Saturday, August 31, 2019

Race by the Numbers Essay

In his article, â€Å"Race by the Numbers†, Orlando Patterson argued about the misinterpretation of the census results and that this misinformation is having negative effects on the perspective of the people. The misinterpreted part of the census, according to Patterson, was the idea that the population of the Whites is becoming the minority in many areas of the country. Thus, Patterson offered arguments and ideas to disprove the validity of the interpretation. However, the question is whether or not Patterson was able to persuade the readers, the citizens, that the interpretation of the census report was indeed incorrect. Patterson’s article is full of information especially statistical and quantitative information that helped him in establishing ground for his arguments. Patterson statement that â€Å"48 percent of Hispanics classified themselves as solely white† (p. 83) adds to his persuasive argument that is also supported by the next sentence in the article, â€Å"Hispanics can be of any race† (p. 83). These statements clearly supported the fact that the total percentage of Whites in was decreased as interpreted by the census report. Patterson also included studies that affirm his claim including recent census result. Patterson stated that, â€Å"whites will constitute 74. 8 percent of the total population in 2050, and that non-Hispanics will still be 52. 8 percent of the total† (p. 83) as indicated by the recent census. With such facts indicated in the article, it can be said that Patterson was able to build a strong evidence and supporting detains and information regarding his assertions. Thus, his argument, regarding the population of white Americans in the country, is a â€Å"gross distortion† (Patterson p. 83) is not a mere point of view but is supported by facts and relevant information. By establishing the facts and the arguments, it can be said that Patterson’s main purpose of writing the article was to show that the population of whites in America is still and will continue to be the majority; disproving the assumption that â€Å"non-Hispanic whites will cease to be the majority† (Patterson, p. 82). By doing so, Patterson aims to encourage the whites that they still are the majority and will continue to be. In this case, Patterson was able to do great job through his article. However, Patterson also indicated in his article the idea that â€Å"each group in the new minority-majority country has longstanding grievances against whites†, thus, Patterson may also want to claim the invalidity of this assertion through his article. But in this case, was Patterson effective? Basing from the article, Patterson was really able to encourage the whites and take away the doubt that they will cease to be the majority. However, Patterson was not able to take away the idea that minority groups in America have grievances on whites. On the contrary, it even points out another idea, that whites does not see minority groups as to be equal to them. Thus, instead of disproving the issue of minorities having grievances on whites, the article may even fuel the said issue. The article can trigger grievances against whites since the article establishes the idea that whites are and will continue to be the superior race in the country. Therefore, this may cause insecurity and rebellion against the white race since others may wish to see the downfall of a superior race. Patterson also included historical developments in regarding some issues such as the classification of races. Patterson stated that, â€Å"In 1930 Mexicans were classified as a separate race by the Census Bureau – which reclassified them as white in 1940, after protests† (p. 84). Patterson also mentioned 2 other related issues in history. In this case, Patterson was able to convince the readers regarding the misclassification done that lead to the misinterpretation of the census result. Thus, Patterson once again established a ground for his ideas and arguments by nullifying the classification made by the census bureau on the issue of which races are to be included as whites. As mentioned earlier, the author was able to establish the supporting facts about his claims. However, there are some instances that the author failed to mention relative and important information. Patterson adapted a study stating that, â€Å"Recent studies indicate that the second-generation Hispanic whites are intermarrying †¦ † (p. 83). However, Patterson did not mention what particular study reaches that conclusion. Therefore, readers in doubt of that particular argument have no means of verifying the claim. Patterson should have indicated all the necessary information about the research to enable the readers to locate the particular study, otherwise doubts will remain doubts in the minds of the readers. Although the article has its strengths, i. e. the use of statistical information, the weakness of the article is readily available to the readers. The main weakness of the article was that the author, Mr. Patterson, was obviously one sided in writing the article. The bias can be seen from the very beginning of the article. Thus, this limits the trust of the readers and the integrity of the writer. Showing personal biases is will really lead to doubts and disbeliefs of the author’s claim since the readers are aware that he or she is arguing for or against one side. Thus, in persuading the readers about a certain action or issue, one must show personal biases for this will weaken the arguments and the ideas presented by the author. In order to establish a ground proof about an argument, a writer must not show biases as much as possible. It would be better to show the different arguments of both side and show relative information, facts and evidences and let the readers decide which arguments weigh more basing from the given evidences. All in all, Patterson did a great job in laying the arguments and he was able to fulfil his main objective, to encourage the whites. However, as mentioned earlier, the article has its own weaknesses as well. Thus, the article would only be effective if the reader is taking the same side as Patterson’s, otherwise, the article would seem very racist of which whites are considered incomparable to others. The validity of the claims is thus, very subjective on the personality and side that the readers will take.

Friday, August 30, 2019

The Role of Banking Sector in the Prevention of Money Laundering in Bangladesh

Chapter One Introduction 1. 0 INTRODUCTION Besides of development of Economic activities, monetary related crimes are also increasing in both developed and underdeveloped countries. Almost in each country illegal transaction of money has been increased & these illegal money has been also used on various illegal activities. Money laundering process refers to illegal receipt or transfer of fund from one place to another. This process involves not only the banking system of the country but also non-banking system.Bangladesh is moving towards an open economy with a small-magnetized sector by liberalizing the financial and economic policies. However, the money laundering mechanisms are creating problem for a country like Bangladesh. Bangladesh Bank as the Central bank of Bangladesh Supervise all the banking and non-banking financial transactions on behalf of Bangladesh Government. Money laundering process is a great obstacle to the execution of monetary policy adopted by Bangladesh bank t o stable the economy of the country.To prevent money laundering, money laundering prevention bill 2002 was passed in the National Assembly of Bangladesh on 5 April 2002 and Gazette Notification was made on 7 April 2002. And Bangladesh Bank has been designated to act as the main preventive agency. Money Laundering has serious adverse effect on Economical, Political & Social condition of a country. It increases unequal distribution of income and as a result, the employment level, output level of the country, price stability as well as economic development and growth can be hampered.So it is immediately required to prevent it. I believe it is a matter of great opportunity for me to study on this topic, as Money laundering, is a manifestation and a facilitator of organized crime, and has attracted increasing interest in our country. Due to money laundering process, desirable investment of the country cannot be done, national income declines and economic growth of the country hampers. 1. Background of Money LaunderingThe mafia mobster Al Capone is most often credited with coining term â€Å"money laundering† because he used investments in coin-operated Laundromats to disguise or â€Å"wash† the millions he made from bootlegging and other illegal enterprises during the Prohibition in the US-the banning of alcoholic drinks in the 20th century. It is also said that the term â€Å"laundering† is used because, years ago, the cash proceeds (in U. S. dollars) from drug sales were actually washed with soap and water to appear old and worn. Launderers would then go to the Federal Reserve Bank and exchange the â€Å"laundered† bills in for new bills.Along with the new bills came a fed receipt, which served to support the â€Å"legitimate† origin of the cash. The scam was finally identified when someone at the Fed realized that the serial numbers on the bills indicated that they should not be as old and worn as they appeared to be. The term first appeared in newspapers reporting the Watergate scandal in the US in 1973 and in judicial/legal contest in the US in 1982. Whilst the term â€Å"money laundering† was coined in the 20th century, it has been going on for several thousand years.The history of money laundering is interwoven with the history of trade and of banking. In 1986, the U. S. became the first country in the world to criminalize the â€Å"laundering† of the proceeds of criminal activity when it passed the U. S. money laundering law. The silk road which scholars say first became a real link around 100 BC, ran for 12,000 kilometers and linked some of the greatest civilizations the world has ever seen – the Chinese, Mongolian, Indian, Persian, Greek, Byzantine, Mesopotamian and Egyptian – transporting goods, people, ideas, religions and Money.Chinese inventions like gunpowder and paper first traveled to Europe in this manner. Along with many other things, Syrian jugglers and acrobat s, cosmetics, silver, gold, amber, ivory, carpets, perfume and glass from Europe, Central Asia, Arabia and Africa traveled to the east. It lasted until the 15th century when newly discovered sea routes to Asia opened up. Traditional method of moving money evolved before Western banking became established in the region protecting early merchants along the Silk Road against robbery.In ancient China it was known as â€Å"fei qian† or â€Å"flying coins†. The system spread throughout the world – to other Asian regions, the Indian Subcontinent, the Middle East, eastern and southern Africa, Europe and North and South America – following immigration patterns. These traditional money transfer systems are called as Chop, Hawala, Hundi, etc. 1970-The US Congress enacted the Bank Secrecy Act (BSA) in October 1970 following increasing reports of people bringing bags full of illegally – obtained cash into banks for deposit.The BSA is simply a reporting and reco rd-keeping statute. Although willful violations of its terms are a crime; it does not criminalize money laundering as such. BSA requires banks –retain financial details, -report cash transactions over $ 10,000/-. Thus in 1986, the U. S. became the first country in the world to criminalize the â€Å"laundering† of the proceeds of criminal activity. Thus made money laundering a crime in its own right, and strengthened the BSA in several respects, most importantly by prohibiting â€Å"structuring†. 990 – The Financial Crimes Enforcement Network (FinCEN) created by the US Treasury on April 25, initially to focus on the detection of financial crimes by providing analytical support to law enforcement investigations. In 1994, the agency would be given BSA regulatory responsibilities. 1992 – Annunzio-Wylie Money Laundering Act amended the BSA in several respects. Perhaps most important, required any financial institution, and its officers, directors, emplo yees and agents, â€Å"to report any suspicious transaction relevant to a possible violation of law or regulation. The Annunzio –Wylie Act, require all financial institutions to put in place, not only BSA compliance programs, but also anti-money laundering programs. At a minimum, the programs would be required to include: 1) The development of internal anti-money laundering policies, procedures and controls; 2) The designation of a compliance officer; 3) An ongoing employee training 4) An independent audit functions to test the program. At first U. S. A. has taken initiative to money laundering but now most of the countries of the world are aware about it. 2. Origin of the ReportThis Research Paper has been prepared for the partial fulfillment of Masters of Business Administration (MBA) Programme. For this purpose honorable teacher and supervisor Mr. Md. Nazrul Islam, Head of the Department of Business Administration, Shahjalal University of Science & Technology, Sylhet aske d to submit a proposal. After discussing with him about various issues of money laundering I have submitted a proposal on â€Å"The Role of Banking Sector in the Prevention of Money Laundering in Bangladesh † was submitted and then the final research paper is prepared. 3.Objective of the Paper The objective of the research paper is to help the students be familiar with how the theoretical knowledge obtained in the degree program can be applied in practice. Generally research is either problem identifying or problem solving tool. The objectives of the study are as follows: – 1. To understand the theoretical concepts of money laundering. 2. To show the present scenario of anti money laundering issues in Bangladesh. 3. To observe the policy development and maintenance by Bangladesh Bank as a supervisor of anti money laundering activities. 4.To figure out core procedures that Bangladesh Bank adopts to supervise the anti money laundering activities. 5. To comment on the exi sting system and recommend for improvement. 1. 4 Methodology Certain methods and techniques is utilized to collect data for this research paper. This study is mainly based on empirical as well as theoretical analysis. Collected data and information is tabulated, processed and analyzed critically in order to make the report informative. Both primary and secondary sources of data are chosen as effective means of collecting data relevant for this paper. . To prepare first part of the research paper secondary sources were used. Publications and database within Bangladesh Bank and others commercial bank helped me to get data about money laundering and its prevention. Various types of circular of Bangladesh Bank regarding money laundering exist in different commercial banks. This paper also required study of annual report, policy related circulars, and service rules, administrative circulars and other related papers. To get more information, I have also collected some books about money la undering and searched website. 2.Interview of the personnel from people within these relevant organizations was the basic technique to collect primary data. Informal discussion with executive connected with the planning and control works in the various levels of the Bangladesh Bank was needed. To collect data and to analyze these properly I have to be interviewed face to face with bank officials. . 5. Justification of the Research To prevent money laundering is very complex task especially in a country like Bangladesh where most of the citizens are illiterate and their economic bad condition inspired them to involve in illegal activities.This increases economic misery of the have-nots and concentrated wealth in the hands of 10% of the total population. The scope and scale of money laundering has increased over time and the process of addressing the problem has become complex because of the global nature of the problem. So cooperation among the law enforcing agencies, awareness of th e overall people of the country about its adverse effects, government strictness to avoid political interferences, all these are required to prevent it, that is, creation of wareness against money laundering is of highest importance at the moment. After about three months research with various money-laundering issues with Bangladesh Bank and Commercial Banks this paper is intended to fulfill course requirements of Masters of Business Administration. Bangladesh Bank, which is the authorized Bank to monitor all the banking and non-banking financial institutional activities, so I have worked on it in details. Beside this I have studied other operational areas of the commercial bank, which have enriched the level of my knowledge. . 6 Limitations Though this report provides the insights of Money Laundering in Bangladesh and the mechanisms by which Bangladesh Bank takes steps to prevent Money Laundering, it has some limitations as well. As the activities of money laundering are illegal, a ll of work is going on behind the sight of general public; it is hard to find out the adequate & real data. The organization on which was studied is the Central Bank of BANGLADESH, which is not a private or public bank of Bangladesh.The main limitation that faced during conducting the study was lack of access to information considered confidential by employees of central bank based on their policy and strategies. Chapter Two 2. 1 Brief History of Money Laundering The mafia mobster Al Capone is most often credited with coining term â€Å"money laundering† because he used investments in coin-operated Laundromats to disguise or â€Å"wash† the millions he made from bootlegging and other illegal enterprises during the Prohibition in the US-the banning of alcoholic drinks in the 20th century.It is also said that the term â€Å"laundering† is used because, years ago, the cash proceeds (in U. S. dollars) from drug sales were actually washed with soap and water to appea r old and worn. Launderers would then go to the Federal Reserve Bank and exchange the â€Å"laundered† bills in for new bills. Along with the new bills came a fed receipt, which served to support the â€Å"legitimate† origin of the cash. The scam was finally identified when someone at the Fed realized that the serial numbers on the bills indicated that they should not be as old and worn as they appeared to be.The term first appeared in newspapers reporting the Watergate scandal in the US in 1973 and in judicial/legal contest in the US in 1982. Whilst the term â€Å"money laundering† was coined in the 20th century, it has been going on for several thousand years. It is said that the abuse of Chinese merchants and others by oppressive regimes and despotic rulers led them to find ways to hide their wealth, including ways of moving it around without it being identified and confiscated. Money laundering in this sense was prevalent 4000 years before Christ.Many minori ties in countries down the ages and around the world have taken steps to preserve wealth from the rulers- either from blatant confiscation or from taxation and, indeed, from a combination of both, who have targeted them simply because of their beliefs or colour. It is happening even today. And, of course from those seeking to enforce judgments in civil cases or to follow the money that results from other crime. The history of money laundering is interwoven with the history of trade and of banking. In 1986, the U. S. ecame the first country in the world to criminalize the â€Å"laundering† of the proceeds of criminal activity when it passed the U. S. money laundering law. 2. 2 The Silk Road – Once World’s main commercial artery The silk road which scholars say first became a real link around 100 BC, ran for 12,000 kilometers and linked some of the greatest civilizations the world has ever seen – the Chinese, Mongolian, Indian, Persian, Greek, Byzantine, Me sopotamian and Egyptian – transporting goods, people, ideas, religions and Money. Heading west were porcelain, furs, spices, gems and other exotic products of Asia.Chinese inventions like gunpowder and paper first traveled to Europe in this manner. Along with many other things, Syrian jugglers and acrobats, cosmetics, silver, gold, amber, ivory, carpets, perfume and glass from Europe, Central Asia, Arabia and Africa traveled to the east. It lasted until the 15th century when newly discovered sea routes to Asia opened up. Traditional method of moving money evolved before Western banking became established in the region protecting early merchants along the Silk Road against robbery. In ancient China it was known as â€Å"fei qian† or â€Å"flying coins†.The system spread throughout the world – to other Asian regions, the Indian Subcontinent, the Middle East, eastern and southern Africa, Europe and North and South America – following immigration patte rns. These traditional money transfer systems are called as Chop, Hawala, Hundi, etc. 2. 3 History of Criminalizing Money Laundering 1970-The US Congress enacted the Bank Secrecy Act (BSA) in October 1970 following increasing reports of people bringing bags full of illegally – obtained cash into banks for deposit. The BSA is simply a reporting and record-keeping statute.Although willful violations of its terms are a crime, it does not criminalize money laundering as such. BSA requires banks –retain financial details, -report cash transactions over $ 10,000/-. 1974 –although the BSA is accepted now, its constitutionality was originally challenged in the courts by elements of the banking community and some civil libertarians. BSA was challenged on a number of grounds. In California Bankers Assn . v. Shultz, 416 U. S. 21 (1974) Supreme Court rejected claims that various parts of the BSA violated constitutional rights. 986 – Growth, seriousness of the problem of Money Laundering, and of widespread non-compliance with the BSA, led to the enactment of the Money Laundering Control Act of 1986. Thus in 1986, the U. S. became the first country in the world to criminalize the â€Å"laundering† of the proceeds of criminal activity. Thus made money laundering a crime in its own right, and strengthened the BSA in several respects, most importantly by prohibiting â€Å"structuring†. 1990 – The Financial Crimes Enforcement Network (FinCEN) created by the US Treasury on April 25, initially to focus on the detection of financial rimes by providing analytical support to law enforcement investigations. In 1994, the agency would be given BSA regulatory responsibilities. 1992 – Annunzio-Wylie Money Laundering Act amended the BSA in several respects. Perhaps most important, required any financial institution, and its officers, directors, employees and agents, â€Å"to report any suspicious transaction relevant to a possible v iolation of law or regulation. † The Annunzio –Wylie Act, require all financial institutions to put in place, not only BSA compliance programs, but also anti-money laundering programs. At a minimum, the programs would be required to include: ) the development of internal anti-money laundering policies, procedures and controls; 2) the designation of a compliance officer; 3) an ongoing employee training 4) an independent audit functions to test the program. 2. 4 Why Money Laundering is done? Criminals engage in money laundering for three main reasons: First, money represents the lifeblood of the organization that engages in criminal conduct for financial gain because it covers operating expenses, replenishes inventories, purchases the services of corrupt officials to escape detection and further the interests of the illegal enterprise, and pays for an extravagant lifestyle.To spend money in these ways, criminals must make the money they derived illegally appear legitimate . Second, a trail of money from an offense to criminals can become incriminating evidence. Criminals must obscure or hide the source of their wealth or alternatively disguise ownership or control to ensure that illicit proceeds are not used to prosecute them. Third, the proceeds from crime often become the target of investigation and seizure. To shield ill- gotten gains from suspicion and protect them from seizure, criminals must conceal their existence or, alternatively, make them ook legitimate. 2. 5 Why we must combat Money Laundering Money laundering has potentially devastating economic, security, and social consequences. Money laundering is a process vital to making crime worthwhile. It provides the fuel for drug dealers, smugglers, terrorists, illegal arms dealers, corrupt public officials, and others to operate and expand their criminal enterprises. This drives up the cost of government due to the need for increased law enforcement and health care expenditures (for example, f or treatment of drug addicts) to combat the serious consequences that result.Crime has become increasingly international in scope, and the financial aspects of crime have become more complex due to rapid advances in technology and the globalization of the financial services industry. Money laundering diminishes government tax revenue and therefore indirectly harms honest taxpayers. It also makes government tax collection more difficult. This loss of revenue generally means higher tax rates than would normally be the case if the untaxed proceeds of crime were legitimate. We also pay more taxes for public works expenditures inflated by corruption.And those of us who pay taxes pay more because of those who evade taxes. So we all experience higher costs of living than we would if financial crime—including money laundering—were prevented. Money laundering distorts asset and commodity prices and leads to misallocation of resources. For financial institutions it can lead to a n unstable liability base and to unsound asset structures thereby creating risks of monetary instability and even systemic crises. The loss of credibility and investor confidence that such crises can bring has the potential of destabilizing financial systems, particularly in smaller economies.One of the most serious microeconomic effects of money laundering is felt in the private sector. Money launderers often use front companies, which co-mingle the proceeds of illicit activity with legitimate funds, to hide the ill-gotten gains. These front companies have access to substantial illicit funds, allowing them to subsidize front company products and services at levels well below market rates. This makes it difficult, if not impossible, for legitimate business to compete against front companies with subsidized funding, a situation that can result in the crowding out of private sector business by criminal organizations.No one knows exactly how much â€Å"dirty† money flows through the world's financial system every year, but the amounts involved are undoubtedly huge. The International Money Fund has estimated that the magnitude of money laundering is between 2 and 5 percent of world gross domestic product, or at least USD 800 billion to USD1. 5 trillion. In some countries, these illicit proceeds dwarf government budgets, resulting in a loss of control of economic policy by governments. Indeed, in some cases, the sheer magnitude of the accumulated asset base of laundered proceeds can be used to corner markets — or even small economies.Among its other negative socioeconomic effects, money laundering transfers economic power from the market, government, and citizens to criminals. Furthermore, the sheer magnitude of the economic power that accrues to criminals from money laundering has a corrupting effect on all elements of society. The social and political costs of laundered money are also serious as laundered money may be used to corrupt national instit utions. Bribing of officials and governments undermines the moral fabric in society, and, by weakening collective ethical standards, corrupts our democratic institutions.When money laundering goes unchecked, it encourages the underlying criminal activity from which such money is generated. Nations cannot afford to have their reputations and financial institutions tarnished by an association with money laundering, especially in today's global economy. Money laundering erodes confidence in financial institutions and the underlying criminal activity — fraud, counterfeiting, narcotics trafficking, and corruption — weaken the reputation and standing of any financial institution. Actions by banks to prevent money laundering are not only a regulatory requirement, but also an act of self- interest.A bank tainted by money laundering accusations from regulators, law enforcement agencies, or the press risk likely prosecution, the loss of their good market reputation, and damaging the reputation of the country. It is very difficult and requires significant resources to rectify a problem that could be prevented with proper anti-money-laundering controls. It is generally recognized that effective efforts to combat money laundering cannot be carried out without the co-operation of financial institutions, their supervisory authorities and the law enforcement agencies.Accordingly, in order to address the concerns and obligations of these three parties, these Guidance Notes were drawn up. 2. 6 Techniques in Money Laundering There are diversified method of money laundering which ranges from the purchase and resale of a luxury item (e. g. a house, car, or jewelry) to passing money through a complex web of legitimate businesses and ‘shall’ companies (i. e. those companies that primarily exist only as named legal entities without any trading business activities). Basically 3 stages, which may comprise numerous transactions by the launderers-Placement†”the physical disposal of the initial proceeds (derived from illegal activity). 1. Breaking up of large amounts of cash into smaller amounts. 2. Depositing the cash in bank and subsequently transferring the same amount from one bank to another, preferably, in abroad. 3. Exchanging into a foreign currency and subsequently conversion into local currency. 4. Cash purchase of single premium insurance policy or other investment. 5. Cash purchase of costly items like jewelry, diamond, car, aircraft, and boats etc as an alternatives to cash. 6.Injecting the cash in business like hotels, restaurants, bars, casinos, bookmakers, travel agency, taxi firm etc. which handle considerable cash in day-to-day operation. Layering—creation of complex layers of financial transactions for disguising the audit trail and provide secrecy. 1. Purchase & sale of securities and commodities via brokers. 2. Conversion into monetary instruments like BCD, TC, BONDs. 3. Electronic funds transfer-very freq uently. 4. Making deposit in outstation bank branches or overseas banking system. 5. Sale & purchase of material assets between some fictitious persons/associates.Integration – the laundered proceeds are set back into the economy in such a way that they re-enter the financial system appearing as normal business funds/legal money. Identification of illicit source becomes next to impossible. 1. Falsification (over/under invoicing) of invoicing/export. 2. Deployment of fund in ‘shell’ company and recoup the as legitimate profit. 3. Taking aid of corrupt bank employees and obtaining bank loan by depositing illicit money as security. 4. False loan repayment. 5. Taking aid of E-cash, which enables to move vast amount of money instantly with just a few keystrokes. . 7 Moving Money Abroad Legitimate purposes-are for moving money abroad: (1) to invest, (2) to speculate, (3) to lend, (4) to meet trading/personal obligations and (5) to safeguard assets against theft or seiz ure by repressive regimes. But a criminal moves money abroad for- (1) Dealing in arms & ammunition, (2) Drug trafficking, (3) Financing terrorist activities, (4) Evasion of exchange regulations/control, (5) Evasion of taxation, (6) Disguise or remove proceeds of threat/fraud/bribe, (7) Making blackmail payments and (8) Paying ransom for kidnappers.The banking system remains one of the most important avenues for money launderers. The use of bearer certificate of deposit, bank drafts, wire transfers to transmit funds internationally and establishment of loan back scheme are commonly used as banking instruments around the world. New methods are constantly being used to avoid detection. These may include simple measures as â€Å"Smurfing† or Structuring that is making numerous small deposits which would fall below a suspicious cash transaction report, using relatives, third party or false names on accounts or more sophisticated measures such as use of shell companies.A recent stu dy by FATF found increasing use of non-bank financial institutions (Money Changers, remittance business etc. ) to provide services attractive to launderers since these institutions are subject to fewer regulatory requirements than banks. Because of increasing profit from the drug trafficking and other criminal enterprises, money launderers are adopting new techniques, employing specialized expertise who can provide sophisticated methods of laundering and various other financial services.Techniques used include false invoicing (over- invoicing, under- invoicing), commingling of legal and illegal money, the use of bank loan arrangements (whereby the launderer transfers proceeds to another country and use them as security for a bank loan, which is sent back to original country) and layers of transactions through off-shore shell companies. In addition, a significant amount of illegal proceeds has been invested in real estate. However, because of the introduction of anti-money laundering counter measures in different countries, money launderers constantly seek new ways to circumvent regulation.Methods that work tend to be replicated in different locations or may be used with some modifications. 2. 7. 1 Underground Banking (Alternative Remittance System) There has also of under ground or alternative banking system commonly known as ‘Hawala’ or Hundi in the sub-continent. This system works without a paper trail. A ‘Hawala’ bankers issue neither a written receipt for the sum received nor an order for payment. What he does, make a firm verbal commitment to the seller of dollars to make an equivalent taka payment at the agreed rate of exchange, through his agent in the particular country.Then he sends a coded message to his agent containing the designated recipients name and time, date and address for the payment. Why people resort to underground banking a. Socio-economic & political reasons b. Higher returns c. Anonymity d. No available bankin g channel e . Avoidance of local taxes f. Illiteracy/Semi-literacy Advantages of Hundi/Hawala: a. No paper trail b. No bureaucracy c. Cost effective d. No body is the loser and e. No holiday-very fast delivery [pic] Figure 1. Basic sequence of communication and payment in an alternative remittanceThe Chinese have a similar system known as ‘fie chien’ or flying money. This system, sometimes known as ‘Chit’ system involved depositing money in one country in exchange for chit or a chop (i. e. a seal) and remittance of this money in another country on presentation of the chit. It is fast and convenient, does not involve the transportation of bank cash, leaves little trail for investigators, has virtue of anonymity and the costs are fairly low. The main negative consequence of money laundering can have on the financial system.A large-scale money laundering operation may put at the risk of smaller nation’s financial system through loss of credibility and i nvestor’s confidence. The victims of the bank’s malpractice were the depositors and the government in developing countries. 2. 7. 2 Electronic Money Laundering Criminals are always looking for â€Å"a new type of detergent which allows for cleaner laundry† (Bortner, 1996). They have been quick to exploit each new method of financial transfer. In the 1980s and 1990s wire transfers became a popular method for moving money in both the legal and illegal sectors.By 2000 we may see the same situation with e-money. The abuse of e-money by money launderers may become a significant problem in the future because e-money systems will be attractive to money launderers for two reasons: 1. Transactions may become untraceable; and 2. Transactions are incredibly mobile. Untraceability |E-money systems may provide Organized Crime with untraceable, | |mobile wealth. | The use of e-money systems will mean fewer face-to-face financial transactions.The anonymity of e-money will make â€Å"knowing your customer† much more difficult. E-money systems also allow the parties to the transaction to deal with each other directly, without the assistance of a regulated financial institution. Thus, there may not be a traditional audit trail. Mobility Hypothetically, e-money could come from anywhere in the world, and be sent anywhere in the world. Thus, e-money systems may offer instantaneous transfer of funds over a network that, in effect, is not subject to any jurisdictional restrictions.The problem may be illustrated by separating the process of money laundering into three basic steps – placement, layering and integration – and then comparing traditional money laundering systems with cyber-systems. The first step in money laundering is the physical disposal of cash. Traditionally, placement might be accomplished by depositing the cash in domestic banks or other kinds of financial institutions. Or the cash might be smuggled across borders for depos it in foreign accounts, or used to buy high-value goods, such as artwork, airplanes, or precious metals and gems, that can then be resold with payment by cheque or bank transfer.With e-money laundering, cash may be deposited into an unregulated financial institution. Placement may be easily achieved using a smart card or personal computer to buy foreign currency, goods, etc. Powerful encryption may be used to guarantee the anonymity of e-money transactions. The second step, layering, involves working through complex layers of financial transactions to distance the illicit proceeds from their source and disguise the audit trail. This phase traditionally involves such transactions as the wire transfer of deposited cash, the conversion of deposited cash into monetary instruments (e. . , bonds, stocks, travelers' cheques), the resale of high-value goods and monetary instruments, and investment in real estate and legitimate businesses, particularly in the leisure and tourism industries. Shell companies, typically registered in offshore havens, are a popular device in the traditional layering phase. These companies, whose directors are often local attorneys acting as nominees, protect the identity of the real owners. These owners also benefit from restrictive bank secrecy laws and attorney-client privilege In an electronic-money system, layering can be done through a personal computer.There is usually no audit trail. In addition, e-money systems allow for instantaneous transfer of funds over a system that, in effect, has no borders. The last step is to make the wealth derived from crime appear legitimate. Traditionally, integration might involve any number of techniques, including using front companies to â€Å"lend† the money back to the owner or using funds on deposit in foreign financial institutions as security for domestic loans. Another common technique is over-invoicing, or producing false invoices for goods sold – or supposedly sold – ac ross borders.In e-money laundering the criminal may be able to achieve integration by using a personal computer to pay for investments or to buy an asset, without having to call on the services of an intermediary financial institution. In short, the temptation of electronic forms of money for the criminal may be the potential for untraceable, mobile wealth. 2. 8 Vulnerability of the Financial System to Money Laundering Money laundering is often thought to be associated solely with banks and moneychangers. All financial institutions, both banks and non-banks, are susceptible to money laundering activities.Whilst the traditional banking processes of deposit taking, money transfer systems and lending do offer a vital laundering mechanism, particularly in the initial conversion from cash, it should be recognized that products and services offered by other types of financial and non-financial sector businesses are also attractive to the launderer. The sophisticated launderer often involv es many other unwitting accomplices such as currency exchange houses, stock brokerage houses ,gold dealers, real estate dealers, insurance companies, trading companies and others selling high value commodities and luxury goods.Certain points of vulnerability have been identified in the laundering process, which the money launderer finds difficult to avoid, and where his activities are therefore more susceptible to being recognized. These are:  ¦ entry of cash into the financial system;  ¦ cross-border flows of cash; and  ¦ Transfers within and from the financial system. Financial institutions should consider the money laundering risks posed by the products and services they offer, particularly where there is no face-to-face contact with the customer, and devise their procedures with due regard to that risk.Although it may not appear obvious that the products might be used for money laundering purposes, vigilance is necessary throughout the financial system to ensure that weakn esses cannot be exploited. Banks and other Financial Institutions conducting relevant financial business in liquid products are clearly most vulnerable to use by money launderers, particularly where they are of high value. The liquidity of some products may attract money launderers since it allows them quickly and easily to move their money from one product to another, mixing lawful and illicit proceeds and integrating them into the legitimate economy.All banks and non-banking financial institutions, as providers of a wide range of money transmission and lending services, are vulnerable to being used in the layering and integration stages of money laundering as well as the placement stage. Electronic funds transfer systems increase the vulnerability by enabling the cash deposits to be switched rapidly between accounts in different names and different jurisdictions. However, in addition, banks and non-banking financial institutions, as providers of a wide range of services, are vulne rable to being used in the layering and integration stages.Other loan accounts may be used as part of this process to create complex layers of transactions. Some banks and non-banking financial institutions may additionally be susceptible to the attention of the more sophisticated criminal organizations and their â€Å"professional money launderers†. Such organizations, possibly under the disguise of front companies and nominees, may create large scale but false international trading activities in order to move their illicit monies from one country to another.They may create the illusion of international trade using false/inflated invoices to generate apparently legitimate international wire transfers, and may use falsified/bogus letters of credit to confuse the trail further. Many of the front companies may even approach their bankers for credit to fund the business activity. Banks and non-banking financial institutions offering international trade services should be on thei r guard for laundering by these means.Investment and merchant banking businesses are less likely than banks and moneychangers to be at risk during the initial placement stage. Investment and merchant banking businesses are more likely to find them being used at the layering and integration stages of money laundering. The liquidity of many investment products particularly attracts sophisticated money laundering since it allows them quickly and easily to move their money from one product to another, mixing lawful and illicit proceeds and integrating them into the legitimate economy.Although it may not appear obvious that insurance and retail investment products might be used for money laundering purposes, vigilance is necessary throughout the financial system to ensure that non traditional banking products and services are not exploited. Intermediaries and product providers who deal direct with the public may be used at the initial placement stage of money laundering, particularly if they receive cash. Premiums on insurance policies may be paid in cash, with the policy subsequently being cancelled in order to obtain a return of premium (e. . by cheque), or an insured event may occur resulting in a claim being paid out. Retail investment products are, however, more likely to be used at the layering and integration stages. The liquidity of a mutual funds may attract money launderers since it allows them quickly and easily to move their money from one product to another, mixing lawful and illicit proceeds and integrating them into the legitimate economy. Lump sum investments in liquid products are clearly most vulnerable to use by money launderers, particularly where they are of high value.Payment in cash should merit further investigation, particularly where it cannot be supported by evidence of a cash-based business as the source of funds Insurance and investment product providers and intermediaries should therefore keep transaction records that are comprehensive enough to establish an audit trail. Such records can also provide useful information on the people and organizations involved in laundering schemes. Corporate vehicles trust structures and nominees are firm favorites with money launderers as a method of layering their proceeds. Providers of these services can find themselves much in demand from criminals.The facility with which currency exchanges can be effected through a bureau is of particular attraction especially when such changes are effected in favor of a cheque or gold bullion. 2. 9 Money Laundering-Bangladesh Scenario Bangladesh is neither a drug producing nor a major consumer country for drugs. However, our country’s proximity to Golden Triangle in the East and Golden crescent in the West rendered her vulnerable to drug trafficking and drug related problems. In Bangladesh, no drug cartel, drug syndicate or organized groups of drug dealers have been intercepted till to day.At present, phensedyl, heroin and cannabis r ank first, second and third in order of prevalence in the country. The influence of the drug money is not yet felt to pose a major concern for us. However, Money laundering is no less then significant in our economy. Both black money and dirty money are being laundered in various ways as under: 1. Conversion of local currency into foreign currency from black market. Smuggle it out of the country and deposit it to any foreign bank; 2. The use of hundi to send money overseas; 3. The use of bearer instruments (drafts, cheques, stock certificate etc) 4.Operating business enterprises, which hardly makes profits, but shows large profits and pays taxes to cover and legalize their dirty money; 5. The use of third party or false name accounts at financial institutions; 6. The purchase of items of value (such as luxury goods, gold, vehicles real estate); 7. Create investment companies in which fictitious persons deposit money invest in shares, stock and bonds; 8. Financing the political group s by other country; 9. Excess greediness; 10. No proper way to determine the amount of income on assets; 11.Dishonesty of customs, defense and government employee; 12. Problems of illegal immigrant; 13. Lack of co-operation from the Bangladesh embassy with Bangladeshi people living in the foreign country; 14. Lack of co-operation from the foreign branches of banks and foreign exchange organization with Bangladeshi people living in the foreign country; 15. Bureaucratic complexity & extra payment; 16. Lack of providing temporary debt privilege; 17. Smuggling; 18. Under invoicing; 19. Transfer pricing & over invoicing; 20. Illegal transaction of capital; 21. Terrorist financing; 22.Lack of potential political figure; 23. Demonstration. 1. Money Laundering Effects on Society 1. Laundered money may be used to corrupt national institutions. Bribing of officials and governments undermines the moral fabric in society, and by weakening collective ethical standards, corrupts our democratic in stitutions. 2. Money laundering erodes confidence in financial institutions and the underlying criminal activity—fraud, counterfeiting, narcotics, trafficking, and corruption—weaken the reputation and standing of any financial institution. 3. Governments need to increase health care expenditures e. . treatment of drug addicts, treatment of victims of violence, etc. 2. 9. 2 Economic Effects of Money Laundering Because crime, underground activity, and money laundering take place on a large scale, macroeconomic policymakers must take them into account. But, because these activities are hard to measure, they distort economic data and complicate governments’ efforts to manage economic policy. In addition, the ability to identify statistically the country and currency of issuance and the residency of deposit holders key in understanding monetary behavior.To the extent that money demand appears to shift from one country to another because of money laundering-resulting in misleading monetary data—it will have adverse consequences for interest and exchange rate volatility, particularly in dollarized economies, as the tracking of monetary aggregates becomes more uncertain. The income distribution effects of money laundering must also be considered. To the extent that the underlying criminal activity redirects income from high savers to low savers or from sound investments to risky, low-quality investments, economic growth will suffer.For example, there is evidence that funds from tax evasion in the United States tend to be channeled into riskier but higher-yielding investments in the small business sector, and also that tax evasion is particularly prevalent in this sector. Fraud, embezzlement, and insider trading seem likely also to be more prevalent in rapidly growing and profitable businesses and markets, because â€Å"that’s where the money is. † Money laundering also has indirect macroeconomic effects. Illegal transactions c an discourage legal ones by contamination.For example, some transactions involving foreign participants, although perfectly legal, are reported to have become less desirable because of an association with money laundering. More generally, confidence in markets and in the efficiency-signaling role of profits is eroded by widespread insider trading, fraud, and embezzlement. And, money that is laundered for reasons other than tax evasion also tends to evade taxes, compounding economic distortions. Moreover, contempt for the law is contaminating—breaking one law makes it easier to break others.Accumulated balances of laundered assets are likely to be larger than annual flows, increasing the potential for destabilizing, economically inefficient movements, either across borders or domestically. These balances could be used to corner markets—or even small economies. The above effects are to some extent speculative; however, the Quick study (1996) also conducted empirical test s on the relationship between GDP growth and money laundering in 18 industrial countries for the first time.It found evidence that significant reductions in annual GDP growth rates were associated with increases in the laundering of criminal proceeds in the period 1983-90. 2. 9. 3 How money is laundered in regional basis in Bangladesh. It has found by the research team from both the different secondary & primary sources that, there are regional trends of money laundering in our country. Such as- In Sylhet region there are a lot of people lived in foreign countries. So there are great chances of illegal money transfer in this region i. e. hundi or hawala.This system works without a paper trail. A hawala banker issues neither a written receipt for the sum received nor an order for payment. What he does, make a firm verbal commitment to the seller of dollars to make an equivalent taka payment at the agreed rate of exchange, through his agent in Sylhet region. Then, he sends a coded mes sage, to his agent containing the designated recipients name and time date and address for the payment. As well as chance of gold smuggling in this region from foreign lived people and their local relatives.In Chittagong region there are a lot of cases of drug smugglings and arm smugglings occurring in front of the eye of different law enforcing agencies. In Khulna region there are many incidents of forest materials & other goods of laundering. In Comilla region a lot of suger, sharies, and fensdils are smuggled every year in our country. In the Rajshahi region the occurrence of cattle smuggling are very common, and it has a network to supply cattle all over the country especially in the season of Eid . How money is laundered Smurfing involves the use of multiple cash deposits, each smaller than the minimum cash-reporting requirement. †¢ Misinvoicing of exports and falsification of import letters of credit and customs declarations can conceal cross-border transfers of, say, the proceeds of drug trafficking. †¢ Barter: stolen property (e. g. , antiques or automobiles) can be exchanged, across national borders or domestically, for illegal substances. †¢ Parallel credit transactions can be used to avoid the formal economy, except for the final use made of the net proceeds of illegal activity to purchase legally marketed goods or services. Interbank wire transfers may not be subject to reporting on money laundering; bribery of bank officials can thus make it easier to conceal large illegal transfers between accounts. †¢ Derivatives that replicate insider trading opportunities (e. g. , a synthetic version of a company stock subject to merger or takeover) can be used to avoid detection of an unusual change in a listed stock price. 2. 11 International Anti-Money Laundering Initiatives Money laundering has become a global problem as a result of the confluence of several remarkable changes in world markets (i. . , the globalization of markets). The growth in international trade, the expansion of the global financial system, the lowering of barriers to international travel, and the surge in the internationalization of organized crime have combined to provide the source, opportunity, and means for converting illegal proceeds into what appears to be legitimate funds. In 1986, the U. S. became the first country in the world to criminalize the â€Å"laundering† of the proceeds of criminal activity with the enactment of the Money Laundering Control Act of 1986.Since enacting the law, the U. S. Congress has increased its coverage, reach and scope, making it the broadest, strongest and most far-reaching money laundering law in the world. The U. S. law is a weapon of enormous breadth and power wielded by U. S. prosecutors in that country. Those convicted under the law face a maximum prison term of 20 years and a fine of $500,000 per violation. A legal entity such as a bank or business that is convicted under the law faces fines and forfeitures.In addition, a bank that is convicted of money laundering can lose its charter and federal deposit insurance. Persons and entities also face civil money penalties. Concerted efforts by governments to fight money laundering have been going on for the past fifteen years. The main international agreements addressing money laundering are the 1988 United Nations Vienna Convention against Illicit Traffic in Narcotic Drugs and Psychotropic Substances (the Vienna Convention) and the 1990 Council of Europe Convention on Laundering, Search, Seizure and Confiscation of the Proceeds of Crime.And the role of financial institutions in preventing and detecting money laundering has been the subject of pronouncements by the Basle Committee on Banking Supervision, the European Union, and the International Organization of Securities Commissions. The Vienna Convention, adopted in December 1988, laid the groundwork for efforts tocombat money laundering by creating an obligation for signa tory states (including Bangladesh) to criminalize the laundering of money from drug trafficking.It promotes international cooperation in investigations and makes extradition between signatory states applicable to money laundering. It also establishes the principle that domestic bank secrecy provisions should not interfere with international criminal investigations. During the past twenty years there have been a number of resolutions passed by the ICPOInterpol General Assembly, which have called on member countries to concentrate their investigative resources in identifying, tracing and seizing the assets of criminal enterprises.These resolutions have also called on member countries to increase the exchange of information in this field and encourage governments to adopt laws and regulations that would allow access, by police, to financial records of criminal organizations and the confiscation of proceeds gained by criminal activity. In December 1988, the G-10's Basle Committee on Ban king Supervision issued a â€Å"statement of principles† with which the international banks of member states are expected to comply.These principles cover identifying customers, avoiding suspicious transactions, and cooperating with law enforcement agencies. In issuing these principles, the committee noted the risk to public confidence in banks, and thus to their stability, that can arise if they inadvertently become associated with money laundering. Over the past few years, the Basle Committee has moved more aggressively to promote sound supervisory standards worldwide.In close collaboration with many non-G-10 supervisory authorities, the Committee in 1997 developed a set of â€Å"Core Principles for Effective Banking Supervision†. Many important guidelines issued by Basle Committee for worldwide implementation for all banks among which, â€Å"Prevention of the Criminal Use of the Banking System for the Purpose of Money Laundering†, December 1988 â€Å"Custome r Due Diligence for Banks†, October 2001â€Å"Sound Practices for the Management and Supervision of Operational Risk â€Å", February 2003; Shell banks and booking offices â€Å", January 2003; relate to money laundering controls.In 1989, the G-7 countries recognized that money laundering had become a global problem, not least due to the increase in drug trafficking. The G-7 Summit in Paris in 1989 took a great step forward in combating international money laundering with the creation of the Financial Action Task Force (FATF) to develop a coordinated international response to mounting concern over money laundering. One of the first tasks of the FATF was to develop steps national governments should take to implement effective anti-money laundering programs.The experts within FATF came up with a list of 40 Recommendations, built on the firm foundations of the 1988 UN Convention Against Illicit Traffic in Narcotic Drugs and Psychotropic Substances and the Statement of Principl es of the Basle Committee on Banking Regulations. The FATF 40 Recommendations set out the basic framework on what countries need to do — in terms of laws, regulations and enforcement — to combat money laundering effectively and were designed with universal application in mind.Over time, they have been revised to reflect new developments in money laundering and experience. The 40 Recommendations have now become the global blueprint in anti- money laundering best practice and set the international standards for money laundering controls. Setting those standards meant that all participating governments committed to moving in the same direction at the same pace, a requirement for success. Through FATF's peer-review process, the participants have pushed each other into implementing the standards.Even the IMF regards the anti-money laundering actions advocated by the FATF as crucial for the smooth functioning of financial markets. In joining FATF, every member nation makes a political commitment to adopt the recommendations and allows itself to be evaluated by the other member nations on whether it has fulfilled that commitment. Today FATF has grown to an organization of thirty-one member countries and has representatives from the Gulf Cooperation Council and the European Commission.Participants include representatives from members' financial regulatory authorities, law enforcement agencies, and ministries of finance, justice, and external affairs. Representatives of international and regional organizations concerned with combating money laundering also attend FATF meetings as observers. This top-down, cooperative approach has been greatly successful in encouraging FATF member nations to improve their money laundering regimes. With expanded membership, FATF has now achieved agreement on money laundering standards and implementation among 31 governments.More than that, FATF has encouraged development of regional groups to adhere to the same standards. B y the last count, about 130 jurisdictions — representing about 85 percent of world population and about 90 to 95 percent of global economic output — have made political commitments to implementing â€Å"The Forty Recommendations. † Another, more controversial initiative that FATF has developed to enhance international cooperation is publication of a list of non-cooperative countries and territories (NCCT) — jurisdictions that lack a commitment to fight money laundering.Following the June 2000 publication of the first such list, a number of the 15 NCCT jurisdictions have acted quickly to implement FATF standards. . Other UN initiatives, such as the 2000 UN Convention against Transnational Organized Crime, have assisted in complementing the work undertaken by the FATF. However, it was the FATF’s exercise on Non-Cooperating Countries and Territories which brought about a sea change in thinking at the highest political levels.The exercise, which identi fies and evaluates the legal, judicial and regulatory framework of countries whose regulatory systems do not appear to meet international standards, has been a success, despite its unpopularity in many quarters. 1. 8. 16. After 11 September 2001, the tragedy in New York highlighted to all civilized nations the need to look at the finances of terrorists and the methods used to transfer funds around the11 world. The FATF expanded its mission beyond money laundering and agreed to focus its expertise on the worldwide effort to combat terrorist financing.The FATF, at its Washington meeting in October 2001, came up with 8 Special Recommendations to tackle this threat. Terrorists use similar systems to money launderers and the 8 Special Recommendations complement the 40 existing Recommendations. The United Kingdom was one of the first countries in the world to have signed and ratified the UN International Convention on the Suppression of the Financing of Terrorists through the Terrorism Ac t 2000. In fact the UK was unique in meeting the requirements of all 8 FATF Special Recommendations immediately.Several regional or international bodies such as the APG (Asia/Pacific Group on Money Laundering), CFATF (Caribbean Financial Action Task Force), the ESAAMLG (Eastern and Southern Africa Anti-Money Laundering Group), GAFISUD (Financial Action Task Force for South America), the MONEYVAL Committee of the Council of Europe (the Select Committee of experts on the evaluation of anti-money laundering measures) and the OGBS (Offshore Group of Banking Supervisors), either exclusively or as part of their work, perform similar tasks for their members as the FATF does for its own membership.Bangladesh is a member of APG. This co-operation forms a critical part of the FATF’s strategy to ensure that all countries in the world implement effective counter-measures against money laundering. Thus the APG, the CFATF, GAFISUD, the MONEYVAL Committee and OGBS carry out mutual evaluatio ns for their members, which assess the progress they have made in implementing the necessary anti-money laundering measures. In the same vein, APG, CFATF and the MONEYVAL also review regional money laundering trends.During the past decade, a number of countries have created specialized government agencies as part of their systems for dealing with the problem of money laundering. These entities are commonly referred to as â€Å"Financial Intelligence Units† or â€Å"FIUs†. These units increasingly serve as the focal point for national anti- money laundering programs because they provide the possibility of rapidly exchanging information (between financial institutions and law enforcement / prosecutorial authorities, as well as between jurisdictions), while protecting the interests of the innocent individuals contained in their data.Since 1995, another forum for international cooperation has developed among a number of national financial intelligence units (FIUs), who beg an working together in an informal organization known as the Egmont Group (named for the location of the first meeting in the Egmont-Arenberg Palace in Brussels). The goal of the group is to provide a forum for FIUs to improve support to their respective national anti-money laundering programs.This support includes expanding and systematizing the exchange of financial intelligence, improving expertise and capabilities of the personnel of such organizations, and fostering better communication among FIUs through the application of new technologies. The Egmont Secretariat, currently hosted by the UK, is the ideal vehicle for FIUs from various countries to talk to one another once they reach the required standard. Financial Crimes Enforcement Network (FinCEN), the U. S. inancial intelligence unit led by the Department of the Treasury, provides training and technical assistance to a broad spectrum of foreign government officials, financial regulators, law enforcement personnel, 12 and ba nkers. This training covers a variety of topics, including money laundering typologies, the creation and operation of FIUs, the establishment of comprehensive anti-money laundering regimes, computer systems architecture and operations, and country-specific antimoney- laundering regimes and regulations.FinCEN also works closely with the informal Egmont Group of more than 50 FIUs to assist various jurisdictions in establishing and operating their own FIUs. Additionally, FinCEN has provided FIU and money laundering briefings and training in many jurisdictions, including Argentina, Armenia, Australia, the Bahamas, Brazil, Canada, China, Costa Rica, Dominican Republic, El Salvador, Germany, Greece, Hong Kong, India, Indonesia, Isle of Man, Jamaica, Jersey, Kazakhstan, Lebanon, Italy, Liechtenstein, Nauru, Nigeria, Netherlands, Palau, Paraguay, Russia, Seychelles, South Africa, Switzerland, St.Vincent and the Grenadines, Taiwan, Tanzania, Thailand, Tonga, and the United Kingdom. FinCEN ha s also conducted personnel exchanges with the Korean and Belgian FIUs. The U. S. Department of State's Bureau for International Narcotics and Law Enforcement Affairs (INL) develops assistance programs to combat global money laundering. INL participates in and supports international anti-money- laundering bodies and provides policy recommendations regarding international money laundering activities.The U. S. State Department has developed a programmatic approach to assist jurisdictions in developing anti-money-laundering regimes to protect their economies and governments from abuse by financial criminals and stem the growth of international money laundering. This approach integrates training, technical assistance, and money laundering assessments on specific money laundering problems or deficiencies to achieve concrete, operational, institution-bui

Thursday, August 29, 2019

Civil War in the Summer of 1642 Essay

There were a number of factors and subsequently a number of people who were crucial in aggravating the outbreak of the first English civil war, but most of these people were apart of two prominent parties, namely the royalists and parliamentarians. Of these two groups, two figures outstand as bitter rivals, King Charles I and John Pym; together they contributed most significantly to the disagreement and aggression between Parliament and King. However, ultimately I believe Pym to be the lesser of two evils. The relationship and status of the monarchy in parliament’s eyes had already been in a state of decline even before Charles’ reign. His predecessor had been known as the ‘wisest fool in Christendom’ and there was a lot of resentment towards the former king, James, not only because of the number of times he dissolved parliament but also from his abuse of power and alienation of them through royal prerogatives, which were justified by his own ‘divine right of kings’ belief. It could be argued that Charles was pulled into an uphill battle from the start and was not to blame for the damaged relationship between the commons and himself, however, during Charles’ reign, he made no attempt to reconcile relations even repeating the ideals of his father through the ‘divine right of kings’ and also through the arrogance of his attitude and subsequent dissolution of parliament on many occasions. History seemed to more or less be repeating itself, with 1629 marking the start of the ‘eleven years tyranny’ through which Charles ran solely without parliament. By his own accord, he then enforced a number of taxes and reforms that were heavily criticised by both parliament and public alike. Among these were the religious reforms brought on by the resented Archbishop William Laud, who was suspected of Roman Catholicism which together with the fact Charles’ wife was Catholic, alienated parliament further and fed a rumour of a Catholic conspiracy. Other reforms brought on such as the Star Chamber and prerogative courts were used to silence critics, and further deepened the divide between the two; some parliamentarians such as John Hampden even challenged the changes such as the ship money tax Hampden refused to pay. All these served to further throw away any hope of peaceful negotiations between parliament and Charles, with each new action undertaken gaining more criticism. Undeniably however, one of his biggest critics was John Pym. Pym was a long serving member of parliament who had opposed the monarchy even in the reign of James, having been active in the impeachment of Buckingham in 1625 and in the production of the petition of right in 1628. He had opposed Charles a numerous points and contributed significantly to the disagreement between Parliament and King and the subsequent dissolutions of Parliament; Clarendon had said during the Short Parliament of 1640, Pym had â€Å"had appeared to be the most leading man†. It was no surprise with such enthusiasm that by the time of the Long parliament, Pym had dodged an accusation of treason and become the leader of the opposition to the king. However, it is important to realise Pym was really just fighting for the rights of parliament and against the absolute monarchy Charles was imposing. Like many other puritans, he had good reason to fear the â€Å"Catholic conspiracy† mentioned earlier and believed the despotic government of Charles was a way of de stroying the protestant faith in England. In this light, Charles’ arrogance comes through as he was obviously unable to negotiate over his unreasonable actions. When parliament finally needed to be called again in 1640 due to the Scottish invasion, it marked a point of vulnerability for Charles, which parliament and namely Pym took advantage of. Charles needed funding, and in exchange for the money the Long parliament demanded the impeachment of both Laud and Strafford as well as the removal of the Star Chamber. In both cases, Pym was spearheading the legal proceedings, even having launched a Bill of Attainder to justify a death sentence for Strafford which was soon reluctantly signed by Charles. The Earl of Strafford had been a close advisor of the king, and his death was a huge blow to Charles and something he always regretted given the promise he made to Strafford â€Å"upon the word of a king, you shall not suffer in life, honour or fortune†. As a result, Charles resented parliament and longed for revenge. With the state of relations between King and parliament at an all-time low, the last thing needed was more criticism to an already weakened king, who had just agreed to the Triennial act of 1641 which meant parliament would be called at least every three years. Despite this, Pym and his supporters presented the Grand Remonstrance; a list of 160 grievances and misdeeds of Charles. This in itself was something proposed by Pym and was almost mocking Charles with his â€Å"divine right of kings† ideal now appearing obsolete. This may have proved a last straw for Charles, who would have been building a great sense of anger with Parliament and more specifically with Pym. Indeed soon after in 1642, Pym along with four other prominent members of the opposition was charged with treason, showing just how much of a threat Charles saw Pym as. When Charles took it upon himself to arrive at parliament with 300 soldiers to personally arrest the five members it destroyed any final shreds of trust between Parliament and Charles. Members of parliament were representatives of the people and Charles was arresting five of them for merely criticising. This event embodied to Parliament the absolute monarchy they were fighting against and all the liberties they still needed to fight for. Charles must have even realised the mistake he had made in breaking any remaining ties with parliament, and six days later headed for Oxford to prepare an army of the inevitable coming war. In conclusion, both Pym and Charles can be interpreted as being the reason relations fell apart and Civil war broke out, however, even with Pym’s involvement in many parliamentary dissolutions and explicit opposition to the king, Charles still appears as the most unreasonable. Charles gave plenty of reasons for parliament and members such has Pym to criticise him, having made no attempt to learn from his father’s mistakes, ruling for 11 years purposely without parliament intervention and from imposing taxes and religious reforms which alienated people. The final act of attempting to arrest five members of parliament with hundreds of armed guards, proved not only too aggressive but also the final reason as to why Civil war became the only solution remaining.

Wednesday, August 28, 2019

Green Power Essay Example | Topics and Well Written Essays - 750 words - 1

Green Power - Essay Example In a similar fashion, using nuclear energy requires Uranium mining, which is reportedly a serious health hazard. Evidently, solar energy is far more popular than nuclear energy for its proclaimed environment-friendly nature, and hence, a rule utilitarian will argue that the uranium proposal be summarily rejected. A perfect example is Governor Bill Ritter who is against Uranium mining (227). According to the tenets of rule utilitarianism, an action is justifiable as far as it follows a general rule that makes common good in normal circumstances. However, in the given case, one can see that the request by Lane Douglas, the Powertech Uranium spokesperson, for a â€Å"fair hearing† is not irrational. This is so because though nuclear energy is normally abhorred, in the present case, the solar energy project will produce cadmium which is no less dangerous than uranium. According to act utilitarianism, an action is just if it produces maximum good in a given situation, and adherence to any general rule is not important. If that is the case, Powertech Uranium requires as much attention as AVA gets. In other words, â€Å"company proposal be judged on facts, not prejudice† (227). In such cases, engineers have many different responsibilities arising out of moral responsibility, personal morality, and professional morality. Based on their personal and professional integrity, engineers have the responsibility to be honest in disclosing the issues associated with the use of cadmium and uranium. As the case reveals, there are serious environmental and health issues associated with the use of both uranium and cadmium, and technology is not developed enough to handle both the cases. Evidently, it is possible to argue that as an employee, an engineer has the professional responsibility to promote the interests of his company. However, this professional interest should not supersede the moral responsibility. At this point, it is wise to utilize the Golden Rule to analyze

Tuesday, August 27, 2019

BUSINESS MODELS AND PLANNING Essay Example | Topics and Well Written Essays - 1250 words

BUSINESS MODELS AND PLANNING - Essay Example The project leader would need to establish the standards within which the communication will occur. The stakeholders would also need to be aware of the course of the communication with the indication of how and when it will take place. The strategic information enables the project leader to set the scope for all the communications that are relevant to the project. The strategic information is also significant for scheduling various projects, within a period, thereby making the stakeholders to be aware of the progress. In proper management of the firm’s processes, the project leader would need a proper strategic information to help in ensuring consistency in the communication process. The presentation of the strategic information to the stakeholders helps them to maintain consistent communication with each other. The stakeholders would need to follow the strategic information to identify any information about the project management. The strategic information helps in harmonizing the stakeholders since all of them have similar information about the situation of the project. The project leader also has the ability to make the stakeholders aware about any change in the project. Consequently, the strategic information helps the project leader to avoid delays associated with the stakeholders being misinformed. Further, the strategic information also increases the productivity of the workers. The establishment of a strategic information ensures that every employee remains informed of every activity included in the project. For instance, a project leader of a company would need to keep the stakeholders aware of the need for their input in reducing the volume of the solid wastes by 50%. This calls for the need of strategic information, which is efficient in equipping the stakeholders with the necessary information. The strategic information helps in restricting the stakeholders to the scope of the project since keeps them

English 305 Assignment Example | Topics and Well Written Essays - 750 words

English 305 - Assignment Example In such a way, the following analysis will seek to analyze to articles upon the topic of global warming (Kunzig 21). The first of these articles takes the viewpoint the global warming is very much caused by human activity and can only be slowed by a definitive and corrective process of engagement on the part of nearly each and every societal stakeholder. Conversely, the second article takes the standpoint that global warming is a natural process, one that is ultimately contingent upon the sun, not human activity, and will necessarily run its course and give way to a cooler era in the near future. The first article, entitled â€Å"Collective Action and Citizen Responses to Global Warming†, discusses the way in which global warming threatens to have drastic impacts upon the way in which individuals live their lives, raise their families, and plan for discernible future (Lubell 399). As such, impacts upon factors such as increased temperatures leading to reduced crop yields, the effects of decreased oxygen in the atmosphere and the possibility for plaintiff and other compliments of the global food chain to be reduced, and the way in which decreased water supplies in some of the more arid regions of the world could easily lead to global conflict. Naturally, none of these determinants is especially hopeful and the reader is left with the take away that unless global warming is stopped, the repercussions of it will create a less than enticing environment in the very near future. By contrast, the article entitled, â€Å"Global Warming: The Hoax of the Century† takes a greatly different stance. Although it is mostly rhetorical in its analysis, this particular article focuses upon the fact that the scientific models and means of analytics that are being referenced to prove global warming are ultimately flawed. Moreover, the author points to the fact that the winds of politics at impacted upon the way in which individuals view the issue, and indeed the way in which scientists are representing it to the general populace (Mardell 15). Most importantly, the article itself puts forward its own set of scientific factors and discusses the manner in which the sun, the entity responsible for warming our planet and keeping the crust of planet Earth from being frozen, as is the case with so many of the other neighboring planets, is ultimately responsible for any fluctuations in global temperature that had been referenced lately. Naturally, the common sense approach that this particular article puts forward allows the individual to come to something of a realization for the fact that global warming, although potentially a serious problem, might not have the human causation that so many individuals and scientists have doggedly been pointing to the past several decades. From the complete and thorough analysis of both of these articles, a more nuanced understanding of what causes global warming and how it is reference within the current dialogue wa s understood. Ultimately, with the available evidence that exists, it is clear to discern that humans are having a negative impact upon their plan. Regardless of whether an individual is an extreme

Monday, August 26, 2019

Country Risk and Strategic Planning Analysis Paper Assignment

Country Risk and Strategic Planning Analysis Paper - Assignment Example Nice blend of coffee serving in presence of amusing environment should be accompanied by the highest serving quality. Price: Since Indian coffee market has a good history, its market is supposed to have few fearsome competitors for Starbucks. Pricing becomes very important in this respect. General attitude of locals towards pricing is very strict; thus lower the price, greater the market share. Place: Starbucks' most vulnerable market comprises of middle class Indians who live in high streets of posh and developing areas of large cities. Therefore, it is of immense value to target the market of Mumbai, New Delhi, Pune, Chennai, Bangalore, and Jaipur etc specially those places which are near colleges, bus stops, cinema theaters, railway stations etc. Distribution and Supply Chain Risks may be termed as the major risk factors for Starbucks in India. Effective resource planning becomes very crucial since distribution through independent sources may become highly cost effective. Abundance of highly educated manpower in this regard can be the key for solution. India is a mixture of various different societies comprising of thousands of ethnic, cultural, religious and social groups. Thus, social and cultural risks are very high due to immense differences in these groups.

Sunday, August 25, 2019

The Importance of Social Justice in Education Essay

The Importance of Social Justice in Education - Essay Example This paper illustrates that scholars have attempted to describe the phenomena in light of factors like political orientation, religious background, and political and social philosophy. However, in the modern society, social justice is the acknowledged as the ideas of ‘equal’ justice and opportunity for every member of the society transcending beyond a courtroom or the judiciary. It involves providing an equal footing to everyone in all the social strata existing, from the very rich to those below the poverty line. The idea of social justice, while hailed by many supporters as the only moral way to run a society is almost impossible to implement in its pure form as many different factors come into play in deciding the life quality of an individual in a society and controlling all them is not only difficult but leads to further debates about the ethical implications of said control. There are two opposing political stances on the issue. The leftist stance which shares some traits with socialism supports the idea of government involvement to ensure social justice through control of the resources present in the society and equal distribution through legislation pertaining to taxation and programs to help to less privileged. Social justice should mean that basic necessities like food, shelter, and education are provided to all at the expense of the privileged few. The right-wing school of thought accepts the idea of social justice but doesn’t support existing government legislation as no one should be ‘forced’ to provide equal opportunity for others- it should be fostered instead by mutual consent and philanthropic response. Healthcare, employment, education, shelter and child protection are just some of the sectors where there is a lot of pressure to ensure social justice as an economy and society can potentially benefit from a healthy and informed population equally provided with all the resources and the prospect to grow and stren gthen. While social justice aims to uphold basic human rights on the basis of a moral and ethical obligation, there is no denying that social justice can also be thought of a practical solution to boost an economy or general profitability of a nation; this may not be one of the more humane reasoning behind the system but it is a rational one. One of the areas which has benefitted from this school of thought is education, where there has been significant movement to ensure some degree of social justice as a well-educated population is a necessary asset to ensure a competitive edge of any nation in terms of technological advances and improved sectors of military, services, sustenance, resource management, and others. It is also necessary as education is one of the major equating factors which decrease the divide existing in a society and the effects trickle down into other areas, effectively impacting lifestyles and a greater possibility of social justice. Education is also one of the tools through which tolerance is spread in society; as shared knowledge and enlightened minds are much more accepting of diversity and merging cultures. By providing the same learning environment, resources and opportunities for higher learning to children coming from different backgrounds, societies have a much better chance of getting rid of negative social developments like racial and sexual discriminations and prejudices. Thereby creating a more equal and collaborative economy which will have an impact on overall productivity as well as social well being of the population.  

Saturday, August 24, 2019

Economic Arguments for Further Enlargement of the EU Essay

Economic Arguments for Further Enlargement of the EU - Essay Example It is important to give a clarification of the above-mentioned phrase ‘further enlargement of the EU’ before I embark on the economic arguments about this move. Further enlargement of the European Union means the introduction of more new members in the union, a process that is well stipulated by the EU policies. The number of countries willing to join the European Union has been rapidly increasing since the 1990s with the most recent members to join the block being Croatia. The European Union has a very concise and clear policy that stipulates the requirements that a country applying for membership has to meet. This policy also referred to as the Union’s acquis communautaire and contains rules and regulations that applicants must follow with the main aim of the policy being to prevent rise of any conflict in the future. The countries have also to meet the criterion that was introduced in Copenhagen fully. The Copenhagen criterion was introduced primarily to cover political and economic aspects of the candidates or what scholars refer to as ‘democratic credentials and economic competitiveness’.   Deepening of the economy of the European Union is among the economic arguments that are highly outlined by economic experts. This is a call for an integration of the economy of the member states commonly termed as ‘having the Full Economic Union’. This would lead to a common market and an entire unification of the current fiscal and monetary policies.

Friday, August 23, 2019

Documenting the Media Revolution Research Paper - 1

Documenting the Media Revolution - Research Paper Example However, the advent of the computer era and the development of various electronic based gadgets have allowed man to finally come up with an alternative to print media. I speak of the eBook readers that come bundled with most of our smartphones and tablet PC's. This paper will take a look into the history of the eBook, what gadgets existed prior to the advent of the modern day eBook reader, and how the technology has made reading a more interactive activity these days. eBooks first appeared on the market back in 1998. The precursor of today's readers were the Softbook and Gemstar Rocket eBook Reader. These particular readers did not easily catch on at the time since most people were still adapting to the internet and paperless era so very little attention if any were actually paid to the launch of these readers. However, the year 2000 launch of Stephen King's horror novel Ride the bullet in pure eBook format called attention to the up and coming technology. By 2003, eBooks and readers were still trying to break into the market as paper books still remain the traditional favorite. by July, Gemstar is merely a footnote in the history of the readers while Barnes and Noble pulls out eBooks from their stores. Critics then begin to predict the beginning of the end for the digital reader format. But the technology gains a new life with the advent of the Sony Librie which is a marked improvement upon its predecessors since it now uses electronic ink and has managed to reduce the backlight glare thus allowing the reader to show the same type of actual ink quality for the reader. By 2007, the Kindle is released and everyone now knows that the eBook reader is here to stay. From that point on other ebook reader devices such as the Nook come into market play. (Kozlowski, Michael â€Å"A Brief History of eBooks†). Even print book manufacturers cannot help but acknowledge that the eBook is fast edging out its physical format competitor in terms of book sales. According to research done by the Pew Research Center: The population of e-book readers is growing. In the past year, the number of those who read e-books increased from 16% of all Americans ages 16 and older to 23%. At the same time, the number of those who read printed books in the previous 12 months fell from 72% of the population ages 16 and older to 67%. (Rainie, Lee & Duggan Maeve â€Å"E-Book Reading Jumps; Print Book Reading Declines†) If one were to think about it, the rise of the eBook reader was actually something that was going to happen eventually. Our society is fast becoming a very tech savvy, gadget obsessed group that is constantly on the look out for the next big gadget that can make their lives easier. In this case, the eBook reader came across at just the right time. People were already conditioned to reading newspapers and other material via the internet and through their computer screens that using the eBook reader was not something that people feared anymore. The technology also found itself vastly improved thanks to the constantly evolving structure of the laptops as well. Newspapers and book publishers acknowledged the fact that there was more money for them to make through the electronic publication of their newspapers and books, so it is easy to surmise that the publishing sector also had a direct hand in the decision of their subscribers to switch to the eBook version of their reading material. (Fowler, Geoffrey & Baca, Marie â€Å"The ABC's of E-Reading). One reason that people are

Thursday, August 22, 2019

River in Siddhartha Essay Example for Free

River in Siddhartha Essay Siddhartha many times in the book, and has many meanings. In the first chapter, Siddhartha visits the river to bath and to make holy sacrifices. â€Å"The sun browned his slender shoulders on the river bank, while bathing at the holy ablutions, at the holy sacrifices. †(pg3) When Siddhartha left Govinda behind, Siddhartha meets with the river again, and crossing this river led him to a new beginning. â€Å"During the night he slept among the boats on the river, and early in the morning, before the first customers arrived in the shop, he had his beard shaved off by the barber’s assistant. He also had his hair combed and rubbed with fine oil. Then he went to bathe in the river. †(pg52) Moving into the town on the other side of the river, Siddhartha got caught up with having money, just like everyone else in the town. â€Å"He was not long in Kamaswami’s house, when he was already taking a part in his master’s business. Daily, however, at the hour she invited him, he visited the beautiful Kamala, in handsome clothes, in fine shoes and soon he also brought her presents. (pg66) After getting tired of the materialistic lifestyle, Siddhartha crossed the river again, he lets go of all the memories he had on the other side of the river. He started to let go, by giving away his fine clothes. So crossing the river again gave Siddhartha a fresh start. â€Å"Will you accept these clothes from me, which I find a nuisance? I should prefer it if you would give me some old clothes and keep me here as your assistant, or rather your apprentice, for I must learn h ow to handle the boat. †(pg103) Staying with the ferryman, next to the river, was one step closer for Siddhartha to find Nirvana. Whenever Siddhartha meets with the river, it represents rebirth and forgiveness. In this novel, they use the river as a symbol for the stream of life and unity. When Vasudeva teaches Siddhartha to listen carefully for one last time, he hears voices which he always heard before, but this time they sound different, he heard the whole of a thousand sounds, the sound of Om. The river taught Siddhartha unity, that how he left his father and his father was hurt, Siddhartha’s son left him, which left him hurt by the loss. And that the agony is experienced again and again throughout a lifetime.

Wednesday, August 21, 2019

Business Environment Essay Example for Free

Business Environment Essay In a highly competitive and ultra-dynamic business environment in order for Morden business to remain competitive and thrive, it is no longer good enough to compete and serve at a local scale, more and more business have seen the need and benefit of expanding their business on a global scale. Expanding the business internationally will allow a broader market which in turn will help the organisation stay competitive even gain a competitive edge, it will also result in increased profit margins and stakeholders larger return on investments. When expanding internationally there are several key issues that will need to be addressed such as the organisational context, the staffing context, recruitment and selection, international compensation and performance management and continued management and re-entry. The organisational context Whinch-it board of directors though lacking the necessary skills to expand globally have expressed interest in expanding to the Asian region to tape into the markets need for boats and boating equipment. When planning an overseas expansion they are several issues that should be considered, these include the change of size and structure of the organisation, the flow and volume of information, control mechanisms, and the host countries demands-Dowling et.al 2008. As the business expands it gets bigger in terms of size and therefore structure of the organisation has to change in order to accommodate the change in size. According to Lihua (2009) two key structural features of the organisation will change which are the hierarchal levels and the number of subunits. Due to more employees being needed they will need to be managers to manage the subunits therefore an increase in the levels of hierarchy in the organisation. Departments such as the export department structure will also be the i nitial stages to be affected and also attended to by manufacturing companies such as Winch-it. Whinch-it will require a foreign agent or a distributor who will have knowledge of the local market, in addition to a foreign agent an export manager is also needed to control the domestic based home office, this new positions will affect the structure and size of Winch-it. With an increasing size of the organisation and a longer hierarchical system the volume of information and control mechanism becomes harder to monitor. According to Arace et.al 1974 communication plays a vital role in the organisation’s control and coordination process and the organisational hierarchy plays a part in the work related communication flows, the more levels of hierarchy means the longer and delay the information might get to certain subunits and the relevancy and urgency of that information might have diminished by the time it gets to its final destination, Arace et.al 1974 also states the need of networking in the organisation as that will strengthen the communication links between individuals in the organisation. There are various organisational structures that Winch-it can adopt for its international expansion, the most effective one I recommend is the matrix structure. By adopting this structure Whinch-it is basically integrating its operations across more than one dimension Dowling et.al (2008). The advantages to this structural form are no issue is neglected as conflicts of interest are brought out in the open and priority is placed upon any problem that may arise in the organisation. Due to Whinch-it having multiple objectives in their plan to internationalize their business such as not just selling their products in the Asian regions but also moving some of the production overseas the matrix structure is an excellent choice as it fits the strategy of simultaneous pursuits and multiple business dimensions which in will also be given equal priority Dowling et.al (2008). According to Qiu et.al (2012) a number of multinational companies use the matrix system to implement high levels of dual strategies such as foreign product diversification and area diversification; this shows the matrix system fits the situation. This matrix structure is highly effective but is also expensive and will require careful implementation and management from the top management. The staffing context Whinch-it can pursue one of several approaches to international staffing, with each having its advantages and disadvantages. These staffing methods include ethnocentric staffing method which the strategic decisions are made at the headquarters and the foreign subsidiaries have limited autonomy. If Whinch-it feels there are no qualified personals in the host country then ethnocentric approach will prove to be the best one. Having a parent company national will also maintain the communication, coordination and control links to corporate headquarters. Disadvantages of this staffing model include reduced productivity and high turnover as a result of limited promotional opportunities to the host country nationals. Another staffing method that can be used is polycentric, this models allows each subsidiary to be managed by a host country national with some decision making autonomy, this will eliminate some of the problems that ethnocentric have while also eliminating adjustment periods, lan guage barriers and it gives continuity of management of foreign subsidiaries Dowling et.al 2008. Polycentric however has its disadvantages such as language barriers with parent company national and the loyalty to the PCN might be lower that the loyalty to the HCN’s nationality. Geocentric method of staffing takes no account of the nationality of the individuals but their ability to perform the task at hand, the advantages of this according to Dowling et.al (2008) is that it enables a development of an international team that will be ready for deployment throughout the global organisation, one of its disadvantages is the host government wanting a bigger percentage of the employees from the host country and it is very expansive due to increased training and relocation cost. Choosing the correct staffing model for Whinch-it, various factors such as the uncertainty of the foreign market and the rules and laws differing greatly from rules and regulation from the PCN and also the technology advancement being different according to Isidor et.al (2011) technology intensity will increase the likelihood of an ethnocentric staffing method, although this will be beneficial I recommend Winch-it to employ the Geocentric staffing model. This model although expensive will allow the organisation to have the best people for the job who are trained by the organisation and will allow for an easier communication and control throughout all the subsidiaries and the PCN headquarters. According to Gowan (2004) recruitment success results from the organisation understanding of relationship among person-job fit, person-organization fit and cultural differences and recruits accordingly. This will help the organisation in employing high potential employees. Recruitment and selection The goal of organisations is to employ people at the positions that there will be able to do their jobs effectively and efficiently, this aspect is extremely important to the organisation as the employees recruited and selected by the organisation will be vital the success of the organisation. Issues that will arise in the international selection and recruiting are the fact that the national government would want the locals to be hired as opposed to foreigners. The fact that they will be cultural difference in the host country the selection of employees will need to be able to adapt to the host country culture and develop the appropriate behaviours as according to host country. Winch-it should consider the factors the inability of expatriate to adjust to foreign culture as this is the main reason for expatriate fail, this may have resulted because of family concerns as the employee will be separated from family or the family will having difficulties adjusting to the foreign land which can put a lot of emotional strain on the expatriate and therefore may also affect their job. The length of the assignment will also prove to be a problem as the expatriate may require longer time to adjust before being effective but due to the lack of time they may be needed to be effective as soon as possible with no sufficient adjustment time. According to Dowling et.al 2008 the companies can offer the expatriate family friendly policies that will assist the families too in the adjustment and adapting to the foreign land. International compensation and performance management Pay is the most important factor as it as the biggest motivator when it comes to employees performing their task effectively and efficiently. A study taken by Chen et.al 2012 showed that groups that where offered a pay increase worked more cohesive and effective that the group that where offered just the base pay. When going international the parent company nationals will need to be compensated for the perceived risk they will be going by going to a foreign land therefor the expatriates should receive benefits that will offer them the incentive to go to their appointed positions and perform at a high level and avoid expatriate failure. Reference list Lihua, W 2009, Ownership, size, and the formal structure of organizations: evidence from US public and private firms, 1992-2002, Industrial Corporate Change, 18, 4, pp. 595-636, Business Source Complete, EBSCOhost, viewed 30 April 2013 arace, R, Pacanowsky, M 1974, Organizational Communication Role, Hierarchical Level, and Relative Status, Academy Of Management Proceedings (00650668), p. 62, Business Source Complete, EBSCOhost, viewed 30 April 2013. Qiu, J, Donaldson, L 2012, Stopford and Wells were Right! MNC Matrix Structures do fit a High-High Strategy, Management International Review (MIR), 52, 5, pp. 671-689, Business Source Complete, EBSCOhost, viewed 30 April 2013 Isidor, R, Schwens, C, Kabst, R 2011, Human resource management and early internationalization: is there a leap-frogging in international staffing?, International Journal Of Human Resource Management, 22, 10, pp. 2167-2184, Business Source Complete, EBSCOhost, viewed 30 April 2013 Gowan, MA 2004, Development of the Recruitment Value Proposition for Geocentric Staffing, Thunderbird International Business Review, 46, 6, pp. 687-708, Business Source Complete, EBSCOhost, viewed 30 April 2013. Sparrow, PR 2007, Globalization of HR at function level: four UK-based case studies of the international recruitment and selection process, International Journal Of Human Resource Management, 18, 5, pp. 845-867, Business Source Complete, EBSCOhost, viewed 30 April 2013. Chen, C, Williamson, M, Zhou, F 2012, Reward System Design and Group Creativity: An Experimental Investigation, Accounting Review, 87, 6, pp. 1885-1911, Business Source Complete, EBSCOhost, viewed 30 April 2013 Dowling, J Marion Festing, D 2008 â€Å"International human resource management†