SPF and DKIM

I recently implemented SPF and DKIM. I verified whether my settings were correct or not by using the port25's verifier service (http://www.port25.com/domainkeys/)

The results are as follows :
SPF check: pass
DomainKeys check: neutral
DKIM check: pass
Sender-ID check: pass
SpamAssassin check: ham

Everything checks out ok except DomainKeys. I am not sure what else do I need to do to get a pass on Domain Keys also.

Any insight will be greatly appreciated.

Grant Select Rights to multiple tables

declare
cursor c1 is select table_name from user_tables;
cmd varchar2(200);
begin
for c in c1 loop
cmd := 'GRANT SELECT ON '||c.table_name||' TO "userid"';
execute immediate cmd;
end loop;
end;

Thanks to :
https://forums.oracle.com/forums/thread.jspa?threadID=616903

Stratified Sampling Verification

As we all know that while dealing with a large population data set, it becomes imperative during the data analysis stage to pull a sample and use that as a reference data set to perform data analysis.

Stratified sampling is a one of the approaches for sample extraction. It is very easy to develop a stratified sampling code (I have used SQL) to extract the sample from the underlying population. The question that I have is how can we verify that the extracted sample is indeed a stratified sample? I have tried using Kolmogorov-Smirnov Test but have not been successful in using the results of the test to prove that the sample I extracted was indeed a stratified sample. By not being successful I mean my p value is less than 0.0001 with my null hypothesis being that the sample is a stratified sample. In this situation, I am pretty sure that the sample I pulled is indeed a stratified sample.

What other tests can I perform? Or What additional points should I consider before performing the K-S test?

Foreign Inheritance and IRS Requirements

In the event of one receiving an inheritance in the form of Stocks, Real Estate etc. from relatives residing in foreign country, IRS requires the U.S. person to report these holdings. For example : If you received an inheritance in the form Stocks and Real Estate from your relatives in foreign country and you have not sold either of them and therefore are still in your name in the foreign country then in this scenario IRS requires you to file the following forms

1. Form 3520 – Annual return to report receipt of certain foreign gifts (Part IV)

2. Form TD F 90-22.1 - Report of Foreign Bank and Financial Accounts (FBAR)

3. Report dividends received from the securities held in my account on Form 1040 Schedule B Box 3.


Form #1 and #2 are not filed as part of your IRS Tax Return. Please refer to the links to find out when/where they need to be sent.

As always your comments are always welcome.

Move securities to Roth Account

If you have securities for which you are losing money and do not want to part with it then one way of avoiding future tax payment is to transfer the securities over to a Roth IRA account that way when in future it is making money, you will not be taxed on profit the security returns. In addition you will be able to claim the loss now as part of your current year tax filing.

For example : If you bought a stock of ABC company at $15 and now it is trading at $10 but you do not want to part with it, then a strategy could be to sell the ABC stock at $10 and claim tax deduction (if you have held it for more than a year) for loss ($500 loss if you have 100 shares) and after 30 days buy the same stock in your Roth IRA account.

The advantage of doing so will be :

1. You get a tax deduction now because of the loss you had by selling it.

2. You will not be required to pay on the profits you make in future.

With the income caps going away in 2010, opening a Roth IRA account should be even more easier.

Leverage Checksum to determine identical files

An easy way to identify if two files are exactly the same or not is by determining the check sum of each file and comparing the check sum. If the check sum for both the files is exactly same then it can said that the two files are identical.


I have written a little java program which determines the check sum of file.


import java.io.FileInputStream;
import java.security.DigestInputStream;
import java.security.MessageDigest;

public class Checksum {

public static String computeCheckSum(String fileName) {


try {
FileInputStream stream = new FileInputStream(fileName);
MessageDigest md = MessageDigest.getInstance("SHA-1");

DigestInputStream dIS = new DigestInputStream(stream, md);
dIS.on(true);


byte [] b = new byte[1000];

while (dIS.read(b,0,1000) > -1);

byte []signature = md.digest();
//System.out.println("The signature is :");
for (int i = 0; i < signature.length; i++) {
System.out.print(signature[i]);
}
} catch (Exception e) {
e.printStackTrace();
}

return "";
}

public static void main(String [] a) {
Checksum.computeCheckSum(a[0]);
}

}

CAMS Certification Preparation

I took the CAMS certification examination (and passed with good points) after 2 months of prep work (approx. 1 hour per day max). The exam is not tough but a good prep work is required. The study guide provided by ACAMS is an excellent resource. In addition to that I reviewed the supplemental guide also. I think all the topics covered in the study guide are equally important and strongly suggest to not skip any chapters. I did not make any notes (I think I am not good at making notes)

I am assuming that someone will take this examination not to just get one more certification but has sincere interest in AML domain and is currently working on projects which are AML related. The test tries to identify how much practical knowledge a candidate has. I certainly would not recommend taking this examination just to get one more certification as in that case it is not worth the time and money spent to get it.

I strongly recommend this test to candidates who have just started in AML field and want to explore it further as their career. It certainly helps the candidate to get a good understanding on various AML aspects, regulations, bodies etc.

Hope this helps and Best of Luck for CAMS Examination!

Section 311 etc. (ACAMS Notes)

Section 311:
Special measure for Primary Money Laundering concerns, this include foreign country, financial institution, type of an account or type of a transaction.
By designating an entity a primary money laundering concern, the government can force US banks to halt financial dealings with the designated entity. It can ask the domestic financial institution to
1. Keep records of each transaction including all the transaction participants and beneficiaries

2. Obtain information of beneficial ownership of any accounts maintained in US by a non US person or his/her representative.

3. Obtain information of all customers who are permitted to use or whose transactions are routed thru the designated financial institution’s
correspondent account.

4. Obtain information of all customers who are permitted to use or whose transactions are the designated financial institution’s payable thru account.

5. Order closure of payable thru and/or correspondent account.

Section 312:
Requires EDD for Correspondent and Private Banking.
The correspondent banking rule applies to bank, broker deals, future commission merchants, mutual funds and introducing broker dealers
The due diligence requirements are based on risk based approach.
EDD for private banking should include senior political figures, their families and close associates.
To fall under this rule Private Banking account must maintain a USD 1 Million or more of minimum aggregate deposit
Private bankers should identify the benefial owners of the account and their source of funds and how they plan to use it.

Section 313:
Do not transaction with Shell Banks.
In addition it prohibits the respondent bank to permit shell bank to access its correspondent bank account through nested correspondent relationship.

Section 319(b):
Allows the Treasury Secretary or attorney general to issue summons or to subpoena records of, a foreign bank that maintains a correspondent account in the US.

Foreign banks must designate a registered agent in US to accept service of such subpoenas.

Section 319(a):
If the funds the US pursues are deposited in a foreign bank which keeps an interbank account at a US bank, the US may attempt to forfeit the crime-tainted funds in the US account.

FATF Membership Points (ACAMS Notes)

To qualify for FATF membership, a country must :

- Strategically Important.

- Be a member of FATF style body(for example : Asia Pacific Group(APG), Eurasian Group (EAG) etc.

- Provide a letter from appropriate government official making a political commitment to implement FATF recommendations (1, 5, 10 and 13 at the minimum) within a reasonable time frame and to undergo a mutual evaluation process.

- Criminilize money laundering and terrorist financing; require financial institutions to perform KYC, EDD and report suspicious transaction to the country's Financial Intelligence Unit (FIU).

Internet Casinos and Prepaid Cards/E-Cash (ACAMS Notes)

Internet Casinos
• Prime mode of payment used is Credit Card.
• Casinos being on offshore location prevents prosecution
• Government receive tax dollars due to internet casino and therefore have lax controls
• Citibank has banned the usage of Visa and Mastercard for Internet Casino usage
• Banks can identify the type of transaction conducted via credit card by interpreting the transaction codes.
• Internet enables fast transmission of money<
• Online gambling does not lend to any cash movement.

PrePaid Cards and E-Cash
• New Payment technologies like internet payment, mobile payment, digital precious metals, prepaid cards)
• Prepaid cards are like cash, they are portable, exchangeable, valuable and anonymous.
• The cards can be purchased by one person and used by another and that too in a different part of the world.
• There maybe an account for each prepaid card issued or alternatively there may be a pooled account that holds funds for all issued prepaid cards.
• Potential Risk Factors

Anonymous card holders

Anonymous funding of cards

Can be virtually anywhere on the globe

No limits on how many cards an individual can buy.

High Value Limits

Offshore card issuers may not observe laws in all jurisdictions

• In Germany, adding value to a prepaid card is considered as making a deposit and therefore the card issuers are considered credit institutions which require full banking license and follow country’s AML regulations.
• Electronic Purses (or stored value cards) are cards that electronically store value on the chips embedded on the card.
• E-Purses issuance is declining
• Potential Risk Factors for E-purses

Anonymous users

Anonymous funding

No High Value

No Transaction Records

• Measure to limit Prepaid/E-Purse vulnerability to AML

Limit number of cards issued to a customer

Assign High Value Limit

Track Transactions

Linking payments technology to banking institutions

Establishment of global standards

Record keeping procedures requirements for the issuing banks

Capability to examine the records by investigating authorities