On August 23, 2012 the Northern California ACAMS Chapter descended upon Golden Gate University in downtown San Francisco to hear from two eclectic speakers: Steve Wallace, BSA/AML officer at First Republic Bank and Alex Seddio of Alex Seddio & Associates.
Alex Seddio speaking at Golden Gate University
In the University’s stadium seating, about 40 local BSA/AML professionals listened and participated in discussions on identifying beneficial ownership and the difference between tax avoidance and tax evasion.
“Tax avoidance is legal. However, tax evasion is illegal!” remarked Seddio who worked with the IRS – Criminal Investigation Unit in his previous career. In his presentation he defined tax avoidance as the legitimate minimizing of taxes using legal methods.
On the other hand, tax evasion is illegal and he defined it as the intentional and illegal practice of not reporting income, reporting deductions not legally allowed or by not paying taxes owed.
Wallace gave a solid presentation on the rules of beneficial ownership. According to the USA PATRIOT Act, Section 312, financial institutions are required to perform due diligence, and in some cases enhanced due diligence, with regard to correspondent accounts established or maintained for foreign financial institutions and private banking accounts.
Wallace cited a few case studies for the failure to identify the beneficial ownership of accounts, pinpointing the Permanent Sub-Committee on Investigation’s review (PSI) on Riggs Bank.
After the presentation, discussions continued at a local venue with drinks.Steve Wallace addressess the audience at Golden Gate University, in San Francisco.