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	<title>Aegis Journal</title>
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	<link>http://www.aegisjournal.com</link>
	<description>Addressing Threats That Affect Your Bottom Line</description>
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	<itunes:summary>ÆGIS Journal focuses on business risks that affect your bottom line. The Journal is a forum for the exchange of information, ideas, operating styles, theories, and related topics for corporate managers who make decisions about threats typically outside the expertise available in-house, yet which have the potential to affect their company’s domestic and international bottom lines.</itunes:summary>
	<itunes:author>The Aegis Journal</itunes:author>
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	<itunes:subtitle>Focusing On Business Risks That Affect Your Bottom Line</itunes:subtitle>
	<itunes:keywords>Business Risks, Financial Investigations, Protection, Due Diligence</itunes:keywords>
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		<item>
		<title>Mining The Meaning From Data</title>
		<link>http://www.aegisjournal.com/due-diligence/mining-the-meaning-from-data/2012/02/</link>
		<comments>http://www.aegisjournal.com/due-diligence/mining-the-meaning-from-data/2012/02/#comments</comments>
		<pubDate>Wed, 01 Feb 2012 18:52:25 +0000</pubDate>
		<dc:creator>aegisadmin</dc:creator>
				<category><![CDATA[Due Diligence]]></category>
		<category><![CDATA[L. Burke Files]]></category>
		<category><![CDATA[Meaning from Data]]></category>

		<guid isPermaLink="false">http://www.aegisjournal.com/?p=4177</guid>
		<description><![CDATA[Our modern corporations are huge consumers and warehouses of data, actually so are our small business, and our households.  Never, in the history of mankind, has there been so much [...]]]></description>
			<content:encoded><![CDATA[<p>Our modern corporations are huge consumers and warehouses of data, actually so are our small business, and our households.  Never, in the history of mankind, has there been so much information and data about &#8211; well &#8211; just about everything.</p>
<p>This volume of information in itself is a problem, as now we are required to be more astute consumers of the information.</p>
<p>We are aware of the value of “information” but we are numb to what is good information and what is noise, what is sound information and what is unsound, what is biased, what is timely and what is dated.</p>
<p>&nbsp;</p>
<p>This all goes to the 7 points of what matters</p>
<p>&nbsp;</p>
<p>• Is this information relevant?</p>
<p>Relevance of information is now very time sensitive. Our ability to perceive and than recognize relevance has an impact on the bottom line. The relationship between information and revenue may or may not be direct one, but the costs of a missed opportunity or an unanticipated threat can be huge.</p>
<p>Q: What is the hallmark of a professional that recognizes relent information in a timely fashion?</p>
<p>&nbsp;</p>
<p>• What am I missing 1/3 &#8211; 2/3 rule</p>
<p>With the prevalence of social media, and blogs and desktop publishing &#8211; publication and editorial power has shifted to the individual.  The information is available the moment it is produced. Yet the Internet has no editor, or fact checker &#8211; thus while the information may not be fact checked &#8211; it is also free from an editors’ biases. <em>(I call to mind a story about a company a local paper would not run because the CEO of the company who be the focus of the negative story sat on the paper’s board of directors and the company bought a lot of add space from the paper.)</em>  The shift from edited and filtered information is a positive shift.  The search engine weightings, rankings and page numbers all have to do with popularity &#8211; not usefulness. The more popular the information the easier to find, the more narrow the topic the harder the information is to find.  It will be difficult for the consumer of vary narrow informational bits to find all of the bits they may wish to see and weigh.</p>
<p>Q: How do we find that which lurks below the surface?</p>
<p>&nbsp;</p>
<p>• Type cast again?</p>
<p>The web uses algorithms to search for the content you may wish to see based upon past browsing history.  The retailers use them, the blogs use them, the search engines use them, but that is not who we are.  Our tastes are not based upon our past history as much as  the whim of our polymath minds or our ever-changing roles in life and work.  Once in one of these loops it can be hard to break out of them and these informational feed back loops can be very limiting when looking for new information on new topics.</p>
<p>Q: How do we escape these biased anchored histories in life and commerce?</p>
<p>&nbsp;</p>
<p>• Keepers of the knowledge, professional oracles.</p>
<p>Experts are a good way to obtain relevant information  with less effort. Specific knowledge on locations, technology, laws and regulations are often a must to make well-informed choices.  The experts can also become gatekeepers to access of information, and biased filters of information.  Experts that are not delivering information that is relevant to the consumer of the information are more dangerous than no information.</p>
<p>Q:  If the experts are giving the same advise to every client, how can I use that expert’s advice to have the competitive edge?</p>
<p>&nbsp;</p>
<p>• I trust my community, don’t I?</p>
<p>We trust those we like and those we interact with.  We get our information from ever growing online communities and social media networks.  A great deal of this information is very relevant and often you can see real-time dilemmas playing out in an industry if your level of awareness is attenuated to both what and how things are being said.  This can produce tremendous insights in to the impact current events will have on a future market place for ideas and or goods and services.</p>
<p>Q: How do I know the community is not being manipulated?</p>
<p>&nbsp;</p>
<p>• Ah ha!  That’s what I was looking for?</p>
<p>You look and look and look for information to help you understand the world around you.  You read and digest information from so many sources. How do you keep up with life, work and family with the heavy burden of always and all the time searching for information.  Yet the content provided distracts you with internal links and mazes of distractions making it take you much longer to get the information you want. It is good for their pages rankings but a time waster for you. You get overload with noise &#8211; but you wait for that ah-ha moment that makes it all worthwhile. Yep overloaded, over overwhelmed, and underwater all at the same time.</p>
<p>Q: What is the different between what I need to know and what I would like to know?</p>
<p>&nbsp;</p>
<p>• How do we become aware of new information?</p>
<p>We must keep our eyes and ears open; we must poll others for opinions and ideas &#8211; yet we also must clear our minds.  Try to practice choiceless awareness. Choiceless awareness is where an individual perceives a given situation or bit of information in an unbiased manner.  That means without distortion, without signal noise that colors or distracts. Therefore they will, with complete awareness, act according to this awareness. The choices made will be the manifestation and result of this awareness, rather than the result of biased or managed choice.</p>
<p>Q: How do I process these changes of awareness and provide a referent for context and location?</p>
<p>&nbsp;</p>
<p>Due Diligence is about information, about doing your homework, and amassing knowledge that is both accessible and usable for choice making.  Information is stored in different locations, with filters, bundles, edited, un-edited, sorted, unsorted, or colored to fit one consumer’s needs making it useless for others, etc&#8230;.</p>
<p>There are many laws now on the books for distracted driving because the results of distractive driving are so severe and sometime deadly.  It is not different for us, as we are finding it extremely difficult not to be distracted by information that is not relevant to our information needs, yet we must stay aware of new developments in a timely fashion as the world now just seems to happen faster.</p>
<p>The state of the information barrage is not going to change &#8211; what needs to happen for all of those in the information and choice making professions is to ask and answer the 7 questions posed,  for themselves.</p>
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		<item>
		<title>Mind The Snail Mail</title>
		<link>http://www.aegisjournal.com/opsec-economic-espionage-competitive-intelligence/mind-the-snail-mail/2012/02/</link>
		<comments>http://www.aegisjournal.com/opsec-economic-espionage-competitive-intelligence/mind-the-snail-mail/2012/02/#comments</comments>
		<pubDate>Wed, 01 Feb 2012 18:48:56 +0000</pubDate>
		<dc:creator>aegisadmin</dc:creator>
				<category><![CDATA[OPSEC, Economic Espionage & Competitive Intelligence]]></category>
		<category><![CDATA[Competitive Intelligence]]></category>
		<category><![CDATA[Economic Espionage]]></category>
		<category><![CDATA[OPSEC]]></category>

		<guid isPermaLink="false">http://www.aegisjournal.com/?p=4175</guid>
		<description><![CDATA[We seem to be very conscious of e-mail security, but are often oblivious to the security of the &#8220;snail mail&#8221; we receive at our homes and offices. Recently, in our [...]]]></description>
			<content:encoded><![CDATA[<p>We seem to be very conscious of e-mail security, but are often oblivious to the security of the &#8220;snail mail&#8221; we receive at our homes and offices. Recently, in our role as consultants in the due diligence arena, we were asked a series of questions of snail mail and corporate snail mail security. The answers bear repeating for a wider audience.</p>
<p>• What type of mail security should we have?</p>
<p>Each type of company will have its own requirements and each specific company will have further refinements of those requirements. If the company regularly handles payments through the mail with a significant volume of payments arriving via postal mail or courier, a lock box service is often a sensible investment, both for security and efficiency.</p>
<p>For smaller companies, I strongly recommend that all mail go to a post office box, not a private mailbox. Post office boxes are securely constructed and often continuously monitored by CCTV. However, private mailboxes (e.g., from the UPS Store) offer a street address for delivery of packages via courier, and may be more practical but not as secure as private mailbox should be securely constructed of heavy gauge steel and accessible only to employees of the mailbox company.  A mail box at a home or office location, if needed should be also be very secure and made of steel with a locking system to gain access to the snail mail.</p>
<p>• How can one segregate mail streams?</p>
<p>Mail drops and drawers can be used to segregate the mail according the wishes and needs of the company. However segregated, mail in significant volume should be picked up by a trusted employee or delivered by postal services in bulk, ending up in a secure location. If that location is at a company facility, it should be segregated from the remainder of that facility. Mail may be received, but should never be kept or even exposed, at a loading dock.</p>
<p>Once in the secure location, the mail can be delivered to the proper department. The mail can be pre-coded by agreement, such as adding to the address of certain locations or functions by adding additional addressing information such as Station A, Building 14, or to the attention of a specific employee. These codes should not interfere with the regular postal addressing.</p>
<p>* How should junk mail be dealt with?</p>
<p>All physical mail should be treated as one would treat e-mail. It should be kept free from the prying eyes and the letter openers of others.  Junk mail often originates from companies offering credit cards or financial services. If such mail winds up in the wrong hands, it can lead to identity theft. Yep &#8211; even junk mail may have value</p>
<p>Unsecured mail streams are also vulnerable to industrial espionage without opening up a single envelope or parcel and with nearly zero risk of detection. Think of the unopened mail as the cleaner version of dumpster diving, but without the leftover food bits. One just needs to look at the front of the envelope to make conclusions about the company and the receiver. For example, an envelope containing a credit card will never have any identification on the envelope other that a post office box address. But, with a minor amount of research, one can link the address to the proper credit card issuer.</p>
<p>Mail stream analysis can also reveal the identity of a company&#8217;s clients, the nature of the relationship, the names and addresses of key suppliers, etc. It is also possible to decode Pitney Bowes franking stamps to determine the, senders names and physical address of where that piece of mail originated.</p>
<p>Now imagine what about what you can learn about a company if one you can open their mail!</p>
<p>* How can I tell if the mail has been tampered with?</p>
<p>Look for smudged ink, as many letters are now printed with jet ink printers. The inks will bleed if the paper is treated with chemicals or water (steam) to pen open the envelope and read the contents. Also examine the corners of the envelope for small tears. They may indicate that a tool was inserted to either spool the contents for removal from the envelope or that a small scope was inserted to read the document while still in the envelope</p>
<p>Many correspondents will tape over the corners of an envelope to prevent tampering. However, someone who tampers with an un-taped envelope may also tape it over to conceal the tampering. For very high security mailings, wax seals may be employed to prevent tampering and authenticate the sender as well as security envelops and tamper evident tape and seals. But yet, that too draws attention..</p>
<p>* How can I be more proactive to see if my mail stream(s) are being tampered with?</p>
<p>Have a letter sent to you, at the address of your choice, on a regular basis. Record the number of days it takes to arrive. If you see an increase in the numbers of days it takes for the test letter to arrive, on a consistent basis, this may indicate tampering or the monitoring of your mail stream, as the mailed items must be diverted for at least a few hours for fiddling purposes. This diversion may result in the mailed items missing the cutoff times for sorting and delivery for a day or more.</p>
<p>Include in your own correspondence a small sheet of rice paper inside the envelope. Rice paper turns to goo when it gets moist, such as in from steam when trying open steam open a glued envelope.</p>
<p>Add chemical dots to the paper and envelope that react to the different types of solvents used such as some of the dry cleaning solvents.</p>
<p>Use inks that react to heat, such as lemon juice that turns brown when heated.</p>
<p>Consider sending to yourself regularly a package that contains a mobile tracking device such as a cell phone, thus allowing you to follow your package from the time of mailing to the time of delivery.  <em>Come to think of it I should do that with my luggage I check with the airlines .</em></p>
<p>As always, specific recommendations for action depend upon specific fact patterns. If competitors of your business can gain a competitive advantage through surveillance of your snail mail, you&#8217;ll want to act proactively to prevent such surveillance.</p>
<p>Much thanks to Mark Nestmann for his help with this topic &#8211; very cool indeed.</p>
<p>&nbsp;</p>
<p><a href="http://nestmann.com/">http://nestmann.com/</a></p>
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		<item>
		<title>Very Private Meeting</title>
		<link>http://www.aegisjournal.com/executive-protection-2/very-private-meeting/2012/02/</link>
		<comments>http://www.aegisjournal.com/executive-protection-2/very-private-meeting/2012/02/#comments</comments>
		<pubDate>Wed, 01 Feb 2012 18:45:52 +0000</pubDate>
		<dc:creator>aegisadmin</dc:creator>
				<category><![CDATA[Executive Protection]]></category>
		<category><![CDATA[executive protection]]></category>
		<category><![CDATA[International Bodyguard Association]]></category>
		<category><![CDATA[James Shortt]]></category>

		<guid isPermaLink="false">http://www.aegisjournal.com/?p=4173</guid>
		<description><![CDATA[One of our charges has come up with a very unique way of conducting private meetings.  It is not often we learn something new from a client. Please do not [...]]]></description>
			<content:encoded><![CDATA[<p>One of our charges has come up with a very unique way of conducting private meetings.  It is not often we learn something new from a client. Please do not take this as a sign of arrogance or indifference but one of reality, as we are saturated with the experiences of all of our team members and clients over many years.</p>
<p>Alphonso, we use this name because it is not his name, has contrived a unique way to have private meetings.</p>
<p>Alphonso travels a great deal, 200,000 a year or better, and negotiates some very unusual contracts for large corporations and wealthy individuals.  Much of the work we do with him is to insure nearly no one knows where he is going to be at any given time.  His threat is knowledge of his whereabouts &#8211; not physical security, per se. Even his arrival in a city, can spawn speculation as to who he might be meeting and what he might be doing.  While his travel plans are private his calendar is not always so private for he must manage his time and his meetings and coordinate with the schedules of those whom he is going to meet.</p>
<p>His tactic is simple, he meets other parties, and whether they be clients or professionals is restricted public or semi public locations.</p>
<p>For example, Alphonso met with a professional from London at the J. Paul Getty Museum in Los Angeles.  They walked from exhibit to exhibit, enjoying not only the art, but also the setting for the meeting.  The counterparty to this meeting was told of the time of the meeting and 45 min before the meeting was told of the location of the meeting.  It was a very private meeting as few were around and the museum offered plenty of private space both inside and outside without being overheard or recognized.</p>
<p>A second meeting was held at the NYPD Police museum, with a follow up conference on the Staten Island Ferry.  The initial meeting was at the museum and when the parties agreed it was time to include two other parties held in waiting near by, they met and concluded the negotiations on the John F. Kennedy Staten Island Ferry.</p>
<p>He has also held meetings in the Prado Museum, Roman Forum, Museum of Asian Culture in Singapore and our favorite &#8211; Disneyland, Paris.</p>
<p>Alphonso’s free wheeling style is not only very secure for communications the sheer randomness of the meeting locations, engineered at his request, adds yet another layer to the “where’s Alphono puzzle”.</p>
<p>We use local agents, as advance team members, to look for places that are both public and offer opportunities for privacy.  These locations are communicated via a very private method we choose not to share and only his Sr. Executive Professional knows the location. When the location is chosen and release to the EP team, another advance team arrives equipped anti eavesdropping technology. When Alphonso or his meeting mates arrive locations with the destination are suggested via a well-placed whisper and off they go.</p>
<p>Alphonso’s situation is very unique, but any person looking for some privacy and anonymity as well as a bit of culture can use this technique.</p>
<p>A similar technique can been used when a meeting has been called for a specific location.  I was to meet a gentleman in the lobby of the St Regis Hotel and as normal I was a few minutes early.  At precisely the meeting time I was paged to come to the phone.  My client was on the phone and changed the meeting location to the Pierre, a hotel very near by, but different.  This technique is also very good at hindering electronic surveillance.</p>
<p>&nbsp;</p>
<p><em>This Executive Protection article was written or edited by Baron James Shortt, the</em> <em>Executive Director of the IBA.</em> <a href="http://www.ibabodyguards.com/"><em>http://www.ibabodyguards.com</em></a><em></em></p>
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		<item>
		<title>iPhone, Blackberry, Android &#8211; Security</title>
		<link>http://www.aegisjournal.com/technical-issues/iphone-blackberry-android-security/2012/02/</link>
		<comments>http://www.aegisjournal.com/technical-issues/iphone-blackberry-android-security/2012/02/#comments</comments>
		<pubDate>Wed, 01 Feb 2012 18:43:38 +0000</pubDate>
		<dc:creator>aegisadmin</dc:creator>
				<category><![CDATA[Technical Issues]]></category>
		<category><![CDATA[android]]></category>
		<category><![CDATA[executive protection]]></category>
		<category><![CDATA[L. Burke Files]]></category>
		<category><![CDATA[RIM]]></category>
		<category><![CDATA[smart phones]]></category>
		<category><![CDATA[technology]]></category>

		<guid isPermaLink="false">http://www.aegisjournal.com/?p=4171</guid>
		<description><![CDATA[I asked a few different experts in electronic surveillance and cell phone security which of the three most popular smart phones is the safest and which is the worst.  The [...]]]></description>
			<content:encoded><![CDATA[<p>I asked a few different experts in electronic surveillance and cell phone security which of the three most popular smart phones is the safest and which is the worst.  The answers were clear and consistent.</p>
<p>1.) On all of them it&#8217;s the user that is the root of the problem.</p>
<p>2.) Android has been labeled the worst for malware.</p>
<p>3.) Blackberry is pretty good as it cannot have a virus, but it can propagate worms through its memory chip and emails.</p>
<p>4) iPhones are great until you &#8220;unlock&#8221; the iPhone with jailbreak or other programs.</p>
<p>All can have programs installed to do whatever the programmer wants the cell phone to do.  One just needs to have physical control over the phone and the time and know how to install or write the program.</p>
<p>In the last half of 2011 almost all of the new malware was programmed for the Android Operating System.  While Android is on the rise as a target, by far the largest known number of virus &#8211; over 75% are for the various Symbian operating systems &#8211; for Nokia Phones.  iPhones while getting some targeted attacks are still one of the safest phones &#8211; unless they have been unlocked.</p>
<p>With more devices there are more threats and the threats depended upon where you are in the world &#8211; in the US the attackers are looking or information about , your phone, what you are saying and doing, where in Latin America and the Far East they are looking for banking information.</p>
<p>Some tips &#8211; if the phone has been out of your hands for any length of time and you are in a higher risk profession &#8211; dump it.  If you have a phone given to you as a gift, dump it or sell it to someone else <em>(nothing like screwing up a targeted attacked by giving the device to a teenage girl &#8211; they will cream the electronic intruder just in fees and messaging),</em> avoid known problems phones and subscribe to anti virus and malware services &#8211; even for the Blackberry and iPhone.</p>
<p>Windows Phone 7 &#8211; is still new and looks to be more robust &#8211; but it too has been hit by some nasty malware.  In December a SMS vulnerability was used allowing hackers to carry out a DOS attack on the victim’s  handset.  Oddly this occurred just after MS offered free Windows Phone 7 to those who had Android systems that were getting hacked.  Windows Phone 7  has not been out quite a year and we are sure it too will be tested by the hackers as it gains popularity.</p>
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		<title>The Office Move</title>
		<link>http://www.aegisjournal.com/real-stories-from-the-field/the-office-move/2012/02/</link>
		<comments>http://www.aegisjournal.com/real-stories-from-the-field/the-office-move/2012/02/#comments</comments>
		<pubDate>Wed, 01 Feb 2012 18:41:47 +0000</pubDate>
		<dc:creator>aegisadmin</dc:creator>
				<category><![CDATA[Real Stories from the Field]]></category>
		<category><![CDATA[L. Burke Files]]></category>

		<guid isPermaLink="false">http://www.aegisjournal.com/?p=4169</guid>
		<description><![CDATA[The time has come to pass and we are leaving our current office for an owned location.  As you read this &#8211; HOPEFULLY &#8211; we are comfortable ensconced in our [...]]]></description>
			<content:encoded><![CDATA[<p>The time has come to pass and we are leaving our current office for an owned location.  As you read this &#8211; HOPEFULLY &#8211; we are comfortable ensconced in our new office &#8211; wherever it may be.  Yep &#8211; not sure where we will be come February 1st.</p>
<p>It all began when I was purchasing a location to set up our new office.  The offer was made and accepted and &#8230; weeks ticked by&#8230; and eventually we were told finally all was fine and we would close in a week or so.  So I gave notice to my landlord <em>(great people by the way)</em> that we would be vacating our office of some 3 years January 31.  This notice was given December 15th.</p>
<p>It seems the new location, a commercial condo, has a small problem.  A former manager slipped and fell, sued the association for defects in a property he was maintaining, and won a large judgment well in excess of the policy maximums.  The association did not declare bankruptcy and the law firm representing the injured former manager is now in possession of all of the common areas.  So while the title to the office condo is OK, the relationship with the association is ???   We, needless to say &#8211; we did not close</p>
<p>How did we find out about this odd situation &#8211; we did our due diligence and found out the problems that were unknown to either the listing agent, the buyer’s agent or the title company? So for a period of time our phones will be forwarded to a web based phone services and we will have to work in disjointed fashion as I scramble to find a new suitable location.</p>
<p>I am also reminded of the AMA article I read some years ago.  It was a poll taken from companies that had recently moved.   Of the “managers in charge” of the move &#8211; fully 2/3 were no longer with the company or had taken a demotion.   While one can plan and plan and plan &#8211; often one’s moving plans do not survive the encounter with the many seemingly random externalities of a given move.</p>
<p>This encounter with a property purchase and a move also reminds me of the phrase, you know what you know, you know what you don’t know &#8211; and you don’t know what you don’t know.   Due diligence helps with all three possibilities, but yet still one must find a way to plan for the unplanned.</p>
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		<title>How to Write a Policy Manual</title>
		<link>http://www.aegisjournal.com/bsa-aml-ofac/how-to-write-a-policy-manual/2012/02/</link>
		<comments>http://www.aegisjournal.com/bsa-aml-ofac/how-to-write-a-policy-manual/2012/02/#comments</comments>
		<pubDate>Wed, 01 Feb 2012 18:39:12 +0000</pubDate>
		<dc:creator>aegisadmin</dc:creator>
				<category><![CDATA[BSA, AML, & OFAC]]></category>
		<category><![CDATA[AML Policy Manual]]></category>

		<guid isPermaLink="false">http://www.aegisjournal.com/?p=4167</guid>
		<description><![CDATA[In the last several seminars we have conducted, as well as clients we have visited, a consistent constant question has arisen, How to write an effective policy manual? Well the [...]]]></description>
			<content:encoded><![CDATA[<p><strong>I</strong>n the last several seminars we have conducted, as well as clients we have visited, a consistent constant question has arisen, How to write an effective policy manual?</p>
<p>Well the first thing is to be honest with ourselves; companies steal <em>(make effective use of existing copy)</em> to compose the first version of the AML manual as well as several sections of the manuals of other companies.  Yep &#8211; you took what existed and began to adapt prior copies for your use, and that is OK.</p>
<p>The second is to cut from the manual those things you are not going to do.  If the manual says you are going to scan outgoing wire transfers for XYandZ and you are not going to and or your firm is not a bank &#8211; cut that part of the manual.  Seems simple, but if this were not a real problem &#8211; we would not have mentioned it.</p>
<p>Cut ALL adjectives and adverbs &#8211; if you need to color a situation &#8211; explain the color with out use of adjectives or adverbs.</p>
<p>Cut all words, nouns, verbs, etc…. that can be interpreted in different ways.  If you are required to use nouns and verbs that are vague, immediately footnote the word and explain how you are using this word in context.  I watched a large bank and the regulators got to battle over the meaning of the word “fiduciary”.  Honestly &#8211; there was not a wise mind in the room during that battle &#8211; geesh.</p>
<p>Avoid exclusionary words such as always and never. Never says that you will always do KYC research so you never get a bad client.  Nuff said.</p>
<p>If you describe an action you will take &#8211; do it.  If you are not going to do &#8211; do not say you are going to do it.  If you say you will scrub the list of client against the OFAC list every 30 days &#8211; do it.  Do not scrub the list on the 31<sup>st</sup> day, for you will have already violated you procedures set forth in you AML manual. Do not offer to do something every month.  Scrubbing your list of clients against OFAC on January 31 and than again on Feb 1 &#8211; is not effective and it looks like every two months based upon days.</p>
<p>AML policies are living documents, they change and are amended as the laws change as your business changes, as technology changes, etc…  For example, Molly drafted your AML policy and it was accepted by FINRA, FDIC, OCC and you insurance company.  Molly has done well and was promoted, and her spot in compliance was filled by Carl &#8211; call began to automate some of the work and thus changed the AML policy to reflect the automation.  Carl was hired away by an executive recruiting firm and  Lars was hired to replace Carl.  This is a common story for many very diligent people in compliance. Lars was on the job for 30 days when an event occurred and the regulators have come to see if you followed your policy.  They will have read the policy you on file with them and will be surprised to find that you have not followed your policy.  This is the beginning of a feeding frenzy for the inspectors for they live to find fault with anyone they investigative (I admit that is a dramatic overreach &#8211; well, kind of), but it is true that this is how many of the regulators think.</p>
<p>How does one avoid this &#8211; simple, but your diligence is still required.  Track all updates changes and why the policy was updated or changed.  Send copies of the update AML  Manuel to the appropriate regulatory authorities as well as your insurance company.  Thus all are informed and cannot say they were not informed of the changes.</p>
<p>This level of diligence is also impressive to both regulators as well as insurance carriers and should help in addressing any questions these stakeholders in your compliance might have, and demonstrate not just your honesty but also your authentic attention to detail and compliance.</p>
<p>&nbsp;</p>
<p>Companies get into trouble when they don’t have any processes, or when they have a process &#8211; but they don’t follow the process.</p>
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		<title>Help Your Employees Get Through Failure</title>
		<link>http://www.aegisjournal.com/books-product-reviews/help-your-employees-get-through-failure/2012/02/</link>
		<comments>http://www.aegisjournal.com/books-product-reviews/help-your-employees-get-through-failure/2012/02/#comments</comments>
		<pubDate>Wed, 01 Feb 2012 18:21:12 +0000</pubDate>
		<dc:creator>aegisadmin</dc:creator>
				<category><![CDATA[Books & Product Reviews]]></category>
		<category><![CDATA[Gail Kasper]]></category>
		<category><![CDATA[L. Burke Files]]></category>

		<guid isPermaLink="false">http://www.aegisjournal.com/?p=4160</guid>
		<description><![CDATA[By Gail Kasper, Author and Mentor of the Top 1% Club http://www.gailkasper.com I am sure many of you, like me, have had to lend a supportive ear to an employee [...]]]></description>
			<content:encoded><![CDATA[<p>By Gail Kasper, Author and Mentor of the Top 1% Club <strong><a href="http://www.gailkasper.com" target="_blank">http://www.gailkasper.com</a></strong></p>
<p>I am sure many of you, like me, have had to lend a supportive ear to an employee or associate. If you’re a manager, business owner or boss, you’re well aware that not every employee is a star performer. Some members of your team might struggle more than others. They may experience a greater incidence of failure. But even your best-performing employees will run into failure from time to time. That’s because where risk and success are involved; failure is part of the territory. As the boss or head of the team, you can take steps to help all of your employees – those who struggle and those who shine – get through failure and get back on track. First, review the steps of my Systematic Attitude Development-Technique™ (SAD-T™), a proven program for achieving extraordi-normal results. Then do the following:</p>
<p>1. Set up a meeting. Don’t let your employee languish in his or her misery and defeat. Saying nothing will only magnify your employee’s feelings of failure. Set up a meeting in your office to talk to your employee and help put things into perspective. Keep this a one-to-one, face-to-face meeting. Don’t bring others in, as this might prove intimidating.</p>
<p>2. Keep it logical. Be sure to keep your comments fair, kind and balanced. This is not the time to make your employee feel worse by bringing judgments and emotions into the conversation. Instead, talk about what’s working well, what needs improvement, and where to go from here. Point out the fact that all great successes are preceded by failures. It’s simply part of the learning curve. Without failure first, there is no ultimate success.</p>
<p>3. Define an action plan. The best way to defeat failure is to put a plan for success into action. What steps can your employee take to improve his or her performance? How can you help your employee do a better job? Would the employee benefit from taking classes, attending a seminar, reading a book, or working with a mentor? Together, you and your employee can develop an action plan designed to make them a winner.</p>
<p>4. Follow up. Every week, follow up with the employee to see how they’re doing. During these follow-ups, be sure to build your employee up by praising both effort and success. Modify the action plan as needed to maximize its effectiveness. Remain positive and optimistic, a source of encouragement. Once your employee is back on track, you won’t need to check back weekly, but do follow up from time to time. By staying in the loop, you’ll help resolve issues before they escalate, and your employee will know that they can count on your support, come what may.</p>
<div id="attachment_4161" class="wp-caption alignright" style="width: 350px"><a href="http://www.top1percentclub.com"><img class="size-large wp-image-4161" title="logo" src="http://www.aegisjournal.com/wp-content/uploads/2012/02/logo-340x115.jpg" alt="" width="340" height="115" /></a><p class="wp-caption-text">Gail Kasper&#39;s Top 1% Club</p></div>
<p>As the Top 1% Club Mentor, I invite you to be our guest <strong><a href="http://www.top1percentclub.com">http://www.top1percentclub.com</a></strong> and receive a list of 50 Ways To Fix Communication Mistakes: Essential Keys To Improve How You Communicate With Others.</p>
<p>&nbsp;</p>
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		<title>Compliance Failures Promote Fraud and Blackmail</title>
		<link>http://www.aegisjournal.com/due-diligence/compliance-failures-promote-fraud-and-blackmail/2012/01/</link>
		<comments>http://www.aegisjournal.com/due-diligence/compliance-failures-promote-fraud-and-blackmail/2012/01/#comments</comments>
		<pubDate>Mon, 02 Jan 2012 02:33:15 +0000</pubDate>
		<dc:creator>aegisadmin</dc:creator>
				<category><![CDATA[Due Diligence]]></category>

		<guid isPermaLink="false">http://www.aegisjournal.com/?p=4138</guid>
		<description><![CDATA[Over the last several years we have noticed an interesting development in the world of fraud.  This is a bit of a follow up to a “Get out of Jail [...]]]></description>
			<content:encoded><![CDATA[<p>Over the last several years we have noticed an interesting development in the world of fraud.  This is a bit of a follow up to a <a href="http://www.aegisjournal.com/opsec-economic-espionage-competitive-intelligence/get-out-of-jail-free/2010/11/">“Get out of Jail Free”</a> article from November 2010 issue of the Aegis Journal.</p>
<p>It seems the fraudsters, often inside a company’s compliance or internal audit department, have taken it upon themselves to print their own &#8216;Get Out Of Jail Free&#8217; cards.  These fraudsters often have many years with a company and are valued and trusted employees. Their frauds begin with the employee finding that the company is out of compliance.  While we focus on AML and OFAC issues, non-compliance issues often include rules and regulations the employer may not even know exist, such as environmental, disclosure, or Fair Labor Act compliance.</p>
<p>Fraudsters quickly realize that their unique position within the company allows them to document these violations in great detail, and in some cases the fraudsters may even facilitate the continuation of the violations.  Once the fraudster has documented and secured the required evidence &#8212; they are now free to defraud the company.  Often the level of skill in finding a compliance violation, or helping it along, requires more sophistication than perpetrating a fraud.  Why?  It&#8217;s simple.  There is little motivation to work on concealment of the fraud.  If the fraud is discovered, they can report the company under whistle blower statutes, and the fraudsters may even collect 30% of the total fine imposed on the company (often more lucrative than the fraud).  If the company accuses the whistleblower of fraud &#8212; the company is accused of retaliation &#8212; yet another expensive legal claim to defend.</p>
<p>Many frauds using this odd form of protection are the direct result of a compliance error. The error and the corporate fear of fines and repercussions from regulators are used by fraudsters as a shield against being prosecuted for their fraud.  This is blackmail, short and simple.</p>
<p>It can be avoided, but it&#8217;s not easy.  Government’s have not made voluntary disclosure of non-compliance (or compliance error) a favorable option for most enterprises.  The lack of forgiveness by the governments is what promotes the essential environment for the blackmail/fraud scenario to succeed.  Since the regulatory enforcement climate is not going to change any time soon, employers have to look at prevention.  Prevention is best accomplished with outside experts reviewing compliance issues on a periodic basis.  Audits may be required every few months if the regulations are rapidly changing, or as infrequent as every few years if the regulations are more seasoned.</p>
<p>Keep internal audit and compliance apart – with no overlap.  Also eliminate individual fiefdoms within the company, encouraging more than one person or department to review compliance issues.  When conducting internal audits, don&#8217;t focus solely on financial matters &#8212; include compliance, disclosure, and reporting requirements.  Establish employment agreements that have real penalties for fraud, for example, allowing retirements to be clawed back if fraud by an employee is substantiated, or bonus money to be repaid, etc&#8230;</p>
<p>Last, but not least, if a fraudster pulls a stunt similar to this on you &#8212; attack, do not submit.  Work with your experts on voluntary disclosure to the regulators, and assume that the fraudster engineered the setup.  It will be difficult, ugly, and painful &#8212; but it will be over.<strong></strong></p>
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		<title>China’s Legacy Bonds</title>
		<link>http://www.aegisjournal.com/opsec-economic-espionage-competitive-intelligence/china%e2%80%99s-legacy-bonds/2012/01/</link>
		<comments>http://www.aegisjournal.com/opsec-economic-espionage-competitive-intelligence/china%e2%80%99s-legacy-bonds/2012/01/#comments</comments>
		<pubDate>Mon, 02 Jan 2012 02:20:13 +0000</pubDate>
		<dc:creator>aegisadmin</dc:creator>
				<category><![CDATA[OPSEC, Economic Espionage & Competitive Intelligence]]></category>

		<guid isPermaLink="false">http://www.aegisjournal.com/?p=4131</guid>
		<description><![CDATA[I have been fascinated over the past several years by traffic in Post 1911 Chinese Bonds.  Not the numismatic traffic &#8212; but the traffic creating fiscal terror perpetrated by people [...]]]></description>
			<content:encoded><![CDATA[<div id="attachment_4133" class="wp-caption alignright" style="width: 323px"><img class="size-full wp-image-4133 " title="China Bond 1911" src="http://www.aegisjournal.com/wp-content/uploads/2012/01/China-Bond-1911.tiff" alt="" width="313" height="423" /><p class="wp-caption-text">China Bond 1911</p></div>
<p>I have been fascinated over the past several years by traffic in Post 1911 Chinese Bonds.  Not the numismatic traffic &#8212; but the traffic creating fiscal terror perpetrated by people who claim these Chinese legacy bonds are valid obligations and that the Chinese Government is going to pay.</p>
<p>When China’s 2,000 plus years of monarchical rule was overthrown in 1911, The Republic of China was born.  During the period between 1911 and 1949, the new Republic&#8217;s efforts to gain economic traction were hobbled by two world wars and Japanese colonial ambitions.  After expelling both the Japanese and the criminal running the Chinese government, the communists arrived&#8230;</p>
<p>In theory, as the Communists gained control of the mainland, the Republic of China relocated (and exists to this day) on the island of Taiwan.  In theory.</p>
<p>During this transitional period, from 1911 to 1949, hundreds of millions of dollars in bonds were sold to Western investors betting on China’s future.</p>
<p>These bonds issuances were;</p>
<p>1911 5% Hukuang Railways<br />
1912 5% Crisp Gold Loan 1912<br />
1913 5% Lung-Tsing-U-Hai Railway<br />
1913 5% Reorganisation Loan<br />
1914 5% French Industrial Gold Loan<br />
1918 8% Marconi Loan<br />
1919 8% Vickers loan<br />
1919 6% 2-Year Gold Loan Treasury Notes<br />
1920 8% Lung-Tsing-U-Hai Railway Loan<br />
1921 8% Lung-Tsing-U-Hai Railway Loan<br />
1922 8% Railway Equipment Loan<br />
1923 8% Lung Tsing U Hai Railway Loan<br />
1925 5% (French Boxer Indemnity) Rep US Gold<br />
1925 8% Lung-Tsing-U-Hai Railway Loan<br />
1925 8% Skoda Loan II<br />
1934 6% British Boxer Indemnity<br />
1936 6% Shanghai Hangchow Ningpo Railway Completion Loan<br />
1937 4% Liberty Bond<br />
1938 5% 27th Year Gold Loan<br />
1940 5% 29th Year Gold Loan</p>
<p>(From  <a href="http://chinahistoricbonds.com/">http://chinahistoricbonds.com/</a>  )</p>
<p>These massive bond offerings, widely acquired by governments, banks, and investors across the globe, funded the modernization of China’s infrastructure.  Who were the underwriters of these bonds?  J.P. Morgan, HSBC, Deutsche Bank, Kuhn Loeb &amp; Co., the First National Bank of the City of New York, and the National City Bank of New York &#8212; you know, the usual suspects.</p>
<p>While the bonds represented a binding engagement upon the government of The Republic of China, and its successors, China defaulted in 1938 and left millions of global creditors unpaid even to this day.  According to the terms of the bonds, the holders can hold modern day China accountable for these obligations &#8212; but any help the bondholder might expect from their respective government has been on hold since 1938.</p>
<div id="attachment_4134" class="wp-caption alignright" style="width: 230px"><img class="size-medium wp-image-4134" title="1923 Chineese Bonds" src="http://www.aegisjournal.com/wp-content/uploads/2012/01/1923-Chineese-Bonds-220x297.gif" alt="" width="220" height="297" /><p class="wp-caption-text">1923 Lung Tsing U Hai Railway Railways</p></div>
<p>The Chinese are experts at interpretative history.  Arguing history and facts with the Chinese government is like playing cards with a five year old &#8212; the facts change as it suits their interest.  To the Chinese, history is malleable, and historical narrative is as much a product of current political considerations as it is a chronicle of past events.</p>
<p>As an heir to the recently celebrated 1911 revolution, why did the Chinese government choose to avoid paying their international debt?  In short, the mainland of China states that The Republic of China is on Taiwan &#8212; and the debt is theirs (despite proclamations that there is only one China).  Contradicting this position is the historical record &#8212; which indicates that all of the borrowing, banking, and investments were on Mainland China.  In any case, virtually none of the bonds have been paid.  I believe this may have been the origin of the phrase &#8220;a giant sucking sound,&#8221; but don&#8217;t quote me on that.  In acknowledgement of the debt, a few of these bonds held in the UK were paid (pennies on the dollar) during the 1980 negotiations on the return of Hong Kong.</p>
<p>Mainland China recently celebrated 100 years of history since 1911, and the current government claims to be heir to the revolution. Yet, mysteriously, there is no acknowledgement of these unpaid debts.  By international law these debts cannot be repudiated, they must be litigated on a country-by-country / county-to-country basis (as citizens have no standing to sue a sovereign nation).</p>
<p>Bondholders in the U.S. can petition the US Foreign Bond Holders Protective Council (created by law in 1933 to settle debts from WWI).  The State Department sponsored the law creating the Council in the belief that it would facilitate settlements agreeable to both debtors and creditors.  It appears to have been a failure upon inception, an analysis supported by the fact it held its last meeting in the 1980&#8242;s.</p>
<p>For those intrigued by other bonds games you can&#8217;t win – following is an interesting legal position.  <a href="http://www.globalsecuritieswatch.org/may30_2003_memo.pdf">http://www.globalsecuritieswatch.org/may30_2003_memo.pdf</a></p>
<div id="attachment_4135" class="wp-caption alignleft" style="width: 230px"><img class="size-medium wp-image-4135" title="China LIberty Bond" src="http://www.aegisjournal.com/wp-content/uploads/2012/01/China-LIberty-Bond-220x161.jpg" alt="1937 Liberty Bond" width="220" height="161" /><p class="wp-caption-text">1937 Liberty Bond</p></div>
<p>Unpaid debt by a sovereign government is nothing new – just another chapter in a series of sovereign defaults plaguing investors over the past few hundred years.  To those who see this as news, and believe they hold valuable bonds, take it as a warning – many possess only a numismatic value.</p>
<p>It is worth noting that FE&amp;E, Inc. has been hired several times to investigate funds that are buying these bonds and claiming them as assets at face value enhancing the value of that fund. We have seem these bonds proffered as security for loans or as assets backing insurance companies.  The fact that these bonds <em><span style="text-decoration: underline;">could</span></em> be collected has prompted several people to claim that these bonds are worth face value as their are viable financial instruments and can be negotiated.  In reality, they represent beautiful artwork and a lesson in history.</p>
<p>Please check out the links in this article if you are looking to purchase these bonds for numismatic value.  Please call us if you are looking to purchase them as an investment (Now <em><span style="text-decoration: underline;">that&#8217;s</span></em> full disclosure)!</p>
<p>&nbsp;</p>
<p>Much thanks to the folks at www.HistoricalBonds.com for images and information.</p>
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		<title>Back to The Basics</title>
		<link>http://www.aegisjournal.com/executive-protection-2/back-to-the-basics/2012/01/</link>
		<comments>http://www.aegisjournal.com/executive-protection-2/back-to-the-basics/2012/01/#comments</comments>
		<pubDate>Mon, 02 Jan 2012 02:17:35 +0000</pubDate>
		<dc:creator>aegisadmin</dc:creator>
				<category><![CDATA[Executive Protection]]></category>

		<guid isPermaLink="false">http://www.aegisjournal.com/?p=4129</guid>
		<description><![CDATA[Executive Protection is a physical endeavor, even when nothing eventful occurs.  In my many years, as an EP professional, consultant, and trainer &#8212; I have seen several mistakes repeated by [...]]]></description>
			<content:encoded><![CDATA[<p>Executive Protection is a physical endeavor, even when nothing eventful occurs.  In my many years, as an EP professional, consultant, and trainer &#8212; I have seen several mistakes repeated by good people who simply forgot.</p>
<p><strong>Keep Hydrated. </strong>Remember to drink water (not soda or coffee).  This is so simple to do, and yet we often get busy, or pressed for time, and we forget.  The first symptoms of dehydration are dry mouth, followed by weakness and painful muscle cramps.  If you know you are going to have a busy day, preload with water &#8212; drink a litre before you even leave your room, and keep extra water around just in case.  We are likely to become dehydrated in desert conditions for two reasons, our sweat evaporates as it leaves our pores, making us unaware that we are perspiring, and we lose even more water just by breathing in the dry air.  I have been in desert conditions where I&#8217;ve consumed several gallons of liquid and never had any need to relieve myself.  Preload, keep loading, and keep moving.</p>
<p><strong>Eating Poorly. </strong> Being on the move means limited fare – the offerings are frequently limited to pub grub or fast food.  Realizing you may not be able to find balanced nutrition on the road, stock up on some protein bars and choose salads when you can.  Make sure you have fiber tablets with you, such as oat bran, and stay away from heavy fats and carbs.</p>
<p><strong>Muscle Spasms</strong> can be brought on when you are in one position for too long (such as sitting in an airplane, car seat or at your post), by a lack of electrolytes (particularly calcium), and fluid, or when muscles are overexerted in a hot environment.  Diabetes and anemia are aggravating factors.  Inactivity combined with pressure on one point of the body, arm, lower back, or thigh (such as, sitting) can constrict the blood flow and cause a temporary loss of fluid and electrolytes to muscles, triggering a cramp. What’s the secret to avoid spasms?  Being aware of the possibility before you deploy.  If you have had spasms in the past – be aware of what has precipitated those problems and prepare with proper gear or supplements.</p>
<p><strong>I Forgot Something.  </strong>This is a common distraction.  It might be dress clothes, cufflinks, the car keys, prescriptions, eyewear, or simply giving the family your itinerary.  I use these examples because I have forgot all of them in the past.  This may sound trivial, but checklists do help.  Items can be updated as needed &#8212; but it really helps to have a list.  In time, you can create a universal list that allows you to simply eliminate what you&#8217;re not going to need.  This is not that big of an issue when traveling between 1st world locations &#8212; but when you&#8217;re deployed to a remote or underdeveloped location, any missing item can become unnecessarily troublesome.</p>
<p><strong>Attitude</strong> can always become an issue as we tire of bad food, muscle pains, and strange lodgings.  Add to this mix the normal airport charades and the logistics of coordinating multiple security teams &#8212; and attitude can become a real issue.  We need to remember that an upset is either an unfulfilled expectation or a thwarted intention.  If we simply align our expectations and communicate our intentions better, we will have fewer upsets. Working with fewer upsets helps us to enjoy what we do a little bit more, and when we enjoy our work, we do it better.</p>
<p>I have seen these five basic elements of readiness cause more problems to EP professionals than any other items I can recall &#8212; even more than the externalities our clients have retained us to manage.</p>
<p>File under: Mind the basics and get back to work.</p>
<p><strong>The 6th item&#8230;</strong></p>
<p>Please don’t forget what is left behind when you are working.  Your friends and family imagine that you are in the lap of luxury while seeing parts of the word many only dream about.  Communicate home at every opportunity, and remind family and friends why you return &#8212; as it&#8217;s the best part of the journey.</p>
<p><em><br />
</em></p>
<p><em>This Executive Protection article was written or edited by Barron James Shortt, the Executive Director of the IBA.  </em><a href="http://www.ibabodyguards.com/"><em>http://www.ibabodyguards.com</em></a><em></em></p>
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