money laundering and terrorist financing: what are the...
TRANSCRIPT
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Money Laundering and TerroristFinancing: What are the
Criminals up to Now?
August 27, 201012:00PM – 2:00PM EDT
Panel is in Practice Session
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Welcome to the ACAMS Web Seminar:
Money Laundering and Terrorist Financing: What are the Criminals
up to Now?
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Money Laundering and Terrorist Financing: What are the Criminals up
to Now?
August 27, 2010August 27, 2010
Dennis M. LormelPresident & CEO
DML Associates, LLC
Jeff BreinholtCounsel for Law & PolicyNational Security DivisionU.S. Department of Justice
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• Background
• Terrorist Groups and Their Financial Requirements
• Criminal – Terrorist Nexus
• Current and Emerging Trends
• Money Laundering & Terrorist Financing
• Right to Financial Privacy
• BSA Information Facilitates Investigations
• Conclusion
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Background
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Current Terrorism Threat in U.S.
On April 15, 2010, Director Robert S. Mueller testified before the Senate Committee on Appropriations, Subcommittee on Commerce, Justice, and Related Agencies. Regarding terrorism, he stated:
“Terrorism, in general, and al-Qaeda and its affiliates in particular, continue to leverage proven tactics and tradecraft with adaptations designed to address its losses and the enhanced security measures of the United States. Al-Qaeda seeks to infiltrate overseas operatives, who have no known nexus to terrorism, into the United States using both legal and illegal methods of entry…”
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Compliance Concerns• Adaptations (adaptability)
– Risk recognition
• Al-Qaeda seeks to infiltrate overseas operatives, who have no known nexus to terrorism, into the United States (anonymity)
– Know your customer
• What if…
– Terrorist group succeeds with attack in U.S.
– You banked them
• Potential adverse impact to bank
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Importance of Due Diligence• Risk recognition
– Mitigation– Adaptability
• Living process
• Know you customer program– Sound process– Verification
• Investigations– Consistency– Documentation
• Suspicious activity reporting– Most serious compliance breakdown
• Comprehensive• Importance
• Financial intelligence
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Terrorist Threats Are Enhanced by…
• Adaptability
– Learning organizations
– Exploitation of systemic vulnerabilities
• Knowledge and learning important
• Anonymity
– Avoiding detection
– Facilitates operational success
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AML: Current Risk Issues• Risk recognition
– Risk assessment
• Know your customer (KYC) program• Risk mitigation
– Non-static process– Adaptability and exploitation factor– Cyclical nature
• Suspicious activity reporting (SAR) process– Importance of investigations
• Diminished capacity• Vigilance
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Terrorist Financing• Extremely difficult to identify
– Coordination– Innovation– Training
• Not adequately understood– Four elements must be considered
• Terrorist groups• Funding capacity• Financial mechanisms• Individuals, entities and cells
• Perspectives– Government– Industry
• Possibility v. probability of detection– Detection possible but not probable– Must develop mechanisms to increase probability
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Disruption of Funding Flows • Back to origin / forward to strike teams
– Funding to networks / organizations from point of origin
– Funding to operations• International organizational support• Support of specific activities / operations
– Funding to individuals, cells, or groups
Mohamed AttaKSM
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Terrorist Groups and Their Financial Requirements
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Understanding & Disrupting Funding Flows• Must understand four dimensions
– Organization– Funding Capacity
• Source of funds• Money laundering method• Availability of funds
– Funding mechanism• Formal financial system• Informal system
– Group members• Funding cycle
– Raise– Move– Store– Spend
Raise
Store
Move
Spend
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Types of Terrorist GroupsFBI assessment issued January 11, 2007, identified the following groups as threats to the U.S.:
• Al-Qaeda
• Regional terrorist groups aligned with Al-Qaeda
• Homegrown cells
• Shia extremists
• Palestinian terrorist groups
• Domestic terrorist groups
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Inspire Magazine• English language online magazine published by
Al Qaeda in the Arabian Peninsula (AQAP)
– First issue July 2010
• Resource manual
– Offers blueprint for planning and executing terrorist
attacks in the West against the U.S.
• Provides explicit detail
• Recruitment tool to cultivate homegrown jihadists
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• Operation Smokescreen– Hizballah fundraising cell led by Mohamed Youssef Hammoud– Cigarette smuggling from Charlotte to Detroit
• Front / shell companies• False identifications / fraudulent visas• Approximately 500 bank accounts and credit cards
– 25 convictions• Four indicted for conspiring to support Hizballah
– Six others charged with related crimes– Philadelphia, Pennsylvania– Agreed to purchase approximately 1,200 Colt M-4 carbines, sold counterfeit currency, fraudulent
passports and counterfeit goods• Tri-Border Electronics Case 2010
– Four individuals and three freight forwarding companies indicted for illegally shipping electronics equipment from Miami to a Hizballah controlled shopping center in Ciudal del Este, Paraguay
– Owned by Muhammad Yusif Abdallah, senior Hizballah leader in South America– Used fake invoices, false addresses and fictitious consignees to conceal true destination of
shipments
Support to Hizballah from U.S.1995 - 2000
2008 - 2009
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Criminal – Terrorist Nexus
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Terrorist and Criminal Groups• Must have continuous stream of funds available
– Must have capacity to raise funds
• Fraud and money laundering often key – Nexus between fraud and money laundering
• Drug trafficking the most lucrative criminal activity • Must have immediate access to funds• Pose threat to national security and economy
– Importance of disruptive and preventive measures
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Criminal Activity• Terrorists increasingly rely on criminal activity to raise funds
– Makes them more vulnerable
• Terrorists are adept at exploiting systemic vulnerabilities to facilitate and commit crimes – They are only limited by their imagination
• Investigators should remain vigilant for criminal activity whichcould be linked to terrorism
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OC Traits Adapted by Terrorists• Terrorists rely on OC techniques
– Corruption
– Intimidation
– Violence
• Greed v. ideology
– Emergence of hybrid organizations
• Reliance on shadow facilitators
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Drug Trafficking and Terrorism: A Growing Nexus
• Nexus between drugs and terror growing at light speed
• DEA linked 19 terrorist organizations to global drug trade
• DEA believes up to sixty percent of terrorist organizations connected to illegal narcotics trade
• As terrorist organizations become more involved in drug trade, hybrid organizations are emerging
– Morphed into one part terrorist organization, one part global drug trafficking cartel
• Taliban
• FARC
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OC-Terrorism Nexus• Organized crime groups are incorporating
characteristics and methods of operations from terrorist groups
• Terrorist groups are adopting strategies learned from organized crime
• This evolution makes both groups stronger and more flexible
• Tri-border region example
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OC – Terrorism ComparisonOrganized Crime
• Motivated by profit/greed• Seek economic ends• Engage in corruption• Network and cell based structure• Require safe-havens• Need to recruit new members• Requires specialists• Group identity important• Threat of violence• Select targets that pose threat to the
group• Avoid public attention• Money laundering essential operating
tool
Terrorist Groups• Motivated by ideology • Seek political ends• Engage in corruption• Network and cell based structure• Require safe-havens• Need to recruit new members• Requires specialists• Group identity important• Threat of violence• Select symbolic
targets • Seek public attention• Money laundering essential
operating tool
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Current and Emerging Trends
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Trends in Financial Market• Innovation drives opportunity
• Innovation drives vulnerability/exploitation– Increased use of electronic transfers
– Increased use of technology (advances in technology)• Internet
• Mobile devices
– Increased use of credit/debit cards
– Decreased use of checks
– Decreased use of currency
• Changing regulatory/compliance environment
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Rise of Electronic Payments• Moving toward elimination of cash and checks• Setting the stage for mobile commerce• Upward Trend
2000 2005 2010Cash 19% 18% 15%Check 46% 33% 13%Debit Card 7% 12% 30%Credit Card 24% 26% 28%Electronic Transfer 4% 11% 14%
• Where is the forward thinking?– Law enforcement, regulators and compliance professionals should be
forward thinking• Identify/assess future trends• Identify areas of vulnerability• Develop methodologies to minimize exploitation
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New Payment Methods
• Services that provide virtual accounts– Stored value cards
– Online payment services (Paypal)
– Digital currency (e-Gold Ltd.)
– Mobile payments
– Online virtual world transactions
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The Threat• Anonymous
• Untraceable
• Reusable
• Universally accepted
• Requires no intermediary
• Instant settlement
– The closer an electronic payment method comes to mimicking cash, the greater the money laundering and terrorist financing threat
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Terrorist Exploitation of the Internet
• Psychological warfare
• Propaganda
– Recruitment
• Fundraising
• Communications
• Information gathering
– Training
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Internet / Cyberfraud• Ranging from credit card fraud to money laundering• Terrorists can be extremely internet savvy
– Imam Samudra• Mastermind of Bali bombing• Jailhouse manifesto “Hacking, Why Not”
– Ali Al Marri• Al-Qaeda facilitator for post 9/11 activity in U.S.• Internet expert
– Younes Tsouli aka Irhabi (Terrorist) 007• Used email and radical websites for propaganda and
communications• Committed massive cyber crime and credit card fraud
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Future Trends• As society moves away from cash/checks so will
the bad guys– Will gravitate to electronic mechanisms
– Will identify new vulnerabilities to exploit
• Law enforcement, regulators and compliance professionals must identify and implement mechanisms to mitigate areas of vulnerability rife for exploitation
• Proactive vs. reactive– Communication, cooperation, coordination
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Mexico’s Dollar Deposit Restrictions• On June 10, 2010, Mexico established rules to limit U.S. dollar
deposits in Mexican banks – Individual and corporate customers USD $4,000 per month– Non-account holders USD $300 per day and $1,500 per month
• Intended to stem flow of narcotics trafficking funds into Mexican financial institutions
• Supposed to be enforced in September, 2010• Will cause surge in deposits in U.S. and South America
– Surge in U.S. will not just be along Southwest border– Will include money funneling points in big cities and regional
centers• Could serve as catalyst for Mexican Drug Cartels to move from
cash to new payment methods
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Exploitation of Systemic Vulnerabilities• Terrorist and criminal organizations constantly exploit
systemic vulnerabilities• Vulnerabilities or high risk areas in the financial services sector
August 27, 2010
▫ Fraud
▫ Money LaunderingWire transfer
October 3, 2001*
▫ Wire Transfer
▫ Correspondent banking
▫ FraudCorrespondent banking
Illegal money remitters/hawalas
Shell companies
▫ MSBs
* Lormel testimony before House Committee on Financial Services
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Lloyds TSB “Stripping” Case• Lloyds entered deferred prosecution agreement with Manhattan District
Attorney and U.S. Department of Justice on January 9, 2009– Had correspondent relationships with banks on OFAC sanctions list to
include banks from Iran and Sudan
– Established policies and procedures to systematically “strip” (remove) SWIFT messaging instructions to ensure U.S. banks did not identify institutions on OFAC list
• U.S. banks led to believe bank of origination was Lloyds and not Iranian or Sudanese banks
▫ Evaded OFAC monitoring filter
– “Stripped” out identifying features allowing Iranian banks and their customers to wire transfer more than $530 million from 2001 to 2004
• Violation of the International Emergency Economic Powers Act (IEEPA) and New York state law
• Lloyds paid a $350 million fine
• Nine other international banks under investigation
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Credit Suisse Case• Credit Suisse entered deferred prosecution agreement with Manhattan
District Attorney and U.S. Department of Justice on December 16, 2009– Beginning as early as 1995, and continuing through 2006, Credit Suisse in
Switzerland and the U.K., altered wire transfers involving U.S. sanctioned countries or persons
• Deliberately removed material information, such as customer names, bank names, and addresses from payment messages so that wire transfers would pass undetected through filters at U.S. financial institutions to evade OFAC monitoring
• “Stripped” out identifying features allowing Iranian banks and their customers to wire transfer more than $530 million from 2001 to 2004
• Trained its Iranian clients to falsify wire transfers so that such messages would pass undetected through the U.S. financial system
• Moved hundreds of millions of dollars through the U.S. financial system
• Violation of the International Emergency Economic Powers Act (IEEPA) and New York state law
• Credit Suisse paid a $536 million fine
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Barclays Bank
• August 16, 2010: Barclays entered into a deferred prosecution agreement with the government, agreeing to pay $149 million each to U.S. and State of New York.
• Acknowledged violating U.S. financial sanctions imposed on Cuba, Iran, Sudan and Burma.
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650 Fifth Avenue• 36 story office building located in upscale section of New York City• Built in 1970s by Pahlavi Foundation
– Non profit charitable organization associated with Shah of Iran– Bank Melli (Iran) provided $42 million in financing– Alavi Foundation successor to Pahlavi Foundation
• Alleged links to Iran• Building valued at $560 million• Alavi Foundation transferred an ownership interest in building to Assa Corporation in
conjunction with Bank Melli cancelling building loan• Assa Corporation owned by Assa Company Limited a Jersey, Channel Islands shell
company• Assa Company Limited owned by Bank Melli• In December 2008, Alavi Foundation owned 60% of building and Bank Melli owned 40%
through Assa Corporation• On December 17, 2008, FBI seized 40% of 650 Fifth Avenue
– In accordance with International Emergency Economic Powers Act (IEEPA)
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Iranian Fronts• Alavi Foundation
– Controlled and operated by Iranian Government• Provided numerous services to Iranian Government• Ran a charitable organization for the Iranian Government• Transferred funds from 650 Fifth Avenue Company to Bank Melli
• Assa Corporation and Assa Company Limited– Shell companies owned by Bank Melli
• Provided numerous services to Bank Melli in contravention of IEEPA and Iranian Transactions Regulations
• On December 19, 2008, Farshid Jahedi, then President of the Alavi Foundation, was arrested for obstruction of justice.– Allegedly destroyed documents required to be produced under
Grand Jury Subpoena concerning the Alavi Foundation’s relationship with Bank Melli and the ownership of 650 Fifth Avenue.
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Amended Charges• On November 12, 2009, the U.S. Attorney’s Office, Southern
District of New York, filed an amended civil complaint to forfeit the remaining 60% ownership interest in 650 Fifth Avenue held by the Alavi Foundation
• In addition to the building, the amended complaint seeks forfeiture of
– All other assets of the Alavi Foundation and AssaCorporation
• Bank accounts owned by 650 Fifth Avenue Company, the Alavi Foundation and Assa Corporation
• Real properties owned by the Alavi Foundation in New York, Maryland, Virginia, Texas and California
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Illegal Money Remittance Business • Abad Elfgeeh
– American citizen born in Yemen
• Carnival French Ice Cream Shop– Annual average revenue about $185,000– Illegally wired $22 million overseas
• Mostly to Yemen
• Used account with a major bank to wire money overseas
• Illegally transferred money for Sheik Mohammed Ali Hassan al-Moayad
– Al-Qaeda and Hamas fundraiser/supporter– Ties to Osama bin Laden
• Elfgeeh claimed he was not running unlicensed money transfer business but providing a “community service”
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Money Laundering&
Terrorist Financing
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Money Laundering: Understanding the Enemy
• Terrorists– Threat to National
Security
– Motivated by ideology
• Criminals– Threat to the Economy
– Motivated by greed
• Profit
• Power
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The Process
Terrorist FinancingMoney Laundering
Legitimate Funding ORIllegitimate FundingIllegitimate Funding
Funds deposited into financial system
Placement
Funds moved to other institutions to obscure origin
Layering
Integration
Funds used to acquire legitimate assets
Funds distributed to finance terrorist activities
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Money Laundering and Terrorism Finance Comparison
Money Laundering• Motivation is profit• Circular funding flow
– Vlademiro Montesinos• PEP
– Abused his trust
• Laundered over 400 million globally (80 million in U.S.)
• SARs instrumental to investigation
Terrorism Finance• Motivation is ideological• Linear funding flow
– Shawqi Omar• Terrorist
– Abu Musab al-Zarqawi
• Beneficiary of multiple frauds involving family members in U.S.
• SARs instrumental to investigation
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Targeting the Money Launderer• Key vulnerabilities in the money laundering
process▫ Cash▫ Wire transfers▫ Fixed assets
• Identifying money laundering mechanisms• Intelligence gathering and exploitation• Disrupting illicit money flows
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Right to Financial Privacy
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The Bank Secrecy Act31 U.S.C. § 5311 et seq.
• Originally enacted in 1970 with the addition of nine sections to Title 12.
• Title II - imposes recordkeeping and requirements on financial institutions
(The name is a misnomer!)
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Is this a good policy?
• 4th Amendment• 5th Amendment• 1st Amendment• Privilege? • Due Process?
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Early ChallengesCalifornia Banker’s Association
v. Schultz94 S.Ct. 1494 (1974)
Bank customers, bank, bankers' association and organization suing on behalf of itself and its bank customer members brought action to enjoin Secretary of Treasury and head of other federal agencies from enforcing provisions of BSA
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Early Challenges(cont’d)
U. S. v. Miller , 96 S.Ct. 1619 (1976)
Mitchell Miller was convicted of possessing an unregistered still, carrying on the business of a distiller without giving bond and with intent to defraud the Government of whiskey tax, possessing whiskey upon which no taxes had been paid and conspiring to defraud United States of tax revenues. He claimed that the evidence – microfilms or checks, deposit slips and other records relating to his accounts at two banks, obtained by subpoenas –should have been suppressed.
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Impact of ListsDrives Terrorist
Supporters Underground
- Requires shift in investigative orientation & focus
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“Overinclusive” TargetingMISCHIEFMISCHIEF
CRIMECRIME
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Money LaunderingFinancial transactions designed to make
illegal (or “dirty”) proceeds appear to be legitimate (clean).
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Al-Haramain Islamic Foundation, Inc. (D. of Oregon)
Pirouz Sedaghaty, a/k/a Pete Seda, PerouzSeda Ghaty and Abu Yunus
18 U.S.C. 18 U.S.C. §§ 371 371 ––Conspiracy to Defraud the United StatesConspiracy to Defraud the United States
26 U.S.C. 26 U.S.C. §§ 7206(1) 7206(1) ––False IRS Return by Tax Exempt OrganizationFalse IRS Return by Tax Exempt Organization
31 U.S.C. 31 U.S.C. §§ 5316(a)(1)(A) 5316(a)(1)(A) ––Failure to File Report of InternationalFailure to File Report of InternationalTransportation of Currency or Monetary InstrumentTransportation of Currency or Monetary Instrument
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The American Experience with International Terrorists
The “Non-Bomb-Throwers”
-- the use of United States as a financial staging grounds
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“Overinclusive” Targeting in Counterterrorism Enforcement
TERRORISMTERRORISM
TERRORISTSTERRORISTS’’SUPPORTERSSUPPORTERS
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18 U.S.C. § 2339BProviding Material Support to Terrorist
Organizations
(a) Prohibited activities.--(1) Unlawful conduct.--Whoever knowingly provides
material support or resources to a foreign terrorist organization, or attempts or conspires to do so, shall be [guilty of a felony]. To violate this paragraph, a person must have knowledge that the organization is a designated terrorist organization [or] that the organization has engaged or engages in [terrorist activity.]
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U.S. Lists relevant to counterterrorism enforcement
(1) State Department designated “Foreign Terrorist Organizations” (FTOs)
• 46 groups, including their aliases• groups only, no individuals• all are “foreign”• § 2339B crime
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The Right to Financial Privacy Act12 U.S.C. § 3403
• (a) Release of records by financial institutions prohibited
No financial institution, or officer, employees, or agent of a financial institution, may provide to any Government authority access to or copies of, or the information contained in, the financial records of any customer except in accordance with the provisions of this chapter.
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RFPA Litigation History
RFPA Cases Over Time
0
5
10
15
20
1979 1983 1987 1991 1995 1999 2003 2007
Year
# C
ases
# RFPA
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RFPA Litigation History• 56 cases vs. Bank• 78 cases vs. Government
0 20 40 60 80
Banks
Government
# Cases
# Cases
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RFPA Litigation History
0
5
10
15
20
25
30
35
40
1970s 1980s 1990s 2000s
Banks
Government
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Sample RFPA Lawsuit vs. Bank• Young v. Chemical Bank, 1988 WL 130929 (S.D.N.Y. 1988)“it would be absurd to hold that Chemical disclosed Sybil
Young's records in violation of the Privacy Act. Chemical was served with a subpoena, regular on its face, requiring testimony and production of all records at Chemical pertaining to Roderick Young and/or Sybil Young. The subpoena contained an order prohibiting Chemical from disclosing to any person the existence of and Chemical's compliance with the subpoena. Failure to comply with the subpoena would have subjected Chemical to an order of contempt. This Court cannot penalize compliance with a subpoena where such compliance did not violate any federal statute .”
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Best Resource for Description of FTOs
• www.state.gov/s/ct/
• Does not describe American legal history of them, except in passing
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Supplemental Resources
The Prosecutor’s Guide to the FTOs
(DOJ NSD December 2009)
The FTO Litigator(DOJ NSD February 2010)
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BSA INFORMATION FACILITATES INVESTIGATIONS
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GAO Report February 2009• Bank Secrecy Act: Suspicious Activity Report use is
increasing...– Automated monitoring systems can flag multiple indicators of
suspicious activities and identify significantly more unusual activity than normal monitoring
– Public enforcement actions against depository institutions prompted other institutions to look more closely at client and account activity
– Greater awareness of and training on BSA requirements– More regulator guidance for BSA examinations– Federal agencies have taken actions to more effectively analyze
SAR data• Better integration of BSA data with law enforcement data
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Value of Financial Institution Records
• Investigations rely on bank financial data
• Compliance with subpoenas and regulatory reporting requirements absolutely vital
• Financial records have potential value as evidence of financial crime or transactions, or to enhance other parts of an investigation
▫ Bank records: transaction records, loan applications, signature cards, etc.
▫ Reporting records: SARs, CTRs, etc.
Financial institutions are gatekeepers of information about terrorists’ financial activity in the regulated sector
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FBI Investigative Data Warehouse
• Implementation of data sharing / data mining technology
▫ Time sensitive and meaningful data exploitation
• Importance of Suspicious Activity Reports
▫ Thorough completion of forms to include as much identifying data as possible
• Importance of Know Your Customer and Customer Identification Programs
▫ Proliferation of false identity documents
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BSA Data: Enhancing Investigations• Every FBI terrorism investigation must include a financial sub-
file– First check on sub-file checklist is FinCEN BSA database
• SARs & CTRs in concert provide significant data to construct a financial intelligence picture– SARs: point to potential criminal activity– CTRs: provide almost sole opportunity for visibility on cash
movement, capture objective data on financial activity and patterns
• Total number of terrorism subjects in FBI investigations with positive hits in Investigative Data Warehouse/BSA data sets: 41.7%
Source: FBI
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Yemeni Shopkeepers• Three Yemeni shopkeepers in Rochester, New York engaged in a scheme to
launder money for undercover operatives from ICE– Seleh Mohamed Takei Saeed– Yehia Ali Ahmed Alomari– Mohamed Al Huraibi
• Investigation predicated on analysis of Currency Transaction Reports (CTRs)– Saeed’s social security number associated with 324 CTRs totaling
approximately $12.3 million dollars between October 2002 and November 2004– Alomari’s social security number associated with multiple CTRs totaling
approximately $2.6 million dollars during the same time period• ICE conducted two year undercover investigation• Subjects transferred approximately $200,000 outside the U.S. after the money
was represented to be proceeds of specified unlawful activity, and intended for Hizballah
• Saeed, Alomari and Huraibi plead guilty in August 2009
Durnan Mini MartShort Deli & GroceryMOJO’s Stars Restaurant
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Keys to Effective AML / TF Programs• Time sensitivity
• Risk recognition
• KYC program
• Adaptability
• Thoroughly completed SARs
• Financial Intelligence
• Proactive AML program
– Terrorist financing specific training
• Vigilance
• Communication, cooperation & coordination
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• Internal measures
– Break down fraud and money laundering silos
– Understand the problem
– Vigilance
– Communication, cooperation, coordination
• External measures
– Terrorist financing specific training
– Security clearances for select bankers
– Feedback mechanisms regarding importance of BSA
– Assessment of all SARs identifiable with terrorism cases
– Case studies of terrorist financing investigations
– Combining BSA data with other data to include empirical and anecdotal information for trend analysis
Improving Possibility v. Probability
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2010 Web Seminar SeriesTuesday, September 712:00- 2:00PM
Suspicious Transaction Reporting: Going Beyond the Form
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DML Associates, LLC19309 Winmeade Drive, #110
Lansdowne, VA 20176571.333.0300
Dennis M. LormelPresident & CEO
Jeff BreinholtCounsel for Law & PolicyNational Security DivisionU.S. Department of Justice