Monthly Archives

February 2017

Sat on Timebomb

Californian based bank, Merchants, fined $7,000,000.00 for impeding compliance staff.

The Financial Crimes Enforcement Network (FinCEN) Monday fined Merchants Bank of California $7 million for impeding compliance staff and threatening to fire staffers who wouldn’t process suspicious transactions.

Merchants Bank didn’t give compliance staff “the necessary level of authority, independence, and responsibility” to run the anti-money laundering program. For example, customers from high-risk jurisdictions weren’t flagged or subjected to required diligence.

Many of the bank’s unreported suspicious transactions were conducted on behalf of money services businesses owned or managed by Merchant Bank insiders. The insiders “encouraged staff to process these transactions without question or face potential dismissal or retaliation,” FinCEN said..

Bank insiders also directly interfered with the AML staff’s attempts to investigate suspicious activity related to the insider-owned accounts, according to FinCEN.

Full article courtesy of FCPA Blog here


False Confession

Amanda Knox: Why Do Innocent Women Confess to Crimes They Didn’t Commit?

“What we think in this situation,” said the first detective, “the other babies are screaming, crying, whatever. You’re taking care of them by yourself. You have Ben in your hands, he starts acting up and, you get mad at him and you throw him on the floor.”

“You threw him on the floor?” asked the second detective.

Transfixed by her accusers, Melissa nodded, “Yeah.”
What a great example of inappropriate investigative interviewing, particularly impactive when interviewing a vulnerable interviewee, yet advocated, indeed even encouraged, by some interviewing models preferred in many countries.
By all means have (and try to verify) a working hypothesis but to frame it in such a forensically inappropriate (leading) question is wrong.
Some interview ‘models’ encourage confession culture, permitting deceit to secure it, a most dangerous place without checks and balances.
The PEACE framework (for framework is what it is) originating in the UK in the early 1990s goes some way to secure against this but exponents of the framework who are neither current nor understand its subtleties are misguided to take a view that it is a ‘cure-all’ for global miscarriages of justice. It is not a ‘one size fits all’, ‘one stop’ solution, but a framework within which several models of interviewing are practised by the skilled and competent flexible interviewer.
“Melissa’s arrest, prosecution, and conviction relied exclusively upon her false confession,” Kathleen Zellner, Calusinski’s post-conviction attorney, explains.
In February 2016, when asked why she confessed, Calusinski struggled to explain: “The only way for me to get out of there was basically what they wanted.”
At Intersol we take enormous pride in our global reputation, in continuing to develop and practice cutting edge empirically proven techniques. We don’t treat interviewing as simply an adjunct to the investigation but as a golden-thread woven through the entire case management process, so if you really want to understand the complexities of PEACE, of investigative interviewing and its impact on any investigation process, we are your ‘go-to’ entity.



Are non-technical skill-sets of value to auditors?

Nobody doubts the technical skills of auditors (internal or external), they’re inevitably highly qualified and competent in accountancy, economics, or law, perhaps an IT degree or business skill. They undoubtedly have that technical knowledge but have they been supported with the non-technical (dare I say ‘soft’?) skill development that complements and effectively applies the former in the workplace during the fieldwork, meeting, and reporting phases?

Our global experience is an emphatic ‘NO’! Until now that is. At the end of a week that has now seen us train over 500 auditors globally in the skill of effectively managing audit meetings (investigative fact-finding conversations), Canada, North America, and Ireland this week alone, the universal feedback of auditors is that they ‘wished they’d had this training years ago’ at the outset of their audit career.

Our world-class team of associates and partners have developed a series of training courses and workshops that add significant value to the audit role meaning that at last they can be perceived as a business essential, an asset that adds real and tangible value to an organisation not just unwelcome cost.

But we didn’t stop there, we haven’t simply mapped over and force-fed the audit community a solution that had little relevance and meaning, we added context mixed with proportionality, relevance, and added subject matter expertise, securing feedback that has been universally and without exception excellent.

Neither did we stop here! Not satisfied with that, and taking notice of auditors feedback that they didn’t need any more degrees but would relish a vocational and transferrable skill to enhance their careers, we’ve developed and released one!

Harnessing the many and varied skills of Intersol associates we have now released the first global qualification for auditors to achieve a level 3 in managing audit conversations (investigative interviewing for auditors). No, it’s not a degree, it’s not purely academic, but it is a fascinating mix of real life conversation management, the psychology of human interaction, life skills, blended with a bit of investigative competence, forensic questioning techniques, listening skills, and models, finished off with a light touch of detecting deceit and lies, all underpinned by cutting edge empirical research, decades of practical experience, and the imperative to work within an institution and provide added value and worth (and to be seen by ALL stakeholders to be doing so!).

Did we stop there? NO! Not satisfied with that, and listening intently to our clients, we invested in a virtual learning platform and put as much as we could into a blended virtual learning environment to enable flexibility of delivery, minimise workplace abstraction, and maximise value. All this accredited (and audited ironically!) by Ofqual in the UK and supported by Skillsfirst. We became an officially accredited virtual adult learning centre and added more qualifications for investigators and workplace (HR) interviewers and will grow the centre to be a resource of excellence for any entity that puts a value on Extraordinary Case Management (ECM®) with interviews (meeting conversations) at their core.

If you’d like to know more, perhaps be one of the first to set yourselves apart from global competition, if you want the ‘gold standard’ please feel free to drop us a line at and we’d be delighted to explain more.

Best wishes,

All at IG.