FormerFedsGroup issues White Paper Working Draft on US Mint mutilated coin program

WASHINGTON, April 26, 2016 /PRNewswire/ — The FormerFeds Group LLC, today announced the release of its White Paper on the U.S. Mint’s Mutilated Coin Redemption Program including recommendations to improve coin redemption procedures.  This program was suspended by the Department of the Treasury in November 2015 for a review of its security processes.  The FormerFeds Group White Paper was commissioned by GeyerGorey LLP, the law firm representing Wealthy Max Limited (Wealthy Max), a claimant in a federal civil forfeiture case involving redemption of supposedly counterfeit coins.

The White Paper was produced by a team of professional researchers, analysts and retired FBI agents all working in the FormerFeds Group organization.  The document reviews the history and development of the U.S. Mint’s Mutilated Coin Redemption Program since its founding in 1911, and recent concerns about the possibility of criminal exploitation of the program.  It concludes with several policy recommendations for the Mint and Treasury Department to consider when determining how best to restructure and relaunch the program.  A copy of the White Paper can be downloaded here.

“Over the last six months the FormerFeds Group has worked closely with the Wealthy Max legal defense team to provide investigation support, internal compliance review and auditing and most recently policy research and recommendations,” saidRoy Johnson, Special Agent in Charge, FormerFeds Group LLC.  “Our investigation into this program has found no evidence counterfeit mutilated coins have ever been redeemed, yet concerns have lingered about this possibility.  This White Paper uses our research and analysis capabilities to present a neutral review of the current program, and generate practical recommendations for improvements in security that will not significantly increase costs.  We believe there is consensus among all stakeholders that the Mutilated Coin Redemption Program is worthwhile and should be maintained in a manner that addresses security concerns.  Our White Paper reflects the FormerFeds Group contribution to this discussion.”

On April 25th the White Paper was delivered to multiple officials at the U.S. Mint and is also being sent to members of the House Financial Services Subcommittee on Domestic Monetary Policy and Technology as well as senior officials from the Departments of Treasury, Justice and Homeland Security.

The primary recommendation of the FormerFeds Group White Paper is that the U.S. Mint require all large scale coin redeemers to implement a rigorous compliance program with third party validation, to demonstrate coins being redeemed are genuine U.S. currency.  Each shipment of coins would need to be inspected and validated prior to being submitted to the U.S. Mint for redemption.  The costs of the compliance program would be borne by the organizations redeeming coins and thus would not add to the government’s expenses associated with this program.

“The FormerFeds Group thinks the institution of a well-structured and documented compliance program for coin redeemers is an effective and viable approach to addressing concerns regarding the potential redemption of coins that are not genuine U.S. currency. We would welcome the opportunity to sit down with Mint officials to discuss our recommendations in greater detail,” concluded Raymond J. Carr, Special Agent in Charge, FormerFeds Group.

The FormerFedsGroup is an international provider of compliance, investigative, crisis management and business development services for private and non-government organizations.  The organization is staffed with experienced professionals, all of whom have over 20-years of experience in United States federal law enforcement.

SOURCE The FormerFeds Group LLC

Related Links

http://www.formerfedsgroup.com2015-05-29 11.34.57

Connolly’s Cartel Capers: A Look at Other Significant Submissions to the Sentencing Commission on Possible Reforms to the Antitrust Guidelines (2R1.1)

A Look at Other Significant Submissions to the Sentencing Commission on Possible Reforms to the Antitrust Guidelines (2R1.1)

I’ve posted recently on my concerns with the Antitrust Sentencing Guidelines (2R1.1) as they relate to individual defendants (here).  Other submissions have been made to the Commission by people/institutions with great insight and influence in the cartel arena.  I’ve summarized a few of these below.

Click Here For the “Rest of the Story” (hat tip to Paul Harvey)

Trustbusters Targeting Cartels Abroad Reined in by U.S. Judges

Trustbusters Targeting Cartels Abroad Reined in by U.S. Judges
* * *

“The ruling opens the doors to foreign cartels to shield themselves from U.S. law by selling to a third party instead of directly into the U.S., said Robert Connolly, a lawyer at GeyerGorey LLP and a former prosecutor with the Justice Department’s antitrust division.

‘No Difference’

‘People can fix prices and then use a middleman,’ he said. ‘From an American consumer point of view, there’s really no difference.'”

* * *

Allen Grunes quoted regarding Publicis-Omnicom Merger in Bloomberg News

Allen Grunes shared his perspective with Bloomberg News regarding the proposed Publicis-Omnicom Merger.  Click Below:

Publicis-Omnicom Merger Seen as Drawing Antitrust Look

Competition Policy International: US: New antitrust firm GeyerGorey snags DOJ lawyers after office closures

Click Below:

Competition Policy International: US: New antitrust firm GeyerGorey snags DOJ lawyers after office closures

Main Justice: Policy Politics and the Law: Former DOJ Attorneys Aim For New Model With GeyerGorey LLP Law Firm

Click Link Below———>

7/10/2013 Main Justice: “Former DOJ Attorneys Aim For New Model With GeyerGorey LLP Law Firm

 

GeyerGorey LLP first international law firm to beta test PerfectShield™

GeyerGorey LLP first international law firm to beta test PerfectShield™

WASHINGTON — GeyerGorey LLP today announced that it had been chosen by FormerFeds LLC to be the first international law firm to beta test its revolutionary “PerfectShield™” Compliance system designed and deployed by former American fraud enforcers (a/k/a “FormerFeds”).  PerfectShield™ is the newest weapon in our arsenal

to provide a ‘redundant complex risk prevention array’ for clients that is affordable and provides automated and organized support for a company’s compliance operations overseen and administered by our law firm,” said firm partner Robert Zastrow.  “Because PerfectShield™ delivers the things we need most right now for our clients, we were happy to help FormerFeds LLC fine tune its compliance system to assist its other law firm clients later in the year.  We believe this gives GeyerGorey and its clients an advantage in our constant struggle to implement and maintain a vigilant compliance culture that innovates and reinforces productive corporate behavior moving forward.”

PerfectShield™ provides:

  • centralized, whole-of-business risk and compliance visibility and benchmarking
  • easy configuration to meet any regulatory environment in any sector
  • unique compliance portal for customized assessments and notifications
  • red flag generation and tracking system designed to protect privilege
  • cost effective, low-risk, pay-as-you-go pricing

“We were looking ‘software as a service’ (SAS) that provided an organizational ‘fire and forget’ system embedding compliance, transparency and corporate governance into one program solution,” stated Hays Gorey.  “FormerFedsCompliance™ developed its system across disciplines so that the wall that exists between various specialties within a law firm—for instance, cartel enforcement and FCPA, is rendered obsolete by PerfectShield™; efforts in each area informs the other area and efforts to embed compliance on the “sell” side of operations informs the “buy” side of operations capturing incremental improvements, innovating the program and constantly improving and solidifying the program on an affordable schedule that factors in legal counsel’s expert assessments regarding risk,” said Brad Geyer.

“It allows us to focus on the risk and emerging legal threats while PerfectShield™ gathers the information, red flags threats and channels those threats back to us in real time so that we can immediately follow through in a way that preserves the attorney client privilege.  Customized tracking and notification preferences allows inside compliance counsel, inside legal counsel and or management to track , statistically analyze performance and benchmark results moving forward,” said Geyer.  All the while, PerfectShield™ documents and records the performance and comprehensiveness of the compliance program for presentations to interested enforcement agencies, standards boards, acquisition candidates, large suppliers or large customers.

GeyerGorey LLP, with offices in Washington, New York, Boston and Philadelphia, provides international and inside-the-beltway experience to individuals and companies that have become — or wish to avoid becoming — the subject of federal law enforcement agency interest.

GeyerGorey LLP announces partnership with FormerFedsCompliance.Com

GeyerGorey LLP announces partnership with FormerFedsCompliance.Com

GeyerGorey LLP (GeyerGorey.Com) announced today that in development partnership with FormerFedsCompliance.Com, it is offering a Foreign Corrupt Practices Act Self-Assessment Module to its clients.  The Assessment Module is free to use for any company that administers the software solution through its own legal department or through GeyerGorey LLP.

GeyerGorey LLP is offering the FCPA Assessment Module as the first market deliverable assessment module as part its beta test of a FormerFedsCompliance.Com full-service compliance assessment solution that is forecasted to be released to law firms that will be selected in late Summer 2013.

The FCPA Assessment Module (available today) and software that delivers it is free and it is designed to measure FCPA risk at all levels of an organization within moments of conducting the assessment.  The secure FCPA assessment module is cloud-based and can be accessed immediately from desktops or handheld devices by all employees in an organization.  Results are tagged with customized privacy controls.  Results are measured and extensive statistical analysis is automatically performed, gaps are identified and significant problems—known as “company busters”—are immediately brought to the attention of GeyerGorey LLP for immediate follow-up by its attorneys and alliance professionals around the world.  The notifications are configured to protect the disclosure under attorney-client privilege, but GeyerGorey LLP and/or inside corporate counsel can still inform management so that it can continue to make informed decisions based on the progress of the assessment and remediation efforts.   Assessment responses can be measured and gaps can be identified and supplemental training can be targeted to problem areas.   For a reasonable licensing fee, a follow-on assessment is then performed that captures and “locks-in” programmatic improvement.  Each subsequent assessment can be customized and refined to the needs of the organization and additional customized modules can be added as needed.

The FCPA Assessment Module was designed by former American Enforcers (A/K/A”FormerFeds”) to allow companies to immediately assess their FCPA vulnerabilities with the assistance of inside legal counsel or GeyerGorey LLP.

GeyerGorey LLP can be reached at (888) 486-FEDS

FormerFeds LLC is headquartered in Cinnaminson, NJ and can be reached at [email protected] or at (609) 291-0881.

FormerFeds LLC
Suite 303
141 i Route 130 South
Cinnaminson, NJ 08077

FormerFeds LLC selects GeyerGorey LLP to Beta Test Compliance system

FormerFeds LLC selects GeyerGoreyLLP to beta test Compliance system

WASHINGTON — FormerFeds LLC today announced chosen GeyerGorey LLP to beta test its revolutionary Compliance system designed and deployed by former American fraud enforcers (a/k/a “FormerFeds”).  The FormerFedsCompliance.Com compliance solution is the newest weapon in the legal community’s arsenal  that seeks to help the legal community provide a ‘redundant complex risk prevention array’ for clients that is affordable and provides automated and organized support for a company’s compliance operations overseen and administered by inside legal counsel or alliance law firms.

The FormerFeds LLC compliance assessment solution (FormerFedsCompliance.Com) is designed to be administered by inside legal counsel or outside law firms like GeyerGorey LLP to maximize attorney client privilege protections.
The FormerFedsCompliance.Com Compliance Assessment solution will provide:

  • immediate assessment and gap analysis
  • centralized, whole-of-business risk and compliance visibility and benchmarking
  • easy configuration to meet any regulatory environment in any sector
  • unique compliance portal for customized assessments and notifications
  • red flag generation and tracking system designed to protect privilege
  • cost effective, low-risk, pay-as-you-go pricing

FormerFedsCompliance.Com has developed a ‘software as a service’ compliance assessment solution that our customers can ‘fire and forget’ system that melds compliance, transparency and corporate governance into one program solution.  With the legal assistance of GeyerGorey LLP, FormerFedsCompliance.Com is developing its compliance assessment system across disciplines so that there will be no wall between various specialties within a law firm—for instance, cartel enforcement and FCPA.

GeyerGorey LLP, with offices in Washington, New York, Boston and Philadelphia, provides international and inside-the-beltway experience to individuals and companies that have become — or wish to avoid becoming — the subject of federal law enforcement agency interest.

FormerFeds LLC is headquartered in Cinnaminson, NJ and can be reached at [email protected] or at (609) 291-0881.

FormerFeds LLC
Suite 303
141 i Route 130 South
Cinnaminson, NJ 08077