entirely different department.”
He stared at her, looking for the telltale signs of lies. Unfortunately he didn’t see any. “I haven’t heard of this.”
“Don’t feel bad. Learning the ins and outs of banking regulations takes years, and then the regs change overnight.” As Kayla spoke, she tried the edge of the heavy silver knife with her thumb again. Still dull as a baseball bat. “I could probably finesse the Treasury regs that require an SAR, but American Southwest is small enough that multimillions in new deposits to an old account will ring alarms all over the place.”
“SAR.” He said it like a curse.
“Suspicious Activity Report,” she translated sweetly. “We have to file a report with the feds whenever we encounter unusual activity in an account. And I believe your request would qualify as unusual if not outright suspicious.”
“You’re insolent.”
“I’m blunt,” Kayla said. “The more you know about what I can and can’t do, the less chance there is of a big misunderstanding. Who knows, we just might find we have a lot in common. Profitable things.”
Elena came back toward them, sandals sparkling. Behind her there was nothing but silence.
Bertone turned to his wife. “You said your banker was a naïf.”
“I said she was polite, sweet, and bright.”
“I’m flattered,” Kayla lied. “Nobody has called me sweet since I told my third-grade teacher to go screw the principal. I work for the bank, but I regard myself as an independent entrepreneur. And so does the bank.”
Bertone and Elena exchanged glances. Then he lit one of theCuban cigars he’d taken up with his most recent identity change. He missed cigarettes, but it was a small sacrifice for freedom. In any case, there were so few places left in the land of the free and home of the brave where a man was free to smoke anything but fish.
“Go on,” he said, blowing out a stream of fragrant smoke.
Kayla forced herself to pick up the check she’d rather burn. “Entrepreneurs can be difficult, but they’re more useful than clerks. For example, a young bank officer with an entrepreneurial streak might remember that she’d handled transactions from the Bertone accounts at the Bank of Aruba in the past.”
“But of course,” Elena said impatiently. “You’ve handled many of—”
Kayla talked over her. “That would mean this entrepreneurial bank officer could say to her bosses that the customer had an established record of legitimate dealings with American Southwest and that the deal was what is called ‘normal and expected.’ That’s the important language, ‘normal and expected.’”
Bertone watched her through narrowed eyes.
“Of course,” Kayla said, “if somebody challenged the transaction at some later time, the ambitious bank officer would have to say she’d been mistaken about the previous banking relationship. So sorry, my bad, but everyone makes honest mistakes, right?”
For the space of a long, savoring draw on the cigar, Bertone was silent. Then he said, “Wouldn’t such a mistake get the young entrepreneur fired?”
“It might,” Kayla agreed, “or she might get a raise for bagging millions in new deposits. Banks love big new deposits, so long as they come with plausible explanations. That’s the whole fallacy of these ‘know-your-customer’ regulations. They’re really a way the banks can clean their own skirts. Plausible deniability, in political terms.”
Kayla flashed a cold, cynical smile, hoping that her clenched teeth didn’t show. What she was saying was half true. The other half was that the lowest employee on the banking food chain was the one who got fired and went to jail when normal and expected became unusual and suspicious in the federal government’s 20/20 hindsight.
Like the countless ways to interpret income tax law, the gray areas in banking law were often decided in court.
“In other words, all of this was quite unnecessary,” Kayla said. “I’m
He stared at her, looking for the telltale signs of lies. Unfortunately he didn’t see any. “I haven’t heard of this.”
“Don’t feel bad. Learning the ins and outs of banking regulations takes years, and then the regs change overnight.” As Kayla spoke, she tried the edge of the heavy silver knife with her thumb again. Still dull as a baseball bat. “I could probably finesse the Treasury regs that require an SAR, but American Southwest is small enough that multimillions in new deposits to an old account will ring alarms all over the place.”
“SAR.” He said it like a curse.
“Suspicious Activity Report,” she translated sweetly. “We have to file a report with the feds whenever we encounter unusual activity in an account. And I believe your request would qualify as unusual if not outright suspicious.”
“You’re insolent.”
“I’m blunt,” Kayla said. “The more you know about what I can and can’t do, the less chance there is of a big misunderstanding. Who knows, we just might find we have a lot in common. Profitable things.”
Elena came back toward them, sandals sparkling. Behind her there was nothing but silence.
Bertone turned to his wife. “You said your banker was a naïf.”
“I said she was polite, sweet, and bright.”
“I’m flattered,” Kayla lied. “Nobody has called me sweet since I told my third-grade teacher to go screw the principal. I work for the bank, but I regard myself as an independent entrepreneur. And so does the bank.”
Bertone and Elena exchanged glances. Then he lit one of theCuban cigars he’d taken up with his most recent identity change. He missed cigarettes, but it was a small sacrifice for freedom. In any case, there were so few places left in the land of the free and home of the brave where a man was free to smoke anything but fish.
“Go on,” he said, blowing out a stream of fragrant smoke.
Kayla forced herself to pick up the check she’d rather burn. “Entrepreneurs can be difficult, but they’re more useful than clerks. For example, a young bank officer with an entrepreneurial streak might remember that she’d handled transactions from the Bertone accounts at the Bank of Aruba in the past.”
“But of course,” Elena said impatiently. “You’ve handled many of—”
Kayla talked over her. “That would mean this entrepreneurial bank officer could say to her bosses that the customer had an established record of legitimate dealings with American Southwest and that the deal was what is called ‘normal and expected.’ That’s the important language, ‘normal and expected.’”
Bertone watched her through narrowed eyes.
“Of course,” Kayla said, “if somebody challenged the transaction at some later time, the ambitious bank officer would have to say she’d been mistaken about the previous banking relationship. So sorry, my bad, but everyone makes honest mistakes, right?”
For the space of a long, savoring draw on the cigar, Bertone was silent. Then he said, “Wouldn’t such a mistake get the young entrepreneur fired?”
“It might,” Kayla agreed, “or she might get a raise for bagging millions in new deposits. Banks love big new deposits, so long as they come with plausible explanations. That’s the whole fallacy of these ‘know-your-customer’ regulations. They’re really a way the banks can clean their own skirts. Plausible deniability, in political terms.”
Kayla flashed a cold, cynical smile, hoping that her clenched teeth didn’t show. What she was saying was half true. The other half was that the lowest employee on the banking food chain was the one who got fired and went to jail when normal and expected became unusual and suspicious in the federal government’s 20/20 hindsight.
Like the countless ways to interpret income tax law, the gray areas in banking law were often decided in court.
“In other words, all of this was quite unnecessary,” Kayla said. “I’m
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