So since my return to the Abstraction world, I have noticed a few things.

• There is still a big time stigma against No Pay Companies, often with people on the constant alert who alert other companies of their Non Pay Behavior
• Part of that stigma against No Pay Companies, is towards Non-paying OFF SHORE COMPANIES or OFF-SHORE companies in general

I attended a training seminar by a agent with (insert name of top secret 3-letter agency here) and one of the things they talked about is how the USA, compared to the rest of the world, is a haven for shell companies, fraudulent companies, fronts for illegal activity, etc, especially in Delaware(which is a hub of sorts). We are pretty lax believe it or not compared to other countries in terms of our restrictions and regulations.

Now, in the battle between Us vs Off-Shore Companies, I remain neutral. I am not afraid of doing business with off-shore companies, provided they:

• Pay
• Have a US-based office and/or US Contact
• Are transparent and operate under ethical, legal practices with integrity
• Operate with respect to American Interests in mind 

Its a global market after all. HOWEVER, recently I have been contacted by companies, often start ups, or off shore, asking and looking for a US Partner to represent/operate for them. Seriously, it is at least a new one every week. One of these, in my due diligence fit the tell tale signs of being fraudulent:

• Address to a office suite/PO Box in Delaware
• They had a website, but it was cheap. Seriously, according to my analyst, cost about 2 USD to make.
• A simple google search revealed the actual OWNER Company of the business was a different name
• Website was not even registered in their name
• The address of the actual owned business was in a total different state altogether

and some other factors.

This is VERY DANGEROUS in the business world. That company could:

• be owned or invested in by foreign sanctioned individuals, organizations, or companies, etc.
• linked to foreign sanctioned individuals, companies, organizations, or addresses
• be a front for organized crime or other illegal activity
  

Title Company Owners, Mortgage Officers, and others who hire off shore companies as vendors: you may be getting the work done cheap, but not only is the liability and risk substantial, but the Department of Treasury's - Office of Foreign Assets Control has a ZERO TOLERANCE POLICY AGAINST COMPANIES AND INDIVIDUALS  who conduct business transactions with sanctioned individuals, businesses, organizations, or addresses.

Read: They CAN AND WILL FINE YOUR BUSINESS MILLIONS, IF NOT TENS OF MILLIONS, IF NOT HUNDREDS OF MILLIONS, OR BILLIONS OF DOLLARS.

Don't believe me? Look up  on Google "OFAC ZERO TOLERANCE".

That said, when taking on a client, contracting, or sub-contracting to a company who is or may be a foreign company (or owned by a foreign company) always be vigilant and conduct due diligence:

• Always be wary of suspicious names (John Smith, etc.) especially when paired with foreign accents.  Keep in mind Sanctioned Individuals or those flagged under FINCEN 314(A) or 314(B) often know they are sanctioned, and use aliases to try and avoid detection. When I worked in intel I was investigating a potential client in my hometown who owned a massage parlor. A diligent search was conducted because it was suspected he was the same as an international fugitive who ran a sex trafficking operation. His front? A massage parlor. 98% name match, same date of birth. Plot twist? Our potential client owned a: you guessed it, a massage parlor. I red flagged it for escalation....

• New client? Don't be afraid to ask for a retainer in the form of half up front non-refundable. I cannot think of a SINGLE ATTORNEY that does not require a retainer up front before ANY SERVICES ARE CONDUCTED ON A CLIENT'S BEHALF

• Always do a extensive google search on any company. They may be a unlicensed business, and you can learn a lot. If you see SCAM alerts, no pay alerts, then do not pay them mind. It is not worth it. Nobody in their right mind would ever work for free.

• In reference for the above, if you see the company is registered in a different name and/or different state/different country and they have not been forthcoming, then walk away. That means they are not transparent, and/or may be conducting suspicious activity.  When I was attached to A. B. Abstraction Services, the business was a LISCENSED business (LLC) and it was registered to my at-the-time address. My Tax ID, E&O all shared the same address. 

• I came across this gem today: on the website for one of these suspect companies, they had a reference testimonial of a "satisfied customer" from a generic name like "Tom Smith". No photo, no company listing, no email, no LinkedIn. Granted, it could be fluff to boost their marketing but any legitimate reference will be, again, transparent (like references found on LinkedIn). When dealing with a company you suspect may be fraudulent, don't be afraid to have them put you in contact with a reference.

• Always google map their address (or in my case a quick current owner search won't hurt): if their company address is an empty space, non-existent, or a derelict building, then WALK AWAY. 

I hope this helps. I fight for everyone, especially the under dogs, and I want everyone to succeed. I do not ever want to read about a small time Title Search being subject to Federal Investigation because they vendored out to a off-shore company and it turns out they were sanctioned, etc.

Be smart, be diligent, be innovative, be successful.

-Will

Will Duncan

Senior Vice President - LGT/ABN

(831) 325 - 8471

willduncancss@yahoo.com 

"Keeping it local in North Carolina since 1981"