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Patriot Act and Money laundering MEC DUE DILIGENCE SERVICES Background On October 26, 2001, President George W. Bush signed into law the PATRIOT Act, which, among other things, strengthened the anti-money laundering provisions put into place by earlier legislation and included new anti-money laundering provisions applicable to broker/dealers. The Act includes the requirement, effective April 24 2002, that each securities firm has an anti-money laundering compliance program in effect. MEC International Ltd is well placed to support the needs of investment management firms facing the requirement to demonstrate an increased understanding of the background and activities of their investor clients since its Investigations Group has been active in the market for some 15 years. The MEC Investigations Group offers an investigation capability in Europe, the Middle East, the Former Soviet Union, Eastern Europe, Asia as well as the Caribbean and the USA. Specifically the service covers litigation support; asset searches; due diligence; fraud investigation; personnel vetting; and document verification. Recent investigations work in MEC now envisages a complete due diligence review of asset management companies operating in foreign jurisdictions. This process is conducted with total discretion and no exposure of the process to the public domain. Methodology The methodology adopted by MEC is the provision of a specialist task force to deal with the individual investigations allocated by the client. Membership of the task force management group includes senior consultants with extensive experience of all types of investigations in both the government and private sectors. For the implementation of each due diligence enquiry, MEC utilises its wide range of professional sources, contacts and investigator groups in Europe, the Caribbean including the Cayman Islands, and other markets listed above. Each investigation is the subject of an exchange of letters defining the scope of the task, the timing, cost of fees, possible ancillary expenses, and date of delivery of the final report. Implementation and Timing Once a client decides to use the services of MEC International, a first test investigation is then allocated for execution. Each due diligence case will be allocated to one or other of the MEC team Investigations Group leaders, backed by research carried out by MEC staff. The individual team leader is responsible for direct liaison with the client as required to complete full implementation of the due diligence and submission of the final report. In general, individual reports will take 3-4 weeks for completion of phase 1. Implementation of a Phase 2 can be decided on a case by case basis. Costs MEC works on the basis of a fixed cost agreed at the time of signature of contract contained in an exchange of letters for each investigation between client and consultancy. Costs will be charged at an agreed fee level plus any expenses for travel, hotel, communications or out of pocket expenses which will be at cost and backed by vouchers and receipts. The level of fees will vary with each case and will be negotiated starting with a basic due diligence and increasing in line with the complexity of the case. Value In general MEC fee levels are significantly less than those charged by larger international practices for the same services. We are competitive because of lower overheads while as a small operation offering bespoke services we offer a personal service led by individuals with decades of experience. Meeting our client’s needs is important to us, as we know that a reputation takes a lifetime to build but a moment to lose. |
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