltron Holdings Limited). So could the transfers have been legit? Perhaps, but the arrangements have all of the makings the layering of companies, shell-company arrangements, massive commissions, circular payments and vague invoices of classic money laundering. Finally as if the Russian transfers needed still more intrigue Russia s top tax official, a certain Vladimir Bondarenko was found murdered on A world without borders Meanwhile, the Russian accounts are not the end of suspicious money movements across borders. Files included Gameshi Holdings Limited, which aside from being registered at the same St. Helier s address as the hundreds of other shell companies formed by the Warren Trustees group, also highlights a relatively minor tax evasion scheme in the United States. Another file, labeled Danesfort, includes details linked to companies that appear to have been working to take over companies and illegally play the Australian stock exchange. Meanwhile, files related to the Warren Trustees and Browne detailed business interests ranging from Turkey to Zimbabwe to Curacao to the former Yugoslavia. Back to Poland... Admittedly, such accounts demand more investigation before conclusions can be drawn. Yet the Polish accounts, while less heart-stopping, also hold their own surprises especially those active during authorities and the Channel Islands was at least somewhat indicative of international concerns at that time. Even so, secrecy does seem to be Jersey s biggest selling point, and getting answers to simple questions is not easy. No comment or I can neither confirm or deny that an investigation is taking place, is the norm, and Jersey police are in fact limited by Jersey law so that they cannot make comments to the press with regard to an ongoing investigation. But to assume that Jersey officials have no interest in ongoing cases would be a mistake. Considering Jersey s GDP some estimates put this as high as GBP 2.2bn there is plenty of reasons to run a legitimate, honest shop that cannot be shut down by the bad apples in the batch. When contacted by Poland Monthly, Gary Grodel, director of enforcement for the Jersey Regulatory Commission, said, I can confirm that Warren Trustees is a regulated trust company business, and we take issues such as those raised in your publication seriously. You will appreciate that I cannot discuss any non-public information with you. Grodel did respond to theoretical situations, however, agreeing that a situation where a single director appears on a hundred-plus different trust funds or large amounts of money arriving from troubled and infamous companies such as PZU or Gazprom should set off warning bells among Jersey directors. There is always some discussion going on between us and the [Jersey police], he added. We have the proper gateways and if we see something going on, then we will get around [to a particular company to investigate it.] I think that if I had a client and I saw details in the press, and that information looked as if it should be taken seriously, I would hope that they reach for that file and if they don t make a report, then they are quite comfortable about that. When asked if a failure to contact Jersey police in such a situation could make a director or lawyer that was privy to such information culpable for a crime, Grodel answered that according to Jersey law the failure to report even a suspicious transaction could be punished by prison time. Grodel said that recent changes in the law had put the onus on bankers, lawyers and trust directors to try and stop money laundering, 29

10 the PZU crisis years that began with the regime of former PZU President Władysław Jamroży. Markaz LTD files indicated relatively sundry sums being disbursed to a certain Kazimierz Dembski, as well as to a Leszek Strawiński and Jan Chrostowski, all of whom also received Barclays cards (No XXX, No XXX and No XXX, respectively) on May 22, 2001 under the Hermes Consultants LTD company, also set up at the same Union Street address as almost every company mentioned in this month s Poland Monthly. Chrostowski also received power of attorney for yet another offshore trust, Haselden Investments Limited only one day earlier ostensibly to sign a loan agreement made between the company and Elmedia. Monies had previously been sent to Chrostowski s various private accounts in different Warsaw banks, but money was also sent to a certain Pierre Belin, who received FF 1,246,800 at an account listed as Tresor Public, Tresorie de Draguigan Cedex. The reference on the transfer was listed as Plots 37/38 Bal on 3 Plots Mr. J., which at first seems a bit mysterious. Strawiński had received successive $50,000 sums, sent from Hermes to a bank account in Switzerland, but Mr. J. appears to have been Marek J. and again the intrigue is considerable. In December 2001 Marek J. found himself fighting with the former employees of technology provider Formus, who had accused him of acting against the interest of the company and de facto leading it to bankruptcy. Interestingly enough, Formus happens to be the same company that, according to a Gazeta Wyborcza report, spawned Elmedia although it would seem that the company was instead born out of Hermes sister company Haselden Investments Limited, and at least partly funded by a $101,500 bank transfer sent from Haselden account No to Elmedia s Wielkopolski Bank Kredytowy account in May Even more interesting, in a telephone interview Chrostowski, he current director of WAN, a little known Warsaw developer that just landed a contract for Polkomtel s new headquarters, admitted to being a co-owner of Formus. That said, he denied any knowledge of Haselden or Elmedia, which seems strange as, according to various media reports, Elmedia owned 51 percent of Formus. So do the minor Polish accounts amount to money laundering? Not necessarily, although there mere existence could be a violation of Polish law. Moreover, the fact that almost everything organized by the Warren Trustees (including yet another account under the Elysium trust for a controversial Polish lawyer) is suspect, would seem to demand inspection by the authorities. That some of the above-mentioned accounts were at least indirectly, if not accidentally, linked to the Russian accounts and the PZU accounts also arouses suspicion. In a best-case scenario, the above-mentioned Polish accounts were all backed by special permission from the Polish authorities. Perhaps all transfers were based on services rendered, were taxed appropriately and were completely legit. Perhaps, the bizarre accounting and cross-borrowing by the Warren Trustees has wrongly cast doubt on otherwise squeaky-clean offshore banking. Perhaps, but still there seems to be little doubt that the Warren Trustees have, at the very least, a lot of explaining to do. Gazprom. Chimprom. Russian schemes and indicted Poles and hundreds of documents that indicate monies were also later transferred to Turkish accounts. And considering that leading anti-corruption experts claim that up to one-third of the world s money is traded illegally, a logical explanation for all of the above is something many of us would really like to hear. Preston Smith, which has become an even greater worry in the age of terrorism. We can t say that no money laundering has ever occurred in Jersey, he added. All kinds of institutions the world over have been involved in things they should not have been. You could say the same thing about London or New York. But having said that, once it s discovered, the question is: What happens next? Do these guys act responsibly? Responsible behavior, unfortunately, has not always been the norm in offshore banking. Traditionally, the hint of an investigation has prompted illegal brokers to begin shredding documents, but recent legislation has paid off. The Jersey commission and Jersey police recently broke up a Nigerian group and repatriated monies back to that country, according to a press release posted on its website. According to the commission, trust fund directors have an obligation to know your client, and ignoring a proper vetting process is a first, and potentially lawbreaking, mistake. 30 Which leads us back to the wondrous powers of the Warren Trustees and chief director Alan Evans. According to documents in Poland Monthly s possession, Evans managed the accounts of at least 700 different trust funds, with many funds changing names or having double or triple accounts at different addresses in Dublin, Trenton NJ, the Bahamas and other locations around the world. Considering the wide range of nationalities involved and the wide range of business links it is difficult to believe that the Warren Trustees Group took even basic steps to vet international clients. Moreover, some companies and persons appear to have been simultaneous experts in real estate acquisition, insurance, reinsurance, government permit acquisition, construction, Internet technology and project development not to mention in trust fund law and financial advisory services. Moreover, even a cursory glance at documents should have raised eyebrows. How Sogaz CEO Vladimir Denga could buy reinsurance from Robert Woodthorpe Browne s RRI group, yet receive commissions on the sale to a trust set up for Denga by Evans and apparently Browne is a mystery. Of course, receiving commissions on something you buy yourself is the oldest scam in the book (especially if it is using government money), but if Gazprom and PZU are the model for the Warren Trustees, it is probably worth having a look at other operations, including those in the former Yugoslavia and Turkey. So what is going on? Hopefully, some sort of investigation somewhere. Either Evans and partners are the ultimate business geniuses, or the Jersey commission is going to have quite a bit of work on its hands. Considering that this may not be the only scam of its type (top Romanian journalist Paul Radu also recently traced bizarre Gazprom transfers to Jersey, which appear to be unrelated but happened to go through Balkan contacts), it would probably be good to bet on the latter. Preston Smith,

11 SUBSCRIBE TO POLAND MONTHLY! BUSINESS Annual gold subscription package (250 PLN in Poland, EUR 150 in Europe, USD 170 outside Europe). Includes: 12 editions of Poland Monthly sent by post to your address, an invitation to all Poland Monthly events and conferences throughout Poland, discounts and special offers that are offered by businesses to Poland Monthly subscribers 6 month gold subscription package (175 PLN in Poland, EUR 90 in Europe, USD 110 outside Europe) Includes: 6 editions of Poland Monthly sent by post to your address, an invitation to all Poland Monthly events and conferences throughout Poland, discounts and special offers that are offered by businesses to Poland Monthly subscribers Annual silver subscription package (100 PLN in Poland, EUR 100 in Europe, USD 120 outside Europe). Includes 12 editions of Poland Monthly sent by post to your address 6 month silver subscription package (60 PLN in Poland, EUR 60 in Europe, USD 70 outside Europe). Includes 6 editions of Poland Monthly sent by post to your address Annual event subscription (200 PLN in Poland) Includes an invitation to all Poland Monthly events in Poland throughout the year SPECIAL OFFER! ORDER THE GOLD SUBSCRIPTION PACKAGE IN SEPTEMBER AND GET THIS GREAT GIFT FROM POLAND MONTHLY: THE 2005 EDITION OF THE GIRLS OF POLAND SWIMSUIT CALENDAR Client details/dane osoby zamawiajàcej: From issue / od numeru:... Mr/Pan Ms/Pani... Company/Firma... Address/Adres... Postal code/kod pocztowy... City/Miasto... Country/Kraj... Tel./Fax/ ... NIP (Poland only/tylko w Polsce)... Payment details/sposób p atnoêci: Bank transfer/przelew bankowy Cash/Gotówka Cheque enclosed/za àczony czek (payable to/wystawiony na: Poland Business Publishing Sp. z o.o.) Credit card/karta kredytowa nr.... Exp. date/wa na do:... VISA Eurocard Mastercard American Express Other/inna:... I authorize Poland Business Publishing to issue an invoice for this subscription without my signature. I hereby affirm the authenticity of the above data. On the basis of articles 23 and 24 of the Personal Data Protection Act of August 29, 1997 (Dziennik Ustaw Journal of Laws No. 133, item 833 with subsequent amendments) I consent to the processing of my personal data for statistical and marketing purposes at present and in the future. At the same time I consent for Poland Business Publishing Sp. z o.o., Millennium Plaza, Al. Jerozolimskie 123, Warsaw, Poland to use my personal data provided I am ensured the right to inspect the data in question and correct them. I confirm that I m over 18 years old, I use tobacco and alcohol products, and I agree to receive marketing materials from alcohol and tobacco companies through Poland Business Publishing Sp. z o.o. Check this box if you don t want to receive marketing materials from alcohol and tobacco companies through Poland Business Publishing Sp. z o.o. Upowa niam Poland Business Publishing do wystawienia faktury VAT na niniejszà prenumerat bez mojego podpisu. Potwierdzam autentycznoêç powy szych danych. Na podstawie art. 23 i 24 ustawy z 29 sierpnia 1997 r. o ochronie danych osobowych (Dz. U. nr 133, poz. 883 ze zmian.) dobrowolnie wyra am zgod na przetwarzanie moich danych obecnie i w przysz oêci dla celów statystycznych i marketingowych. JednoczeÊnie przyjmuj do wiadomoêci, e administratorem danych b dzie Poland Business Publishing Sp. z o.o., Millennium Plaza, Al. Jerozolimskie 123, Warszawa, który zobowiazany jest do zapewnienia prawa wglàdu do gromadzonych danych oraz ich poprawiania. OÊwiadczam, e mam ukoƒczone 18 lat, korzystam z wyrobów tytoniowych i alkoholowych oraz zgadzam si na otrzymywanie materia ów marketingowych od firm alkoholowych i tytoniowych za poêrednictwem Poland Business Publishing Sp. z o.o. Zaznacz, jeêli nie wyra asz zgody na otrzymywanie materia ów marketingowych od firm alkoholowych i tytoniowych za poêrednictwem Poland Business Publishing Sp. z o.o.... SIGNATURE/PODPIS PLEASE FAX OR POST THIS FORM TO/PROSIMY O PRZES ANIE NINIEJSZEGO FORMULARZA: POLAND BUSINESS PUBLISHING SP. Z O.O. MILLENNIUM PLAZA, AL. JEROZOLIMSKIE 123 (23RD FLOOR), WARSAW, POLAND, TEL. +48 (22) , FAX +48 (22) BRE Bank S.A, PLN Account no , US$ Account no EUR Account no Subscription Terms: 1. Your order will be filled within a week of the time your order is received and payment is made to Poland Business Publishing bank account. 2. The price is effective until December Please fill out the order form in BLOCK LETTERS and fax or mail it to Poland Monthly. 4. Information on prices and ordering is available Mon.-Fri. 9 a.m.-5 p.m. at tel. +48(22) Please notify us of any problems by telephone or in writing. Warunki prenumeraty: 1. Realizacja zamówienia nastàpi w terminie 7 dni od otrzymania zamówienia i wp yni cia zap aty na konto Poland Business Publishing. 2. Cena obowiàzuje do grudnia Prosimy o wyraêne wype nienie formularza DRUKOWANYMI LITERAMI i przes anie do redakcji Poland Monthly. 4. Aby uzyskaç informacje o cenach i sposobie zamówienia prenumeraty prosimy dzwoniç pod numer +48(22) w godzinach 9:00-17:00 od poniedzia ku do piàtku. 5. Jakiekolwiek reklamacje prosimy zg aszaç telefonicznie lub pisemnie na adres Wydawnictwa.

12 INTERVIEW Wieczerzak the Enigma On deadline, former PZU Życie President Grzegorz Wieczerzak agreed to meet Poland Monthly Editor Preston Smith to talk about the Warren Trustees and Jersey accounts. The interview was at times intriguing, mystifying and often more than just a little troubling. Smith: First, let me say that I appreciate you having the courage to meet with me and talk about this face-to-face. Most of the others linked to the PZU accounts have asked for us to send faxes or have avoided interviews altogether. Wieczerzak: It s [not a problem to meet]. Smith: Getting to the point, through a number of sources we obtained the accounting and bank transfer records for the Warren Trustees, an offshore company in Jersey that created trusts for a number of people in Poland, Turkey and Russia, not to mention yourself. When we met the first time I m sorry that I was rather rude you told me that Fountain Holding did belong to you, although it was not active. Wieczerzak: I wasn t the owner. I only had power of attorney. Smith: But you were listed as having the unlimited right to withdraw money. Wieczerzak: Yes. Smith: There were also other accounts, including Hestia and Stofield Developments, created in your name. That s what it looks like. Wieczerzak: I can only say I would be very interested in this for a very simple reason. I have to account for $930,000, which the bank is demanding of me, which my wife took from me. I would very much like to take these documents straight to the public prosecutor. Smith: That s intriguing. The bank transfers involved show money going to either Anna Wieczerzak sometimes the middle name or middle initial is different or large sums of money are sent from this account apparently to pay for your son s schooling. It appears that some money was moving around between Hestia and Stofield after you had been arrested. Not the first $930,000 that hit the Midland bank account only a little while after you took over at PZU ycie but the later transfers were sent to Anna Wieczerzak or to pay for school for you son or Wieczerzak: I pay for my children s photo by Preston Smith Cool and collected... Wieczerzak owned up to some facts, but also said he wanted to know more himself. school myself. Nine-thousand pounds is much too much money to pay for private school. Smith: Private school can cost that much or this could simply be something written to somehow justify transfers on paper. There are plenty of other transfers with very strange reasons attached to them. We know the money was sent and your family s names are involved. I m prepared to believe that you did not know about the later transfers because you were under arrest, but the $930,000 to Midland Bank did happen. Wieczerzak: I don t know what this is about. On my account it is true that in October or maybe in November 1998 this investment went through, but what I am looking at here does not correspond with my name. The prosecutor has all of this information, and I have even given the prosecutor power of attorney to try to get through this. Smith: This is money sent to a private person (to A.R. Wieczerzak), so this could be classified as an investment. That is what is strange about it. The other accounts also were foundations, but in the end they were in the names of individuals which was illegal in Poland. Wieczerzak: It is pretty much the right amount of money. The bank is the same. The time frame is not correct because the money should have been sent there sooner and the name is not right. Only the amount of money is correct, not the bank account number or the name. I would like to check it out myself because this money the $930,000 I never saw it again in my life. [Grinning] And I m sure I ll never see it. Smith: I still don t understand. PZU was supposed to pay you $930,000? Wieczerzak: That was money coming from the bank, from Societe-Generale, some of it for an investment and some to be awarded to me. Only it was sent to my private account some to be my earnings and some to be invested and you can check this with the tax office. I ve given them power of attorney to my accounts in Great Britain, so there is no problem for them to go there or to Societe and find out. I ve made it as easy for them as I can. But I can only say that a large part of that money should be returned to me by the banks, but my wife left and took the money from the account, although the account should read A.R. Wieczerzak, not G. Wieczerzak. The other things don t add up. The name of the bank is correct, although that is the old name because it is HSBC Smith: Are you separated from your wife? Wieczerzak: I m in the middle of a divorce. Smith: That is intriguing. When it comes to the Warren Trustees, the way they handled money is strange from the start to the finish. Wieczerzak: [No answer] Smith: Are you in contact with W adys aw Jamro y? Wieczerzak: No. Smith: His account at one time held about EUR 6m. There was also a lot of money on the other peoples accounts, which is why I have to be critical of anything you say. After all, you are all involved with PZU, and some have already confirmed that they had accounts in Jersey, which is in itself controversial as they were not legal for private persons. Wieczerzak: Please remember that I was not the owner of Fountain Holdings. Smith: Right. You had power of attorney, but Portland did belong to Mr. Jamro y, and in fact the trust is regis- 32

13 tered in Jersey. But okay. If we look at Hestia and Stofield this is just a small part of the documents you can see what was happening. Wieczerzak: I can only comment in the abstract because I was being held under arrest when these transfers were taking place. My wife did not have the legal right to take money out of my account except to pay for our children or to pay for school. Then she could have arranged these kind of payments if they were supposedly being used for school The sums of money are still very big and I paid from this account myself for their school fees, so like I said, I can only say this is something I can t really comment on, except in the abstract. Even in Britain that is a lot of money for school. Like I said, this has all been checked out by the tax office, and the account is G. Wieczerzak, not A.R. Wieczerzak, so I can t say any more about that. Smith: Fair enough. I guess the next question I would like to ask, however, is that you have said more than once that you are being framed. That you did not commit any crimes. The problem I have with that is that so many other people are involved we have found evidence to support almost point-by-point irregularities listed in the Deloitte&Touche audit... My point is that this would have to be an extremely well-organized conspiracy against you because it would mean that everyone else is guilty but you. How would you realistically explain this? If true, who would be behind it? Wieczerzak: I m not going to sit in jail for something I did not do. The affairs of Alan Evans and the Warren Trustees, that s one thing, but it never had anything to do with PZU Życie. Smith: I can t agree with you there because too many things are in Deloitte report. If you were right, this would have to be a huge conspiracy, which would be difficult for me to believe. And why would this be happening to you? What would be the logical reason for so many people to attack you, Grzegorz Wieczerzak? Wieczerzak: This is revenge for me blocking the privatization of PZU. For everything that happened in 2000 [ed. note he is referring to a series of controversial board votes that saw Deutsche Bank fail to take control of Big Bank Gdański]. This is a case of personal revenge from people backed by the president. Smith: KwaÊniewski? Wieczerzak: Yes. Smith: President Aleksander KwaÊniewski? Wieczerzak: Yes. Smith: [Stunned] All right. I have one last question. How did you get involved with the Warren Trustees? With Alan Evans for example? Wieczerzak: Through some of our clients when I worked at Societe Generale. At that time it was very popular for people to set up accounts in Britain. It was, among other things, a tax question for some of our clients. It was very popular for people in banking to set up such accounts for annual premiums in Jersey, where the money was sent. Smith: But such firms in Jersey, set up for individuals, were not legal. Wieczerzak: [Shrugs] Smith: Okay. But you can t tell me who approached you first on the matter? Wieczerzak: I don t remember exactly, but it would have been in 1996 or Smith: Do you know Robert Woodthorpe Browne? Wieczerzak: I know him. Smith: Maybe it was through him? Wieczerzak: It could have been. 33

Written Testimony of Sonia Ellis Submitted to the Special Committee on Aging United States Senate Hearing on the Jamaican Lottery Scam March 13, 2013

Written Testimony of Sonia Ellis Submitted to the Special Committee on Aging United States Senate Hearing on the Jamaican Lottery Scam March 13, 2013 Written Testimony of Sonia Ellis Submitted to the Special Committee on Aging United States Senate Hearing on the Jamaican Lottery Scam March 13, 2013 I would like to thank Chairman Nelson, Ranking member

More information

ARREST! What Happens Now?

ARREST! What Happens Now? Personal Injury Wrongful Death Slip & Fall Automobile Accidents Trucking Accidents Motorcycle Accidents Medical Malpractice Criminal Defense You re Under ARREST! What Happens Now? Do NOT Speak to Police

More information

STATEMENT BY SENATOR CARL LEVIN (D-MICH) BEFORE PERMANENT SUBCOMMITTEE ON INVESTIGATIONS FAILURE TO IDENTIFY COMPANY OWNERS IMPEDES LAW ENFORCEMENT

STATEMENT BY SENATOR CARL LEVIN (D-MICH) BEFORE PERMANENT SUBCOMMITTEE ON INVESTIGATIONS FAILURE TO IDENTIFY COMPANY OWNERS IMPEDES LAW ENFORCEMENT STATEMENT BY SENATOR CARL LEVIN (D-MICH) BEFORE PERMANENT SUBCOMMITTEE ON INVESTIGATIONS ON FAILURE TO IDENTIFY COMPANY OWNERS IMPEDES LAW ENFORCEMENT November 14, 2006 In 2004, the United States was home

More information

THE SEC OFFICE OF THE WHISTLEBLOWER 2014 ANNUAL REPORT: HELPFUL HINTS FROM THE SEC ON BECOMING A SUCESSFUL WHISTLEBLOWER BY DANIEL J.

THE SEC OFFICE OF THE WHISTLEBLOWER 2014 ANNUAL REPORT: HELPFUL HINTS FROM THE SEC ON BECOMING A SUCESSFUL WHISTLEBLOWER BY DANIEL J. THE SEC OFFICE OF THE WHISTLEBLOWER 2014 ANNUAL REPORT: HELPFUL HINTS FROM THE SEC ON BECOMING A SUCESSFUL WHISTLEBLOWER BY DANIEL J. HURSON The recent release of the SEC s Office of the Whistleblower

More information

THE GLOBAL SOLUTIONS GROUP INC.

THE GLOBAL SOLUTIONS GROUP INC. Page 1 of 7 A World of Opportunity THE GLOBAL SOLUTIONS GROUP INC. FOR SALE: Offshore Licensed Banks, Financial Companies and more from THE GLOBAL SOLUTIONS GROUP INC., International Group of the Attorneys

More information

first direct credit card terms

first direct credit card terms first direct credit card terms 1 Definitions These are the definitions used in this Agreement: : a transfer to the Account of an amount you owe to another lender (who is not a member of the HSBC Group)

More information

Worldwide Anti-Corruption Policy

Worldwide Anti-Corruption Policy Worldwide Anti-Corruption Policy I. PURPOSE The laws of most countries make the payment or offer of payment or even receipt of a bribe, kickback or other corrupt payment a crime, subjecting both Eaton

More information

Bank of Scotland Private Banking Savings Accounts

Bank of Scotland Private Banking Savings Accounts Bank of Scotland Private Banking Savings Accounts Terms and Conditions Applicable to: Premier Investment Account Premier Reserve Account (for Personal Customers) Premier Reserve Account (for Trusts) 3

More information

Networked Knowledge Media Report Networked Knowledge Prosecution Reports

Networked Knowledge Media Report Networked Knowledge Prosecution Reports Networked Knowledge Media Report Networked Knowledge Prosecution Reports This page set up by Dr Robert N Moles [Underlining where it occurs is for editorial emphasis] Anthony Graves is appointed to the

More information

The proposed legislation would end the all too frequent use of loopholes in State incorporation laws to hide money.

The proposed legislation would end the all too frequent use of loopholes in State incorporation laws to hide money. Testimony of Jack A. Blum, Esq. before The United States Senate Committee on Homeland Security and Governmental Affairs on S.569, the Incorporation Transparency and Law Enforcement Assistance Act November

More information

ROGERS JOSEPH O'DONNELL

ROGERS JOSEPH O'DONNELL 415.956.2828 (t) Robert Dollar Building 415.956.6457 (f) 311 California Street, 10th Flr. San Francisco CA 94104 ROGERS JOSEPH O'DONNELL 202.777.8950 (t) Victor Building 202.347.8429 (f) 750 9th Street,

More information

HALIFAX CASH ISA. Conditions and information

HALIFAX CASH ISA. Conditions and information HALIFAX CASH ISA. Conditions and information Welcome to Halifax 3 Section 1 How these conditions work 5 Section 2 Special Conditions 7 ISA Saver Variable 12 ISA Saver Online 13 ISA Saver Fixed 14 Junior

More information

MONEY LAUNDERING INDICATORS. 1. Financial professionals must pay especially close attention to the following indicators

MONEY LAUNDERING INDICATORS. 1. Financial professionals must pay especially close attention to the following indicators Belgian Financial Intelligence Processing Unit Gulden Vlieslaan 55/ 1 1060 Brussels - Belgium Tel. : +32 2 533 72 11 Fax : +32 2 533 72 00 E-mail : info@ctif-cfi.be MONEY LAUNDERING INDICATORS NL1175F-EN

More information

Testimony Of Ms. Anne Wallace. On behalf of. The Identity Theft Assistance Corporation. Identity Theft: A Victims Bill of Rights

Testimony Of Ms. Anne Wallace. On behalf of. The Identity Theft Assistance Corporation. Identity Theft: A Victims Bill of Rights Testimony Of Ms. Anne Wallace On behalf of The Identity Theft Assistance Corporation Identity Theft: A Victims Bill of Rights Information Policy, Census, and National Archives Subcommittee Oversight and

More information

Asset Tracing. PC.DEL/790/12/Rev.1 4 September 2012. Seminar Identifying, Restraining and Recovering Stolen Assets in the OSCE Region Session IV

Asset Tracing. PC.DEL/790/12/Rev.1 4 September 2012. Seminar Identifying, Restraining and Recovering Stolen Assets in the OSCE Region Session IV Seminar Identifying, Restraining and Recovering Stolen Assets in the OSCE Region Session IV Jean-Bernard Schmid State Prosecutor, Geneva PC.DEL/790/12/Rev.1 4 September 2012 ENGLISH only Asset Tracing

More information

Savings account conditions and information.

Savings account conditions and information. Savings account conditions and information. Welcome to Cheltenham & Gloucester. Thank you for choosing a C&G savings account. This booklet contains the conditions that apply to your personal savings account.

More information

Dr. Nicholas Ryder Professor in Financial Crime Department of Law

Dr. Nicholas Ryder Professor in Financial Crime Department of Law Money laundering and the United Kingdom: a haven for dirty money and an endless cycle? A critical reflection on the United Kingdom s anti-money laundering policies Dr. Nicholas Ryder Professor in Financial

More information

United States Attorney Southern District of New York

United States Attorney Southern District of New York United States Attorney Southern District of New York FOR IMMEDIATE RELEASE MAY 27, 2010 CONTACT: U.S. ATTORNEY'S OFFICE YUSILL SCRIBNER, JANICE OH PUBLIC INFORMATION OFFICE (212) 637-2600 NEW YORK COUNTY

More information

REPORT OF FLORIDA PROSECUTING ATTORNEYS ASSOCIATION. Re: The Office of Statewide Prosecution DECEMBER 2001 I. BACKGROUND

REPORT OF FLORIDA PROSECUTING ATTORNEYS ASSOCIATION. Re: The Office of Statewide Prosecution DECEMBER 2001 I. BACKGROUND REPORT OF FLORIDA PROSECUTING ATTORNEYS ASSOCIATION Re: The Office of Statewide Prosecution DECEMBER 2001 I. BACKGROUND The Office of Statewide Prosecution (OSWP) was created by Constitutional Amendment

More information

GUARDIANSHIP OF ADULTS

GUARDIANSHIP OF ADULTS Taylor Cochr ane Making Service A Matter of Practice Since 1835 GUARDIANSHIP OF ADULTS The material in this booklet is a compilation of in house materials developed by Taylor MacLellan and three brochures

More information

DOLCEFINO CONSULTING

DOLCEFINO CONSULTING DOLCEFINO CONSULTING The Harris County District Attorney s Office is committed to provide or arrange for services to meet the material, emotional, and information needs experienced by victims and witnesses,

More information

Excess Professional Indemnity. Policy document

Excess Professional Indemnity. Policy document Excess Professional Indemnity Policy document Contents A warm welcome to Zurich 3 Your Excess Professional Indemnity policy 3 Section 1 Definitions 5 Section 2 The Cover 5 Section 3 Provisions 6 Section

More information

Excess Professional Indemnity policy

Excess Professional Indemnity policy Excess Professional Indemnity policy Contents A warm welcome to Vela Underwriting 3 Making yourself heard 4 Your Excess Professional Indemnity Insurance Policy 5 Section 1 Definitions 8 Section 2 The Cover

More information

YOUR BANKING RELATIONSHIP WITH US. Personal Banking terms and conditions

YOUR BANKING RELATIONSHIP WITH US. Personal Banking terms and conditions YOUR BANKING RELATIONSHIP WITH US Personal Banking terms and conditions July 2015 Changes to your Bank Account or Savings Account Conditions We are making some changes to the conditions that apply to our

More information

CONSULTATION PAPER NO 2. 2004

CONSULTATION PAPER NO 2. 2004 CONSULTATION PAPER NO 2. 2004 REGULATION OF GENERAL INSURANCE MEDIATION BUSINESS This consultation paper explains the need for the Island to regulate general insurance mediation business and examines the

More information

When you need someone to scrutinize your financial situation, call Kessler International we'll turn your questions into answers.

When you need someone to scrutinize your financial situation, call Kessler International we'll turn your questions into answers. It's no secret that today's highly-volatile business environment demands a high level of financial scrutiny multinational corporations have been brought down by instances of financial fraud, often perpetrated

More information

Sample Credit Card Agreement

Sample Credit Card Agreement Credit Cards Sample Credit Card Agreement Please note this is a sample credit card agreement. It does not contain a credit limit, any interest rates, an APR or the Total Amount Payable as this information

More information

Developed by. Emma Oettinger, Anti-Money Laundering Policy Officer Law Society of England & Wales

Developed by. Emma Oettinger, Anti-Money Laundering Policy Officer Law Society of England & Wales A TEACHING EXERCISE FOR LAW SCHOOLS, POST-GRADUATE PROFESSIONAL EDUCATION PROGRAMS AND CONTINUING PROFESSIONAL DEVELOPMENT FOR LAWYERS ON ANTI-MONEY LAUNDERING OBLIGATIONS, LEGAL ETHICS AND PROFESSIONAL

More information

TERMS & CONDITIONS OF BUSINESS

TERMS & CONDITIONS OF BUSINESS TERMS & CONDITIONS OF BUSINESS 1. Introduction These terms and conditions explain the basis upon which we carry out work for you and charge for our services subject to any variations set out in our engagement

More information

ELECTRONIC FUNDS TRANSFER AND DISCLOSURE

ELECTRONIC FUNDS TRANSFER AND DISCLOSURE 135 Raritan Center Parkway Ph: 732.225.1505 Fax: 732.225.4572 www.pinnaclefcu.com ELECTRONIC FUNDS TRANSFER AND DISCLOSURE This Electronic Funds Transfer Agreement is the contract which covers your and

More information

Platform Specialty Products Corporation Foreign Corrupt Practices Act/Anti-Corruption Policy

Platform Specialty Products Corporation Foreign Corrupt Practices Act/Anti-Corruption Policy 1. Introduction. Platform Specialty Products Corporation Foreign Corrupt Practices Act/Anti-Corruption Policy 1.1 Combating Corruption. Platform Specialty Products Corporation, including its subsidiaries,

More information

Understanding Fraud From All Sides

Understanding Fraud From All Sides Understanding Fraud From All Sides Co Authored by the RCMP, FINTRAC, and the ICABC The following RCMP case file was written by Inspector George Pemberton of the Vancouver RCMPʹs Integrated Proceeds of

More information

ROLES TO ASSIGN. 1. Judge. 2. Courtroom Deputy. 3. Prosecutor 1 opening statement. 4. Prosecutor 2 direct of Dana Capro

ROLES TO ASSIGN. 1. Judge. 2. Courtroom Deputy. 3. Prosecutor 1 opening statement. 4. Prosecutor 2 direct of Dana Capro ROLES TO ASSIGN 1. Judge 2. Courtroom Deputy 3. Prosecutor 1 opening statement 4. Prosecutor 2 direct of Dana Capro 5. Prosecutor 3 direct of Jamie Medina 6. Prosecutor 4 cross of Pat Morton 7. Prosecutor

More information

DUI FAQ Guide. FAQs to Help Guide You Through The Florida DUI Process

DUI FAQ Guide. FAQs to Help Guide You Through The Florida DUI Process DUI FAQ Guide FAQs to Help Guide You Through The Florida DUI Process Randy Berman, Esq. Law Offices of Randy Berman (561) 537-3877 RandyBermanLaw.com A Simple guide for someone recently arrested for a

More information

Washington, D.C. June 24, 2015. for the opportunity to testify today. I would like to share with you the perspective of state

Washington, D.C. June 24, 2015. for the opportunity to testify today. I would like to share with you the perspective of state Written Testimony of New York County District Attorney Cyrus R. Vance, Jr. Before the U.S. House of Representatives Task Force to Investigate Terrorism Finance Washington, D.C. June 24, 2015 Good morning

More information

INDIVIDUAL CLIENT AGREEMENT AGILITY FOREX LTD INDIVIDUAL CLIENT AGREEMENT

INDIVIDUAL CLIENT AGREEMENT AGILITY FOREX LTD INDIVIDUAL CLIENT AGREEMENT INDIVIDUAL CLIENT AGREEMENT INDIVIDUAL CLIENT AGREEMENT The following terms and conditions apply to individuals who are transacting: for their own account, as a sole proprietor of a business, as a trustee

More information

Technical Advisory. TA 242 September 30, 2004. Subject: Agency Financials The Importance of Staying in Trust

Technical Advisory. TA 242 September 30, 2004. Subject: Agency Financials The Importance of Staying in Trust INDEPENDENT INSURANCE AGENTS & BROKERS OF LOUISIANA 9818 BLUEBONNET BOULEVARD BATON ROUGE, LA 70810 PHONE: 225/819-8007 FAX: 225/819-8027 www.iiabl.com Technical Advisory TA 242 September 30, 2004 Subject:

More information

Testimony of Michelle Easton President, Clare Boothe Luce Policy Institute 112 Elden Street, Suite P Herndon, VA 20170 (703) 318-0720; info@cblpi.

Testimony of Michelle Easton President, Clare Boothe Luce Policy Institute 112 Elden Street, Suite P Herndon, VA 20170 (703) 318-0720; info@cblpi. House Committee on Ways and Means Subcommittee on Oversight Oversight Hearing on IRS Audit Selection Process and Internal Controls within the Tax Exempt and Government Entities Division July 23, 2015,

More information

We are not an insurer.

We are not an insurer. HSBC Insurance Brokers (Philippines), Inc. General Terms of Business for Clients (Appointment) This Terms of Business (Appointment) set out the nature and scope of the services provided by HSBC Insurance

More information

Foreign Currency Account & Foreign Currency Term Deposit Terms and Conditions Effective 1 April 2015

Foreign Currency Account & Foreign Currency Term Deposit Terms and Conditions Effective 1 April 2015 Foreign Currency Account & Foreign Currency Term Deposit Terms and Conditions Effective 1 April 2015 What you need to know about these terms and conditions This booklet sets out the terms and conditions

More information

UNITED STATES DISTRICT COURT DISTRICT OF MAINE. UNITED STATES OF AMERICA ) ) v. ) Criminal No. 07-29-P-S ) HALVOR CARL, ) ) Defendant )

UNITED STATES DISTRICT COURT DISTRICT OF MAINE. UNITED STATES OF AMERICA ) ) v. ) Criminal No. 07-29-P-S ) HALVOR CARL, ) ) Defendant ) UNITED STATES DISTRICT COURT DISTRICT OF MAINE UNITED STATES OF AMERICA ) ) v. ) Criminal No. 07-29-P-S ) HALVOR CARL, ) ) Defendant ) RECOMMENDED DECISION ON MOTION TO SUPPRESS Halvor Carl, charged with

More information

Sending money abroad. Plain text guide

Sending money abroad. Plain text guide Sending money abroad Plain text guide Contents Introduction 2 Ways to make international payments 3 Commonly asked questions 5 What is the cost to me of sending money abroad? 5 What is the cost to the

More information

CLIENT IDENTIFICATION AND VERIFICATION RULES

CLIENT IDENTIFICATION AND VERIFICATION RULES CLIENT IDENTIFICATION AND VERIFICATION RULES INTRODUCTION The Rules require lawyers to follow certain client identification and verification procedures when retained by a client. The Rules also require

More information

Please retain for your reference Terms and Conditions for the Royal Mail Consumer Redirection Service and Special Circumstances Redirection Service

Please retain for your reference Terms and Conditions for the Royal Mail Consumer Redirection Service and Special Circumstances Redirection Service Please retain for your reference Terms and Conditions for the Royal Mail Consumer Redirection Service and Special Circumstances Redirection Service IMPORTANT These Terms and Conditions, together with the

More information

UNDERSTANDING MONEY LAUNDERING

UNDERSTANDING MONEY LAUNDERING UNDERSTANDING MONEY LAUNDERING Preface In light of the international concerns growing on money laundering and the financing of terrorist activities, many countries have taken rigorous measures to curb

More information

Excess Professional Indemnity Insurance

Excess Professional Indemnity Insurance Excess Professional Indemnity Insurance Contents A warm welcome to Vela Underwriting 3 Making yourself heard 4 Excess Professional Indemnity Insurance Policy 5 Section 1 Definitions 8 Section 2 The Cover

More information

White Collar Criminal Defense, Internal Investigations & Corporate Compliance

White Collar Criminal Defense, Internal Investigations & Corporate Compliance Butzel Long :: Practice :: Practice Teams :: White Collar Criminal Defense, Internal Investigations & Corporate Compliance Team Contacts David F. DuMouchel Related Lawyers George B. Donnini Damien DuMouchel

More information

1. I have something called a Chapter 13 plan. What is that exactly?

1. I have something called a Chapter 13 plan. What is that exactly? 1. I have something called a Chapter 13 plan. What is that exactly? The Bankruptcy Code requires that every Chapter 13 bankruptcy have a plan. It is a summary sent to your creditors that, in effect, tells

More information

7. MY RIGHTS IN DEALING WITH CRIMINAL LAW AND THE GARDAÍ

7. MY RIGHTS IN DEALING WITH CRIMINAL LAW AND THE GARDAÍ 7. MY RIGHTS IN DEALING WITH CRIMINAL LAW AND THE GARDAÍ 7.1 Victim of a crime What are my rights if I have been the victim of a crime? As a victim of crime, you have the right to report that crime to

More information

Zurich Accidental Death Cover. Terms and conditions

Zurich Accidental Death Cover. Terms and conditions Zurich Accidental Death Cover Terms and conditions Contents Terms and conditions Introduction 3 Roles and responsibilities 4 Zurich s roles and responsibilities 4 Your roles and responsibilities 4 Your

More information

Thompson Jenner LLP Last revised April 2013 Standard Terms of Business

Thompson Jenner LLP Last revised April 2013 Standard Terms of Business The following standard terms of business apply to all engagements accepted by Thompson Jenner LLP. All work carried out is subject to these terms except where changes are expressly agreed in writing. 1

More information

Barclaycard Business Credit Card Terms and Conditions

Barclaycard Business Credit Card Terms and Conditions Barclaycard Business Credit Card Terms and Conditions 1 Contents 1. Introduction 3 Your card 3 Business credit limit 3 Monthly payment 4 2. Your interest charges 4 Interest rates 4 Promotional balance

More information

This booklet sets out Our Terms of Business in conjunction with the Debt Management Agreement that You have signed.

This booklet sets out Our Terms of Business in conjunction with the Debt Management Agreement that You have signed. Terms of Business INTRODUCTION This booklet should be read in conjunction with Your Debt Management Agreement. The information in this booklet may help You understand the service that We will provide

More information

UNITED STATES DISTRICT COURT DISTRICT OF OREGON Portland Division. V. CRYSTAL COX, Pro Se Defendant

UNITED STATES DISTRICT COURT DISTRICT OF OREGON Portland Division. V. CRYSTAL COX, Pro Se Defendant Crystal L. Cox Attorney Pro Se UNITED STATES DISTRICT COURT DISTRICT OF OREGON Portland Division OBSIDIAN FINANCE GROUP, LLC and KEVIN D. PADRICK, Plaintiffs, V. CRYSTAL COX, Pro Se Defendant Objection

More information

If You have Been Arrested Don t Do Anything Until You Read My Special Report!

If You have Been Arrested Don t Do Anything Until You Read My Special Report! If You have Been Arrested Don t Do Anything Until You Read My Special Report! If you have been arrested by the police for a criminal offense, you re probably confused or worried about what steps to take

More information

WHAT YOU SHOULD KNOW ABOUT YOUR CHAPTER 13

WHAT YOU SHOULD KNOW ABOUT YOUR CHAPTER 13 WHAT YOU SHOULD KNOW ABOUT YOUR CHAPTER 13 YOUR TRUSTEE S NAME, ADDRESS, AND TELEPHONE NUMBER: Nancy J. Whaley Standing Chapter 13 Trustee 303 Peachtree Center Avenue SunTrust Plaza Garden Offices, Suite

More information

Leathes Prior Solicitors Terms of Business

Leathes Prior Solicitors Terms of Business Leathes Prior Solicitors Terms of Business 1. Contacting us Our reception is open from 8.30am to 5.30pm Monday to Friday, excluding Bank Holidays. Arrangements can be made to see clients outside these

More information

Cyber Crime. E-commerce, e-learning but e-terrorism?

Cyber Crime. E-commerce, e-learning but e-terrorism? E-commerce, e-learning but e-terrorism? What with media scaremongering, crusading politicians and global paranoia concerning the capabilities of Osama bin Laden and his al Quaeda network, it is hardly

More information

365 Phone, Online and Mobile Banking Terms and Conditions - Republic of Ireland Effective from 25 th November 2013

365 Phone, Online and Mobile Banking Terms and Conditions - Republic of Ireland Effective from 25 th November 2013 365 Phone, Online and Mobile Banking Terms and Conditions - Republic of Ireland Effective from 25 th November 2013 1.0 Definitions of Terms used in this Document 2.0 Accounts 3.0 Mandates 4.0 SEPA Transfers

More information

David Crum, Esq. Managing Partner New Mexico Legal Group, P.C.

David Crum, Esq. Managing Partner New Mexico Legal Group, P.C. David Crum, Esq. Managing Partner New Mexico Legal Group, P.C. ABOUT THE AUTHOR David Crum, Esq. David Crum is the Managing Partner of New Mexico Legal Group, P.C., an Albuquerque-based criminal defense

More information

Business Internet Banking Application Form

Business Internet Banking Application Form Business Internet Banking Application Form Free online banking for your business Welcome to Business Internet Banking. Please read the guidance notes before you complete each section. To use the service

More information

STATEMENT STUART F. DELERY ASSISTANT ATTORNEY GENERAL CIVIL DIVISION

STATEMENT STUART F. DELERY ASSISTANT ATTORNEY GENERAL CIVIL DIVISION STATEMENT OF STUART F. DELERY ASSISTANT ATTORNEY GENERAL CIVIL DIVISION BEFORE THE SUBCOMMITTEE ON REGULATORY REFORM, COMMERCIAL AND ANTITRUST LAW COMMITTEE ON JUDICIARY U.S. HOUSE OF REPRESENTATIVES FOR

More information

Sample Credit Card Agreement

Sample Credit Card Agreement Sample Credit Card Agreement Please note this is a sample credit card agreement. It does not contain a credit limit, any interest rates, an APR or the Total Amount Payable as this information can vary

More information

How to open a bank account for International students. www.northumbria.ac.uk

How to open a bank account for International students. www.northumbria.ac.uk How to open a bank account for International students Which bank? We cannot recommend one bank in particular so please check out a few banks before making a decision. HSBC, Barclays, Halifax, Lloyds, TSB,

More information

(Unofficial translation by the Financial and Capital Market Commission)

(Unofficial translation by the Financial and Capital Market Commission) (Unofficial translation by the Financial and Capital Market Commission) Text consolidated with amending laws of 12 December 2008; 01 December 2009; 10 December 2009. If a whole or part of a section has

More information

Current Account Conditions and AccounT Information.

Current Account Conditions and AccounT Information. Current Account Conditions and AccounT Information. If you open an account with us it will be with Yorkshire Building Society (trading as Norwich & Peterborough Building Society, Norwich & Peterborough

More information

GUARDIANSHIP LAW IN NORTH CAROLINA for General Guardians - Guardians of the Person-Guardians of the Estate

GUARDIANSHIP LAW IN NORTH CAROLINA for General Guardians - Guardians of the Person-Guardians of the Estate GUARDIANSHIP LAW IN NORTH CAROLINA for General Guardians - Guardians of the Person-Guardians of the Estate IMPORTANT The Clerk of Superior Court in all 100 counties in North Carolina serves as the judge

More information

Free initial consultation

Free initial consultation Bankruptcy Attorney & Lawyer Stoughton, MA Free initial consultation The have offered professional legal advice and representation for individuals throughout South Shore, MA and the surrounding areas for

More information

Supplier Anti-Corruption and Anti- Bribery Policy

Supplier Anti-Corruption and Anti- Bribery Policy Supplier Anti-Corruption and Anti- Bribery Policy 2014 Dwellworks Contents Purpose and Scope... 3 Core Principles... 4 Guidelines for Anti-Corruption and Anti-Bribery Compliance... 5 Applicable Definitions...

More information

CHECK ENFORCEMENT GUIDEBOOK. Maricopa County PROGRAM. Attorney s Office. Where to submit a bad check. Bill Montgomery. Page 1

CHECK ENFORCEMENT GUIDEBOOK. Maricopa County PROGRAM. Attorney s Office. Where to submit a bad check. Bill Montgomery. Page 1 Page 1 Maricopa County Attorney s Office Bill Montgomery Maricopa County Attorney CHECK ENFORCEMENT GUIDEBOOK CHECK ENFORCEMENT PROGRAM Accepting a check What to do with a bad check How to submit a check

More information

Presented By Greg Baldwin

Presented By Greg Baldwin ANTI-MONEY LAUNDERING COMPLIANCE OFFICER TRAINING Presented By Greg Baldwin THE ANTI-MONEY LAUNDERING COMPLIANCE OFFICER We re going to cover: Basis for the requirement to have a Compliance Officer The

More information

Ethics exam October 4102

Ethics exam October 4102 Ethics exam October 4102 1. A registered foreign lawyer in Israel represented a client in a matter involving foreign law. The client paid a portion of the lawyer's fee but refused to pay the remaining

More information

QUESTERRE ENERGY CORPORATION (the Corporation ) INSIDER TRADING AND REPORTING POLICY

QUESTERRE ENERGY CORPORATION (the Corporation ) INSIDER TRADING AND REPORTING POLICY QUESTERRE ENERGY CORPORATION (the Corporation ) INSIDER TRADING AND REPORTING POLICY The purpose of this insider policy is to summarize the insider trading restrictions to which directors, officers, consultants

More information

HOW DOES A CRIMINAL CASE GET DISMISSED WITHOUT A TRIAL? Many criminal cases are resolved without a trial. Some with straight forward dismissals.

HOW DOES A CRIMINAL CASE GET DISMISSED WITHOUT A TRIAL? Many criminal cases are resolved without a trial. Some with straight forward dismissals. HOW DOES A CRIMINAL CASE GET DISMISSED WITHOUT A TRIAL? Many criminal cases are resolved without a trial. Some with straight forward dismissals. In some cases the prosecution can be misinformed by the

More information

FALSIFYING CREDENTIALS: An Analysis

FALSIFYING CREDENTIALS: An Analysis FALSIFYING CREDENTIALS: An Analysis A member of the New York State Bar was convicted last week in New York State Supreme Court, in Manhattan, on a number of charges including Criminal Possession of a Forged

More information

San Diego Chapter THE REAL BURDEN OF PROOF AUDITORS UNCOVERING CRIMINAL ACTS OR DBPP V1.0

San Diego Chapter THE REAL BURDEN OF PROOF AUDITORS UNCOVERING CRIMINAL ACTS OR DBPP V1.0 San Diego Chapter AUDITORS UNCOVERING CRIMINAL ACTS THE REAL BURDEN OF PROOF OR DBPP V1.0 Who is This Guy? George R. Thomas, MBA, CIA, CGAP, CRMA Detective Sergeant San Diego Police Department Current

More information

Inquiry Report My Community UK. Registered Charity Number 1137137

Inquiry Report My Community UK. Registered Charity Number 1137137 Inquiry Report My Community UK Registered Charity Number 1137137 A statement of the results of an inquiry into My Community UK (registered charity number 1137137). Published on 30 June 2015. The charity

More information

Terms of Engagement. Page 1 of 6. Terms of Engagement

Terms of Engagement. Page 1 of 6. Terms of Engagement Terms of Engagement 3 Westfield House, Millfield Lane York YO26 6GA Phone 01904 793195 Fax 01904 782650 E mail jes@sachlaw.co.uk www.sachlaw.co.uk Regulated by the Solicitors Regulation Authority 402072

More information

CRIMINAL COURT IN MINNESOTA: Understanding the Process so You can Sleep at Night

CRIMINAL COURT IN MINNESOTA: Understanding the Process so You can Sleep at Night RYAN PACYGA CRIMINAL DEFENSE 333 South 7 th Street, Suite 2850 Minneapolis, MN 55402 612-339-5844 www.arrestedmn.com More information on the YouTube channel Ryan Pacyga CRIMINAL COURT IN MINNESOTA: Understanding

More information

Excess Directors and Officers Liability. Policy document

Excess Directors and Officers Liability. Policy document Excess Directors and Officers Liability Policy document Contents A warm welcome to Zurich 3 Your Excess Directors and Officers Liability policy 4 Section 1 Agreement with underlying policies 7 Section

More information

INSIDER TRADING. a. Charles Fogarty d. Texas Gulf Sulphur. b. Martha Stewart e. U.S. Security and Exchange Commission

INSIDER TRADING. a. Charles Fogarty d. Texas Gulf Sulphur. b. Martha Stewart e. U.S. Security and Exchange Commission Insider Trading 1 INSIDER TRADING PRE-READING QUESTIONS 1. What do you know about these people or organizations? a. Charles Fogarty d. Texas Gulf Sulphur b. Martha Stewart e. U.S. Security and Exchange

More information

The support you should get if you are a victim of crime

The support you should get if you are a victim of crime The support you should get if you are a victim of crime This is an EasyRead booklet showing you what to do. About this booklet The Ministry of Justice wrote this information. This is an EasyRead guide

More information

Act on Background Checks

Act on Background Checks NB: Unofficial translation Ministry of Justice, Finland Act on Background Checks (177/2002) Chapter 1 General provisions Section 1 Scope of application (1) This Act applies to background checks, which

More information

Bank Account Conditions.

Bank Account Conditions. Personal Banking Bank Account Conditions. Applicable from 30 July 2015. Bank Account Conditions. This booklet contains the general conditions that apply to our personal bank accounts and some related services.

More information

Advocates and Solicitors Examinations. Common Examinations. Civil Procedure and Criminal Procedure. June 2011

Advocates and Solicitors Examinations. Common Examinations. Civil Procedure and Criminal Procedure. June 2011 Advocates and Solicitors Examinations Common Examinations Civil Procedure and Criminal Procedure June 2011 Important notes 1. Read the questions carefully. 2. Hand in all papers. 3. Write legibly unreadable

More information

Financial services regulation in Jersey

Financial services regulation in Jersey www.bedellgroup.com Jersey Guernsey London Dublin Mauritius BVI Singapore Financial services regulation in Jersey Bedell Cristin Jersey briefing briefing Jersey's reputation as a leading international

More information

Foreign currency account

Foreign currency account Foreign currency account Terms and conditions Terms and conditions of the foreign currency account, (incorporating foreign currency current account and foreign currency deposit account) Please read and

More information

RISK MANAGEMENT AND COMPLIANCE: LOOKING AT THE BIG PICTURE HOW TO IDENTIFY AND MANAGE MONEY-LAUNDERING RISK

RISK MANAGEMENT AND COMPLIANCE: LOOKING AT THE BIG PICTURE HOW TO IDENTIFY AND MANAGE MONEY-LAUNDERING RISK RISK MANAGEMENT AND COMPLIANCE: LOOKING AT THE BIG PICTURE HOW TO IDENTIFY AND MANAGE MONEY-LAUNDERING RISK This presentation exposes money laundering from every perspective and will empower you to identify

More information

Office of Personnel Management. Policy Policy Number: Definitions. Communicate: To give a verbal or written report to an appropriate authority.

Office of Personnel Management. Policy Policy Number: Definitions. Communicate: To give a verbal or written report to an appropriate authority. Citation: Arkansas Code Annotated 21-1-601 through 608, 21-1-610; 21-1-123 and 124 Office of Personnel Management Policy 1 Forms: Fraud Reporting Complaint Form Definitions Adverse action: To discharge,

More information

YOUR BANKING RELATIONSHIP WITH US. Personal Banking terms and conditions

YOUR BANKING RELATIONSHIP WITH US. Personal Banking terms and conditions YOUR BANKING RELATIONSHIP WITH US Personal Banking terms and conditions April 2014 This booklet contains the general conditions that apply to our personal bank accounts and some related services. Please

More information

BANKING. Sector Specific AML/CFT Guidance Notes. May 2015

BANKING. Sector Specific AML/CFT Guidance Notes. May 2015 BANKING Sector Specific AML/CFT Guidance Notes May 2015 Whilst this publication has been prepared by the Financial Supervision Commission, it is not a legal document and should not be relied upon in respect

More information

A Self-Made Millionaire's Guide to Dealing with Debt

A Self-Made Millionaire's Guide to Dealing with Debt A Self-Made Millionaire's Guide to Dealing with Debt By Mark Ford, wealth coach I had my first serious run-in with debt when I was 30 years old. My wife K and I were renting a condominium in Washington,

More information

The Police Have Left Word That They Want to Speak With You

The Police Have Left Word That They Want to Speak With You The Police Have Left Word That They Want to Speak With You What Does it Mean and What Should You Do? Don A. Murray, Esq. Shalley & Murray 125-10 Queens Blvd., Suite 10 Kew Gardens, NY 11415 273 Sea Cliff

More information

Welcome to Modus Law, Ltd.

Welcome to Modus Law, Ltd. January 1, 2014 Via Email to Client Name Client Address Client Email Welcome to Modus Law, Ltd. Dear Client, First and foremost, we want to truly thank you for choosing us to be part of your Company. We

More information

Bacstel-IP. Customer Agreement for the Bacstel-IP Direct Service

Bacstel-IP. Customer Agreement for the Bacstel-IP Direct Service Bacstel-IP Customer Agreement for the Bacstel-IP Direct Service Customer Agreement for the Bacstel-IP Direct Service 1. INTRODUCTION This agreement relates to the provision of the Bacstel-IP Service (

More information

ELECTRONIC FUND TRANSFERS AGREEMENT AND DISCLOSURE

ELECTRONIC FUND TRANSFERS AGREEMENT AND DISCLOSURE ELECTRONIC FUND TRANSFERS AGREEMENT AND DISCLOSURE This Electronic Fund Transfers Agreement and Disclosure is the contract which covers your and our rights and responsibilities concerning the electronic

More information

Abington Bank 6 Harrison Avenue Abington, MA 02351 781 878 0045 TheAbingtonBank.com ELECTRONIC FUND TRANSFER AGREEMENT AND DISCLOSURE

Abington Bank 6 Harrison Avenue Abington, MA 02351 781 878 0045 TheAbingtonBank.com ELECTRONIC FUND TRANSFER AGREEMENT AND DISCLOSURE Abington Bank 781 878 0045 TheAbingtonBank.com ELECTRONIC FUND TRANSFER AGREEMENT AND DISCLOSURE For purposes of this disclosure and agreement the terms "we", "us" and "our" refer to Abington Bank. The

More information

NOTICE OF PRIVACY PRACTICES

NOTICE OF PRIVACY PRACTICES FRANKLIN SQUARE EYE CARE 918 HEMPSTEAD TPKE FRANKLIN SQUARE, NY 11010 TEL #: (516) 354-4242 FAX #: (516) 354-7788 E-mail: franklineyecare@gmail.com OFFICE CONTACT PERSON: SHERIN GEORGE O.D. NOTICE OF PRIVACY

More information

Glossary. To seize a person under authority of the law. Police officers can make arrests

Glossary. To seize a person under authority of the law. Police officers can make arrests Criminal Law Glossary Arrest Charge Convicted Court Crime/Offence Crown Attorney or Prosecutor Criminal Custody Guilty Illegal Innocent Lawyer To seize a person under authority of the law. Police officers

More information