Year: 2024

TD Bank Pleads Guilty to $1.8 Billion in Criminal Penalties, Totaling Over $3 Billion in Regulatory & Civil Penalties

TD Bank, one of the largest financial institutions in North America, has pleaded guilty to multiple felonies and agreed to pay a staggering $1.8 billion in criminal penalties, in a resolution that also involves civil enforcement actions totaling over $3 billion. This marks the largest penalty ever imposed under the Bank Secrecy Act (BSA) and signals a significant shift in how U.S. regulators are addressing persistent compliance failures in the banking industry. In an unprecedented move, the U.S. Department of Justice (DOJ) applied the Bank Secrecy Act’s daily fine provision—$500,000 per day for violations—making it the first-ever daily fine levied…

Alleged Hong Kong Crypto Swindler Tied to Singapore Money Laundering Syndicate

A Chinese national accused of stealing millions from investors after the collapse of a cryptocurrency exchange also owned companies with businessmen linked to major money laundering investigations in Southeast Asia — including one who has been convicted, and another suspect on the run. Hong Kong police have called Su Weiyi the “mastermind” behind Atom Asset Exchange (AAX), which had more than two million users before collapsing in 2022. Su Weiyi allegedly absconded with investors’ money, but returned to Hong Kong where he was arrested on July 18 and charged with theft. The charges have not been proven in court and…

Citigroup Ordered to Strengthen AML Compliance Amid Federal Scrutiny

Citigroup Inc., one of the largest banking institutions in the United States, has been ordered to significantly overhaul its anti-money laundering (AML) compliance programs following deficiencies uncovered by federal regulators. A consent order, issued jointly by the Federal Reserve, the Office of the Comptroller of the Currency (OCC), and the Federal Deposit Insurance Corporation (FDIC), requires Citigroup to implement sweeping reforms across its subsidiaries to address critical lapses in its oversight and governance. Citigroup’s global operations, including its ownership of Citibank, N.A. in South Dakota and Banamex USA in California, are governed by stringent U.S. anti-money laundering laws. The Bank…

Popular golf course to be sold after fraud scandal

A popular English championship golf course is set to be sold after becoming embroiled in a high-profile fraud scandal. Mill Ride Golf Club in Berkshire was one of a number of assets forfeited by the wife of a jailed banker following a six-year National Crime Agency (NCA) investigation into fraudulent acquisitions. Zamira Hajiyeva was forced to give up the Berkshire course – as well as a £14million Knightsbridge House – after the NCA concluded it was obtained as a “direct result of large-scale fraud and embezzlement, false accounting and money laundering.” Her husband Jahangir is the former chairman of the…

Raytheon to Pay Over $950 Million in DOJ Settlement for Defective Pricing, Foreign Bribery, & Export Control Violations

Raytheon Company, a defense giant and subsidiary of RTX, has agreed to pay over $950 million to settle criminal and civil investigations by the Department of Justice (DOJ). The hefty settlement addresses the company’s involvement in fraudulent pricing schemes, violations of the Foreign Corrupt Practices Act (FCPA), and breaches of export control regulations under the Arms Export Control Act (AECA). The DOJ has outlined two significant schemes. The first relates to Raytheon’s fraudulent pricing practices on U.S. Department of Defense (DOD) contracts, while the second involves foreign bribery in Qatar and the company’s failure to properly disclose such conduct in…

Kuwait’s measures to combat money laundering and terrorist financing

Kuwait has an adequate legal and supervisory framework to address illicit finance, but has serious shortcomings delivering effective outcomes, including its understanding, investigation and prosecution of money laundering and terrorist financing. The FATF/MENAFATF mutual evaluation report of Kuwait assessed the effectiveness of Kuwait’s measures to combat money laundering, terrorist financing and proliferation financing, and their level of compliance with the FATF Recommendations. Kuwait is a high-income country with low levels of violent crime but that nevertheless faces money laundering risks from crimes that include fraud, corruption, forgery and offences committed abroad. The country is exposed to terrorist financing risks from…

Justice Department Unveils Comprehensive Strategy to Combat AI-Enabled Cybercrime, Emphasizes International Cooperation

The Department of Justice’s Criminal Division unveiled today a sweeping new framework for addressing cybercrime and artificial intelligence-enabled criminal activities, signaling a major evolution in the federal government’s approach to technology-enabled threats. Principal Deputy Assistant Attorney General Nicole M. Argentieri, speaking at the Computer Crime and Intellectual Property Section’s Symposium hosted by the Center for Strategic and International Studies in Washington, DC, detailed the division’s ambitious strategy to combat increasingly sophisticated digital threats while safeguarding civil liberties and promoting responsible innovation. The newly released Strategic Approach to Countering Cybercrime marks the Justice Department’s most comprehensive response yet to the challenges…

UK sanctions Russian troops deploying chemical weapons on the battlefield

Russian troops involved in the abhorrent use of inhumane chemical weapons on the battlefield in Ukraine have been targeted by new UK sanctions. Russia’s Radiological Chemical and Biological Defence (CBR) troops and their commander have been sanctioned for the deployment of barbaric chemical weapons in UkraineUK calls out Russia’s flagrant violation of the Chemical Weapons Convention (CWC) and urges Russia to immediately cease all such activityaction continues the Foreign Secretary’s personal mission to target the full spectrum of the Kremlin’s malign activity through our arsenal of sanctionsRussian forces have openly admitted to using hazardous chemical weapons on the battlefield, with…

OCC Cracks Down: October Enforcement Actions Highlight BSA/AML Failures & Insider Threats

The Office of the Comptroller of the Currency (OCC) has unveiled its latest round of enforcement actions for October 2024, cracking down on banks and individuals for a variety of compliance failures. This month’s actions cover a wide spectrum of issues, from severe violations in Bank Secrecy Act/Anti-Money Laundering (BSA/AML) programs to internal fraud by individual employees. The most significant penalty on the list goes to TD Bank, which received a hefty $450 million civil money penalty, coupled with a cease-and-desist order, for BSA/AML compliance deficiencies. This penalty continues to send shockwaves through the financial sector. It highlights that when…

Billion-dollar cyberfraud industry expands in Southeast Asia as criminals adopt new technologies

A new report launched today has found that Asian crime syndicates have integrated new service-based business models and technologies including malware, generative artificial intelligence (AI), and deepfakes into their operations while establishing new underground markets and cryptocurrency solutions for their money laundering needs.The report, titled Transnational Organized Crime and the Convergence of Cyber-Enabled Fraud, Underground Banking, and Technological Innovation: A Shifting Threat Landscape, is the second in a series of ongoing threat analyses produced by the UN Office on Drugs and Crime (UNODC).“Organized crime groups are converging and exploiting vulnerabilities, and the evolving situation is rapidly outpacing governments’ capacity to…

DOJ’s New Corporate Compliance Blueprint: AI Risks, Whistleblower Protections, and Financial Accountability Take Center Stage

At the Society of Corporate Compliance and Ethics (SCCE) 23rd Annual Compliance & Ethics Institute, Principal Deputy Assistant Attorney General Nicole M. Argentieri delivered a keynote speech underscoring the U.S. Department of Justice’s (DOJ) evolving corporate enforcement landscape. Compliance professionals were at the center of her address, emphasizing their critical role in upholding corporate integrity. Argentieri’s speech wasn’t merely a high-level overview of DOJ priorities; it was a call to action for compliance officers and GRC professionals. With the increasing complexity of corporate crimes, driven in part by disruptive technologies like artificial intelligence, the DOJ’s message was clear: robust compliance…

New York Man Pleads Guilty in Crypto-Fueled $25M Money Laundering Case

The U.S. Attorney’s Office and the FBI announced on Friday that Yanbing Chen, a 30-year-old from Brooklyn, N.Y., pleaded guilty to his involvement in an international money laundering and drug trafficking conspiracy. The organization, led by Jin Hua Zhang of Staten Island, laundered over $25 million in drug proceeds and illegal funds. Chen delivered $50,000 in drug profits, which were converted to Tether, a cryptocurrency, and transferred to Zhang, minus a fee. The funds were traced to multiple countries, including Hong Kong, India, and Brazil. Additionally, Chen transported five kilograms of cocaine in two separate meetings under Zhang’s direction. Zhang…

UK-linked firms suspected of busting Russia sanctions

The government is carrying out 37 investigations into UK-linked businesses for potentially breaking Russian oil sanctions – but no fines have been handed out so far, the BBC can reveal.The identities of the businesses are unknown but it is understood some are likely to be maritime insurance firms.The Treasury said it would take action where appropriate, but pointed to the complexity of the cases as a reason they take considerable time.But Sir William Browder, a longstanding critic of Russian President Vladimir Putin, said it was an “embarrassment” that there had not been a single prosecution or fine for companies investigated…

UNODC report exposes escalating threat of organized crime in the Pacific

The Pacific is increasingly becoming an important transshipment hub and an operational and destination point for organized crime syndicates, according to a new report launched today by the UN Office on Drugs and Crime (UNODC).Titled Transnational Organized Crime in the Pacific: Expansion, Challenges, and Impact, the report provides a detailed analysis of the rapidly evolving organized crime landscape and related drivers. It highlights how foreign criminal groups are capitalizing on the region’s geographic isolation, infiltrating legitimate businesses and using new technologies to advance their illicit operations while evading law enforcement.“Transnational organized crime has become a significant security threat in the…

SFO recovers further £295,000 from convicted fraudster’s hidden pensions

The Serious Fraud Office (SFO) has recovered a further £295,000 from Virendra Rastogi, now known as Vareen Kumar or Veerain Kumarr, who was convicted for an international metal trading scam. The money was recovered from two pension funds as part of an ongoing proceeds of crime investigation into Rastogi’s assets, which has recovered nearly £6 million to date including from the sale of his Marylebone home and via the seizure of money and assets including valuable watches. Rastogi was one of three former directors of RBG Resources plc who was prosecuted by the SFO in 2008 for operating an international…

FCA fines Starling Bank £29m for failings in their financial crime systems and controls

The FCA has fined Starling Bank Limited £28,959,426 for financial crime failings related to its financial sanctions screening. It also repeatedly breached a requirement not to open accounts for high-risk customers. Starling grew quickly, from approximately 43,000 customers in 2017 to 3.6 million in 2023. However, measures to tackle financial crime did not keep pace with its growth. When the FCA reviewed financial crime controls at challenger banks in 2021, it identified serious concerns with the anti-money laundering and sanctions framework in place at Starling. The bank agreed to a requirement restricting it from opening new accounts for high-risk customers…

New York Regulator Fines Nordea $35 Million for Compliance Failures

The New York Department of Financial Services (DFS) has reached a $35 million settlement with Nordea Bank Abp over serious compliance failures and inadequate due diligence practices. The settlement, announced on August 27, 2024, by DFS Superintendent Adrienne A. Harris, follows an extensive investigation into the bank’s role in facilitating potentially illicit financial activities. The investigation, sparked by the 2016 Panama Papers leak, revealed Nordea’s involvement in helping hundreds of customers create tax-sheltered companies using offshore accounts. Further scrutiny uncovered the bank’s connections to major money laundering schemes, including the Russian Laundromat, the Azerbaijani Laundromat, and the Hermitage Capital Allegations.…

Secretive Cyprus-Registered Funds Were Used to Hide Megayachts and Luxury Real Estate Linked to Sanctioned Russian Banker

In Cyprus, a new type of investment fund was marketed to clients as a way to avoid disclosing their ownership of assets. In one case, these funds were used to obscure the ownership of offshore companies that allegedly held luxury assets linked to powerful Russian banker Andrei Kostin, including two megayachts worth tens of millions. Key FindingsTwo megayachts linked to Andrei Kostin were hidden behind secretive investment funds in Cyprus, known as “registered alternative investment funds.”The funds were managed by a company called Inveqo, owned by the wife of a sanctioned Cypriot lawyer.Registered alternative investment funds, or RAIFs, were marketed…

Student Smishing Scams on the Rise

At the start of the 24/25 academic year, the Students Loans Company (SLC) is reminding students to be vigilant of smishing scams. Scammers target students at this time of year as they receive their first maintenance loan payment. SLC is expecting to pay £2bn to students over the autumn term and last year it stopped £2.9m of maintenance loan payments being taken by smishing and phishing scams, where students received and acted on false communications. Smishing, which is fraud involving text messages, is currently the most popular form of scam, with students usually being asked to click a link to…

Wells Fargo Enters Agreement with OCC to Strengthen Anti-Money Laundering Controls

Wells Fargo Bank, N.A., has entered into a formal agreement with the Office of the Comptroller of the Currency (OCC) to address deficiencies in its anti-money laundering (AML) and financial crimes risk management practices. The agreement, announced today, outlines a comprehensive plan to enhance the bank’s compliance with the Bank Secrecy Act (BSA) and U.S. economic sanctions laws. The OCC identified several areas of concern, including violations related to internal controls, suspicious activity reporting, customer due diligence, and compliance with sanctions enforced by the Office of Foreign Assets Control (OFAC). In response, Wells Fargo has committed to implementing a wide-ranging…

UK Conservative Party Advisor Lobbied for Firm Founded by Russian Oligarchs

The man who served as chief of staff under former British Conservative Prime Minister Liz Truss has been lobbying for a company part-owned by two sanctioned Russian oligarchs. Romania’s Logging Industry Continues to Cheat the Timber Tracing SystemSix months after the fraud was exposed and Romanian authorities promised to stop it, wood processing companies continue to cheat Europe’s most sophisticated timber tracing system, allowing illegally harvested wood to enter the legal market. EU Parliament Calls for Sanctions on Georgia and its LeadersThe European Parliament voted in favor of a resolution calling for the EU to stop funding the country of…

Four insights for UK firms in the year of the PEP

The recent review by the Financial Conduct Authority (FCA), along with updates to the UK’s anti-money laundering regulations, has resulted in new requirements for firms: they must now classify ‘domestic’ PEPs as inherently lower risk compared to ‘non-domestic’ PEPs as long as there are no ‘high-risk indicators’ present. With the recent election completed and new MPs in office, UK firms are now facing the challenge of adjusting to these changes in guidance. As firms make operational adjustments in light of the UK’s regulatory update, the spotlight on PEPs presents an opportunity to reflect on four key insights. The FCA review…

SEC Charges Macquarie Investment Management Business Trust with $79.8 Million Fraud Settlement

The Securities and Exchange Commission (SEC) announced today that Macquarie Investment Management Business Trust (MIMBT), a registered investment adviser, has agreed to pay $79.8 million to settle charges of fraud. The case involves the overvaluation of illiquid assets and the execution of unlawful cross trades that favored certain clients over others. According to the SEC’s order, from January 2017 through April 2021, MIMBT managed the Absolute Return Mortgage-Backed Securities strategy, which primarily invested in mortgage-backed securities, collateralized mortgage obligations (CMOs), and treasury futures. The firm is accused of overvaluing approximately 4,900 largely illiquid CMOs held in 20 advisory accounts, including…

Walgreens to Pay $106.8 Million in Major Healthcare Fraud Settlement

Retail pharmacy giant Walgreens has agreed to pay $106.8 million to settle allegations of widespread fraud against government health care programs, the U.S. Department of Justice announced on Friday. The settlement resolves claims that Walgreens billed Medicare, Medicaid, and other federal health care programs for prescriptions that were never actually dispensed to patients. The alleged fraudulent activity spanned over a decade, from 2009 to 2020, during which Walgreens is accused of submitting false claims for payment, resulting in the company receiving tens of millions of dollars for prescriptions that were processed but never picked up by beneficiaries. Principal Deputy Assistant…

Mirabaud & Cie SA seriously violated financial market law

The Swiss Financial Market Supervisory Authority FINMA has found that Mirabaud & Cie SA breached its anti-money laundering obligations and seriously violated financial market law. FINMA determined this in enforcement proceedings. The bank failed to review and document sufficiently the economic background of client relationships and transactions. The bank may not accept any new clients with increased money-laundering risks until compliance with the law has been restored. Furthermore, FINMA has confiscated CHF 12.7 million of unlawfully generated profits and opened three proceedings against individuals.In June 2023, FINMA concluded enforcement proceedings against Mirabaud & Cie SA that were opened in June…

Danske’s France settlement ends final probe over suspected money laundering

COPENHAGEN (Reuters) -Danske Bank has reached a settlement with French authorities to end the final in a series of probes in multiple countries over suspected money laundering at its former branch in Estonia, the Danish bank said on Wednesday. Danske agreed to pay 6.33 million euros ($7.0 million) to settle an investigation in France, a fraction of the more than $2 billion it agreed to pay to end probes in the United States last year. The bank became the subject of several investigations after an internal probe in September 2018 uncovered about 200 billion euros of payments made through its…

Art Market Loopholes Again Threaten U.S. Economic Integrity and National Security

Federal Indictment Charges Kremlin Allies with Money Laundering and Sanctions Evasion On September 5, the U.S. Department of Justice unsealed two criminal indictments charging dual U.S.-Russian citizens with multiple felonies for using art, antiques, and other methods to violate sanctions imposed after the 2022 illegal invasion of Ukraine—a scheme that also allowed the married couple to launder at least $1 million through the U.S. financial system. Dimitri and Anastasia Simes allegedly provided services to and received substantial benefits from sanctioned Russian individuals and entities, including Channel One Russia, the state-controlled television network, and oligarch Aleksandr Udodov. Anastasia, specifically, is charged…

Swedish Court Sends Ex-CEO of Swedbank to Prison

Overturning her previous acquittal, a Swedish court sent former Swedbank CEO Birgitte Bonnesen behind bars for 15 months for having made misleading, financially damaging statements about the bank’s poor anti-money laundering operations. An expert called the verdict of the Svea Court of Appeals “unprecedented.” The lower Stockholm District Court had cleared Bonnesen of all charges in January 2023. Following revelations in 2017–2018 that hundreds of billions of dollars could have been laundered through Danske Bank’s operations in the Baltics, Bonnesen was asked by reporters if Swedbank had similar problems with ties to that scandal. “The court concluded that two of…

Inside Hamas’ Pocketbook : Financing Terrorism through online financial platforms

In the wake of the 7 October attack and the war that has followed, Hamas, the Palestinian Islamic resistance movement, has conducted much of its financial activity through established and emerging online financial platforms (OFPs) to support its rule in the Gaza Strip. Even though Hamas is designated as a terror organisation (and is therefore sanctioned) in the US, UK, EU and elsewhere, it has been able to take advantage of compliance-related loopholes and poor counter-terror financing (CTF) practices OFPs suffer from. Some of the OFPs Hamas uses and abuses include technologies such as online payment processors, virtual assets service…

FCA charges first individual with running a network of illegal crypto ATMs

The FCA has charged Mr Olumide Osunkoya, who is 45 and resides in London, for unlawfully running multiple crypto ATMs without FCA registration. Crypto ATMs are machines that allow you to buy or convert money into cryptoassets. Mr Osunkoya is accused of running crypto ATMs, which processed £2.6m in crypto transactions across multiple locations between 29 December 2021 and 8 September 2023 without the required registration. The charges mark the FCA’s first criminal prosecution relating to unregistered cryptoasset activity under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs). These are also the…

Post-Soviet Union Elite’s Involvement in UK Money Laundering

Dr Henry Balani, Global Head of Industry & Regulatory Affairs for Encompass Corporation comments: “Money laundering in the UK is a far more complicated an issue than one might expect, and there are thousands of unique and intricate relationships between UK finance professionals and international criminals which continues to contribute to the money laundering economy. Historically, London has been the centre of a vast physical empire that has now developed a financial powerhouse to support potential nefarious activities. Covid-19 and lockdown has certainly not helped either, as digital identity authentication and paperless transactions, for example, have made it easier for…

Money launderer jailed after extradition to UK

A man who laundered more than £2m has been jailed after being extradited back to the UK. Calin Barta, 29, originally from Romania, was sentenced at Guildford Crown Court to four years and 10 months in prison. Three years ago, Surrey Police executed a warrant at an address in Woking as part of an investigation into indecent image offences. However, whilst at the property, officers said they found multiple mobile phones and bank card readers along with 38 passports in different names but all with the same photo. Barta returned to Romania while he was on bail, said police. Surrey’s…

Lack of City of London oversight hurting efforts to halt dirty money, FCA warns

A lack of proper oversight across the City of London’s network of lawyers, bookkeepers and accountants is hampering efforts to crack down on dirty money being funnelled through the UK, the City watchdog has warned. The latest report by the Financial Conduct Authority (FCA) flagged concerns over the work of the UK’s 25 professional bodies – which oversee the accounting and legal sectors – and found that some were spending as little as £73 a year on anti-money laundering supervision or were outsourcing it entirely to third parties. It also found “weaknesses” in how bodies were using their powers, resulting…

UK announces new sanctions under Iran, Russia laws

LONDON, Sept 10 (Reuters) – Britain on Tuesday announced a new wave of sanctions, adding seven designations under its Iran sanctions regime and three under its Russia regime.Some of those sanctioned included firms and organisations with ties to the drone industries in Russia and Iran.The announcement came after U.S. Secretary of State Antony Blinken said Russia had received ballistic missiles from Iran and would likely use them in Ukraine within weeks.Alongside that announcement, made during a visit to Britain, Blinken said the U.S. would also impose new sanctions, including on airline Iran Air.France, Germany and Britain strongly condemned Iranian transfers…

Banks must refund fraud up to £85,000 in five days

UK banks must refund fraud victims up to £85,000 within five days under new rules. Most High Street banks and payment companies voluntarily compensate customers who are tricked into sending money to scammers. But in a world first, these refunds will become mandatory from 7 October, the Payment Systems Regulator (PSR) has announced. The watchdog has reduced the maximum compensation from a previous proposal of £415,000. It said the new cap of £85,000 would cover more than 99% of claims. It also announced that once a bank or payment company had refunded a customer, it could claim half back from…

DOJ’s New Whistleblower Program Faces Scrutiny from Legal Experts

The U.S. Department of Justice’s recently launched whistleblower reward program is drawing both praise and criticism from legal experts in the field. While many welcome the initiative, concerns have emerged about key aspects of the three-year pilot program. Introduced last week, the program offers financial incentives to individuals who provide original information or analysis related to financial crimes, bribery, or healthcare fraud. Deputy Attorney General Lisa Monaco announced the program in March, aiming to bridge gaps between existing whistleblower programs at other agencies. Legal professionals specializing in whistleblower cases have identified several potential shortcomings in the program’s structure: Funding Uncertainty:…

PwC Fined £15m for Fraud Alert Failures

PwC has been fined £15m for failing to alert the Financial Conduct Authority (FCA) to suspected fraudulent activity at London Capital & Finance (LCF). The FCA, which is fining an audit firm for the first time, said PwC encountered “significant issues” throughout its 2016 audit of LCF, with the company having and provided the Big Four outfit with “inaccurate and misleading information”. A senior individual at LCF also acted aggressively towards auditors. Considerably longer to complete According to the FCA, PwC found the audit very complex and it took “considerably longer to complete” than anticipated with the firm ultimately coming…

SEC Charges NovaTech and its Principals and Promoters with $650m Crypto Fraud

The Securities and Exchange Commission today announced charges against Cynthia and Eddy Petion, along with their company, NovaTech Ltd., for operating a fraudulent scheme that raised more than $650 million in crypto assets from more than 200,000 investors worldwide, including many in the Haitian-American community. The SEC also charged Martin Zizi, Dapilinu Dunbar, James Corbett, Corrie Sampson, John Garofano, and Marsha Hadley for their roles in promoting NovaTech to investors. According to the SEC’s complaint, the Petions operated NovaTech as a multi-level marketing (MLM) and crypto asset investment program from 2019 through 2023. They lured investors by claiming NovaTech would…

Whistleblowers Cash In: SEC Awards $98 Million for Crucial Tips

The Securities and Exchange Commission (SEC) has awarded a staggering $98 million to two whistleblowers. The announcement, made on August 23, 2024, underscores the critical role that individuals play in uncovering financial misconduct. The lion’s share of the award—$82 million—went to a whistleblower whose initial tip sparked the investigations and who provided ongoing assistance. A second whistleblower, contributing later but significantly to one aspect of the case, received $16 million. “Without these whistleblowers’ information, the violations would have been difficult to detect,” said Creola Kelly, Chief of the SEC’s Office of the Whistleblower, emphasizing the importance of such cooperation in…

Singapore Charges Ex-Bankers with Abetting $2.2 Bn Money Laundering Ring

Singapore charged two bankers Thursday for their alleged role in abetting clients responsible for a US$2.2 billion money laundering ring, marking the first time that criminal charges have been laid against finance professionals since the scandal came to light. The Central American Bank for Economic Integration (CABEI) has been trying to clean up its image after allegations of major mismanagement. But those efforts are now overshadowed by dueling lawsuits between the bank and its former president –– with each accusing the other of tarnishing their reputations. A former Georgian defense minister is under investigation for his alleged role in a…