Free Innocent as Sin by Elizabeth Lowell

do—call the FBI?”
    He leaned back. “No. That’s the last thing we do. The Bertones have been very good customers of American Southwest. This may all be some extraordinary coincidence, or, more likely, a cascade of misunderstandings. Andre is an international financial force. This may simply be the way they do business in his banking circles. We need to explore a little more, find out exactly what’s going on. If we don’t like what we find, we’ll file an SAR.”
    “But—”
    “So process this check,” he said, pushing it back to her, “just to keep Andre happy, while I figure out exactly what we ought to do.”
    Kayla’s stomach felt hollow. “Isn’t that a bit risky?” Especially for me.
    “Not if we can figure a way of covering the transaction for the moment. Is this an account you’ve handled before?”
    “I told you that it wasn’t. If I’d qualified this account previously, there wouldn’t be any question about the transaction.”
    He frowned, looking at the check again. Twenty-two million. “Yeah, I guess you did mention that. So we can’t clean it up that way.”
    Clean it up? Kayla asked silently. I don’t like the sound of that. But then, I haven’t liked the sound of anything since Elena handed me that check.
    The light on one of Foley’s telephones blinked, alerting him to an incoming call. He ignored it.
    “What we need to do is find a way of carrying the transaction on our books that won’t put us at risk but will buy us a little time,” he said. He looked at the check again. “Bank of Aruba, Sugar Sands branch…Wait a minute, wait a minute.”
    He spun his high-backed executive chair and addressed the flat screen of his desktop computer. His fingers moved rapidly over the keyboard, drilling down through pages and documents.
    “There,” he said. “I knew I remembered that name. They have a correspondent banking relation with us. They’ve had it for some months now. That will make things much easier.”
    Some of the tension seeped out of Kayla.
    The light still blinked on the desk phone.
    Foley turned back to her. “Here’s what we do. You call theAruba bank. Make sure Andre has the money in the account, then put a hold on the funds and tell them you intend to run the draft through their correspondent account.”
    Kayla hesitated. “I don’t know nearly as much as you do about international banking and correspondent accounts, but is it legal? Who’s responsible for knowing the customer?”
    Foley kicked back in his chair. “Not us, for damn sure. Our correspondent, aka the Bank of Aruba, Sugar Sands branch, is on the spot for due diligence.”
    She looked as doubtful as she felt. “You’re certain?” It’s my ass on the line.
    “Standard operating procedure,” he said. “If anybody challenges us, we simply say we assumed the Aruba bank had done their own due diligence on the account before they let Andre start writing checks of this size.”
    “Would it fly?” Kayla asked bluntly.
    The telephone light stopped blinking.
    “It’s defensible, which is all that matters. By the way, I really like how you wrinkle your nose when you’re thinking hard.”
    She barely heard the personal remark. She was focused on legalities. “But pushing it off on the Aruba bank is just a bookkeeping trick, almost under the heading of ‘the dog ate my due diligence.’ How does it get me off the hook?”
    Foley laughed. “Sweetie, the bank business is all about bookkeeping tricks. The government makes unenforceable antibusiness regs, and the lawyers find ways around them. Correspondent accounts are a legal superhighway. Nobody ever checks the correspondent accounts, not inside the bank and not at Treasury. Everybody is clean and everybody is happy.”
    Kayla wished she was happy about what she was hearing, but she wasn’t. If the feds came down on her, she wanted something more solid than a “defensible” position to shield her.
    The telephone light started blinking again,