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G-20 Stamps Out Tax Havens

OECDThe fallout from the recent tax evasion settlement with UBS is reverberating throughout the G-20 community.  As we reported back in October,  the French Governments action directing banks to close branches and subsidiaries in non-OEDC compliant jurisdictions will pressure all G-20 participants to adopt a more uniform tax code and enforcement practice.  The drive to strengthen the respect of tax treaties and the closure of havens to custody assets beyond the reach of national tax authorities signals a new era in multinational cooperation and the eclipse of radical free market tax practices.

The principal drivers for this unprecedented level of cooperation and standardization is the dire need for national tax authorities to recognize and tax revenue streams to help address the burgeoning budget deficits the global economic crisis has has wrought.

Clearly the crackdown on tax evasion is gaining momentum since the global financial crisis has devastated national treasuries.  Enormous expenditures on stimulus programs and dramatically falling tax receipts has created a perfect storm and has created an enormous threat to the fiscal soundness of national treasuries.

Forbes reports that Singapore has become the latest in a flurry of jurisdictions complying with Office of Economic Cooperation and Development standards on transparency and exchange of information for tax purposes.  Fifteen jurisdictions have come into compliance since April 2009.  In addition to Singapore and the sea change occurring in the Suisse banking industry; other  governments that have lost revenue to tax havens are individually taking tough action:

–The U.K. government has informed the Isle of Man that it will reduce revenue transfers of value-added tax receipts to the island by 50 million pounds next year, 9% of the island’s revenue.

–French banks are starting to close down their operations in tax havens.

–In Germany, the hiding of funds in Liechtenstein bank accounts has prompted a backlash against tax havens.

–In the United States, White House advisor Paul Volcker in December is due to report on ways of eliminating revenue losses to tax havens.

This heightened regulation and standardization amongst  G-20 tax authorities is quickly closing any regulatory tax arbitrage opportunities for global investors.  The closure of preferential tax domiciles will heighten the power and reach of national tax agencies enforcement capabilities and the scope of their examination reach.  The IRS is stepping up its enforcement and institutional assets to assure that private equity and hedge fund industries comply with all the anti-money laundering laws and stringent tax codes.

Sum2’s IARP helps investment managers assess and manage the growing threat of audit and tax enforcement risk.  Sum2’s CARP helps large and mid-size corporations assess compliance and manage  IFI audit risk.

Risk: audit, enforcement, regulatory, tax, reputational, litigation

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November 16, 2009 Posted by | AML, CARP, corruption, IARP, IRS, legal, OECD, private equity, regulatory, reputational risk, risk management, Tax | , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , | Leave a comment

Sum2 Announces New Business Webinar Series: Recovery Tools for the New Economy

sum2 large corp logoGreat Falls Festival Paterson, New Jersey September 7, 2009: Sum2 is proud to be participating again in this year’s historic Great Falls Festival and is pleased to announce a new webinar series entitled “Recovery Tools for the New Economy.” The webinar series is designed to highlight the dramatic changes occurring in the economy and provide business managers with a set of tools to assess business risks and uncover opportunities the trying business cycle is creating.

The Great Falls Festival presents a perfect opportunity for Sum2 to announce its new webinar series. The Festival brings together leading industry executives, business associations, academic institutions, service providers, government agencies and capital market participants. Sum2 believes economic recovery will require concerted action by all these participants.  Sum2 invites all of their participation to more effectively address the problems and opportunities confronting business and industry to effect sustainable economic recovery.

Recovery Tools for the New Economy

The Recovery Tools for the New economy Webinar Series will consist of three modules.  Those modules include:

  • Macro Risk and Opportunity Assessment: Macroeconomic, STEEPLE, SWOT, Financial Ratios, ROI Analysis
  • Product and Market Segment Assessment: Product, Customer, Competition, Supply Chain, Market Dynamics
  • Business Function Performance Scoring, Management, Sales and Marketing, Operations, Accounting, IT, Human Resources, Facilities

Each webinar will provide participants with an SMB 360 workbook and a series of interactive worksheet templates to conduct assessment exercises.  Each webinar session will run approximately 1 hour in length.  Each webinar module subscription fee will be $75.00.  Subscribers can purchase a subscription to all three modules for $200.00. Subscribers that license all three modules can also purchase a Profit|Optimizer license for $200.00.  Subscriptions to the webinar can be purchased on the Sum2 website www.sum2.com.

Sum2: Sound Practice Thought Leader

For the past three years Sum2 has used the occasion of the Great Falls Festival to announce a new product or market initiative.  Last year Sum2 unveiled The Hamilton Plan.

Sum2’s announcement of the Hamilton Plan is in response to the compounding economic and political crisis that is confronting the United States. The credit and energy crisis, inflation pressures, trade deficits, geo-political instabilities, global warming and ecological degradation are the result of long term systemic problems that government and industry has failed to address effectively.

Sum2 put forth a 10 Point Program that squarely addresses these pressing issues.  The previous year Sum2 announced the SMB|360° product series which has grown to include the Profit|Optimizer, IRS Audit Risk Program and the Macroeconomic Risk Assessment program.

The Profit|Optimizer is a qualitative risk assessment and opportunity discover tool. It assists SME’s to identify and score business vulnerabilities and opportunities. The Profit|Optimizer conducts over 200 assessments encompassing products and markets, business functions and critical success factors. The Profit|Optimizer aggregates risk assessment scores and presents action items on a series of dashboards that enable managers to decide what initiatives mitigate the greatest risk and produce the greatest return.  The Profit|Optimizer demonstrates to shareholders, bankers and other stakeholders that company management are effective risk managers and are committed to corporate governance excellence.

Sum2 offers a series of products and services to help SME’s effectively manage risk, improve stakeholder communication, implement effective corporate governance that create sustainable business practices to assure long term profitability and growth.

Sum2 also offers the award winning PACO™ (Patriot Act Compliance Officer). PACO™ helps financial services companies comply with the anti-money laundering provision of the Patriot Act.

About Sum2, LLC

Sum2 was founded in 2002 to promote the commercial application of sound practice programs. Sum2’s sound practice program addresses risk management, corporate governance, shareholder communications and regulatory compliance. Sum2’s objective is to assist businesses and industries to implement corporate sound practices that add exponential value for stakeholders, employees, customers and to be exemplary citizens within the communities in which they operate and serve. Sum2 manufactures, aggregates, packages and distributes innovative digital data content products to selected channels and markets.

For more information on this program or to order products offered by Sum2 please contact customer.service@ sum2.com or call us at 973.287.7535.

September 8, 2009 Posted by | IARP, product, SME, sound practices, Sum2, Uncategorized | , , , , , , , , , , , , , , , , , , , , , | 1 Comment

The Black Knight

Sir Allen Stanford

Sir Larceny-A-Lot

Sir Allen Stanford turns out to be no knight in shining armor. He’s just another greedy creep who thought he was entitled to other peoples money.   Sir Allen might just be another garden variety Ponzi Schemer; but compared to Madoff this guy is a piker.   The theft of $8bn is petty larceny compared to Madoff’s massive $50bn swindle.

It is becoming startling clear that we can no longer view these types of events as isolated incidents. Sir Allen may be this weeks poster child for capitalists gone wild; but the shock and awe of audacious financial crime is becoming a consistent lead story on the nightly news.  Public trust in the financial markets is at stake.  If people cannot trust their financial fiduciary the whole system goes down.

The SEC’s reluctance to act on information concerning Madoff irregularities and the announcement that over 500 public firms are being reviewed for possible fraudulent business practices are raising a public outcry for more vigorous oversight and protection.  The swirling rumors of bank insolvencies, nationalizations and news of  their egregious failure to adhere to basic risk management precepts are turning the skeptical taxpayers  into vocal opponents of the TARP program and any future bank bailouts.

The allegations that UBS marketed a tax evasion scheme to attract over 50,000 US clients to their private banking business with the promise that it would shield them from onerous tax liabilities may be the straw that breaks the camels back.   US taxpayers are struggling from the burdensome pain of high taxes they dutifully pay.   They are confused and frightened by the orgy of government spending and how the financial industry bailouts will effect them.  The credit crisis and the stunning losses people incurred in their retirement and investment portfolios is casting widening doubt about the trustworthiness of the banking system.  Citizens are urging their elected representatives that all financial service providers must come under a microscope of  scrutiny and oversight.  Consumers want assurances that all fiduciaries are sound.  Taxpayers are demanding that regulators insist that financial institutions provide a level of transparency to assure consumers that they are in compliance with all regulatory mandates, have a program of risk management controls and offer proof of an ethical corporate governance program.

The US tax payer has made it clear that they can no longer shoulder an egregious tax burden that continues to finance insolvent financial institutions that failed miserably to manage risk or comply with the barest minimum standards of proper corporate governance.

The allegations that surfaced suggesting that Sanford Financial may be linked to money laundering for Latin American drug cartels through The Bank of Antigua and related banking enterprises in Venezuela and Ecuador is sure to usher in a new era of aggressive enforcement initiatives by regulators.   The practice of  selling worthless CDs to retail investors that promised high rates of interest is the tip of the spear in a sophisticated money laundering scheme.  This will create some added urgency for regulators to conduct an in depth reviews of financial institutions AML compliance programs.  Examiners will aggressively pursue fund managers  to determine that Know Your Customer (KYC), Customer Identification Procedures (CIP) and Politically Exposed People  (PEP) programs are meeting acceptable standards to detect and deter money laundering.  Of  particular concern will be hedge fund complexes with incorporated off shore structures.  To be sure, examiners will liberally interpret and claim jurisdictional nexus on all offshore structures linked to US domiciled funds.  The US Treasury coffers are bare and it will look to collect taxes on any revenue sources it deems as taxable.

Financial institutions need to demonstrate to counter parties,  regulators, SROs and most importantly investors; that they have a sound risk management program in place that protects the funds investors against all classes of operational risk.    Sum2 offers an AML audit program fund managers use to maintain compliance standards  that  demonstrate program excellence to regulators and investors.

You can believe the examiners are sharpening their spears.  Looking to bag a kill and make an example of wayward managers with lax compliance controls.  Be ready, be vigilant and be prepared.

You Tube Video: Moody Blues: Nights in White Satin

Risk: money laundering, regulatory, operations, reputation

February 23, 2009 Posted by | AML, hedge funds, off shore, operations, regulatory, reputation | , , , , , , , , | Leave a comment