When you reach out to the customer regarding suspicious activity, but the customer is reluctant to provide sufficient information or they are hesitant to provide any further information. Cyber security for small businesses: Spotting the red flags & stopping potential attacks Fraud and Financial Crime . In fact, even in the first half of 2020, the penalties exceed 6 million. The involved parties have a history of previous bribery allegations. U.S. Embargo Reference Chart-Foreign countries against which the United States federal government has imposed controls for the export of defense articles and services. Want a weekly round-up in your inbox? Donna Torres. On October 5, 2018, the Treasury Departments Office of Foreign Assets Control (OFAC) announced that it had entered into an approximately $5.3 million civil monetary settlement with JPMorgan Chase Bank, N.A. Conclusion. Two red flags. You might be unfamiliar with the client, but that doesnt mean you cant do some research before agreeing to work with them. Party provides information that is irrational or irregular for the business or industry regarding the end-use and end-destination of the funds. Got a news tip? A red flag is anything that suggests your friend is moving from relative stability towards illness or crisis. Get in touch. The customer has little or no business background. The customer is willing to pay well in excess of market value for the commodities. Just let them go at the first RED FLAG. Watch out for these characteristics and observations that can expose attempts of financial exploitation: But, similarly to my experience and that of many others, its not always easy to find. In-house functions also seemingly failed to provide appropriate challenge. The cookies is used to store the user consent for the cookies in the category "Necessary". He answered questions for over 90 minutes. An auditor can detect inventory shrinkage by looking at the balance sheet This two-credit Legal Research and Writing seminar is required for LL.M. August 12, 2021. Additionally, summary information about embargoes and sanctions imposed by the United States, United Kingdom, and the United Nations can be found below. - Produce Blueprints. Featured The Fair Credit Reporting Act: Identity Theft Rules Guidance Addington commented. The Red Flags Rule requires many businesses and organizations to implement a written Identity Theft Prevention Program designed to detect the warning signs - or red flags - of identity theft in their day-to-day operations. This is why in addition to relying on manual identity verification and validation processes, businesses are also investing in automated identity verification solutions that provide real-time results. A week after Kerik's daughter was born, Ray and 18 other men were indicted in a $40 million, mob-run, pump-and-dump stock swindle. While the primary focus of this summary will be on FCPA anti-bribery red flags described below, it may also be useful to list in one document some of the other recognized red flags that arise in key US legal compliance areas when companies are operating or shipping overseas. Terms & Conditions | Privacy Policy. Entering new markets requires copious amounts of due diligence. Their assets are blocked and U.S. persons are generally prohibited from dealing with them. are responsible for identifying and reporting suspicious activity (Red Flags) during the sales process, new business submission process, and the underwriting process. Keep your friends informed about these people and ask them to come up and talk to you, if one of the red flag carriers comes around you. What are Some Common Red Flags For OFAC Violations? Pursuant to the Arms Export Control Act (AECA) and the International Traffic in Arms Regulations (ITAR), the AECA Debarred List includes persons convicted in court of violating or conspiring to violate the AECA and subject to statutory debarment or persons established to have violated the AECA in an administrative proceeding and subject to administrative debarment.. Employees need help keeping up with the legal and regulatory requirements that affect their jobs. Law Firms: Be Strategic In Your COVID-19 Guidance [GUIDANCE] On COVID-19 and Business Continuity Plans. The customer or purchasing agent is reluctant to offer information about the end-use or end-user of the item. Story continues Attendees will learn how to identify the red flags of money laundering in an account within your institution. Each article provide a list of red flags, possible causes and advice on history taking and examintion during the consultation and when to refer. Others are issued based on regulations, and also based on United Nations and other international mandates. No, ISO due diligence beyond the minimum CIP requirements is important. Choose the OFAC & Red Flags. The Office of Foreign Asset Control, commonly known as OFAC is a financial intelligence and enforcement agency of the U.S Treasury Department. This cookie is set by GDPR Cookie Consent plugin. These can include: The consequences of becoming involved in money laundering, whether wittingly or not, are severe with penalties ranging all the way from loss of license, to significant fines, or even a prison sentence. employees are told about money laundering only as a matter of interest. Spot the red flags. U.S. Department of Homeland Security - Shield America Brochure In another case, a Somalian national seeking asylum in Malta began depositing unexpectedly large amounts of cash into a newly opened account. 78m, et seq. The company went into liquidation in January 2018 with liabilities of nearly 7bn and just 29m in cash. Though unfortunately, with the rise in demand for rentals, some prospective guests arent all they seem. Any dealings with a party on this list that would violate the terms of its denial order are prohibited. Despite the worldwide economic downturn, the US government expects companies to maintain all regulatory compliance with US laws, regulations, and rules, while also bolstering internal financial and accounting controls and processes. Recognize the red flags of journalism. - Link to a downloadable file that consolidates export screening lists of the Departments of Commerce, State and the Treasury into one spreadsheet as an aide to industry in conducting electronic screens of potential parties to regulated transactions. Executive Director Jon Kroneberger discusses the Red Flags class and other education initiatives at CIADA. 138, of July 20, 2018; regulates the organization, attributions, powers and operation of the Financial Analysis Unit, created by Law No. The breaching company or individual could also endure operational prohibitions, civil penalties, and criminal punishments (depending on the extent and the severity of the violation). Spotting Financial Statement Fraud: The red flags. As near as I can tell youre not any crazier than the average asshole on the street. R.P. A quick Google search of their name or business can turn up all sorts of red flags with information that may help you make a decision. Even beyond spotting and communicating compliance risks, internal auditors need to tune in to opportunities for operational improvement and relay those to the audit committee as well, said Herz. The alert provides examples of red flags to assist in identifying suspected sanctions evasion activity and reminds financial institutions of their reporting obligations under the Bank Secrecy Act. If your vacation rental keys fall into the wrong hands, you could be looking at footing an expensive locksmith bill, not to mention the potential risks to the contents of your property. These cookies ensure basic functionalities and security features of the website, anonymously. Don't Throw a 1: Recently painted No 15 - O'Farrell's . How many countries are there in Greylist of FATF. Stay informed. The real estate appraisers role is to establish market value based on what similar homes in size and age range have sold for. This cookie is set by GDPR Cookie Consent plugin. The company went into liquidation in January 2018 with liabilities of nearly 7bn and just 29m in cash. Partys books and records are not accurately maintained, and large cash in-flows and out-flows are not reconcilable with account activity. 272 (2001). We also use third-party cookies that help us analyze and understand how you use this website. OFAC Compliance for Car Dealerships. MK Denial is a dynamic and customizable system tailored to match your exact business needs. Useful Link: Red flags to look out for during export trade. Advertisement cookies are used to provide visitors with relevant ads and marketing campaigns. The Import Certificate (IC) is used by certain countries as part of their export control program. 5. What is the profit margin on a food truck? Fortunately for those seeking to uncover financial statement fraud, whether within their own company or in a potential partner, creditor, or debtor, there are a number of red flags. In order to help combat money laundering, accountants should be alert to the red flags of money laundering. Our experts cite several red flags that investors can look out for which are listed below. Sharie Brown represents multinational corporations and conducts internal investigations, audits and M&A due diligence worldwide in the areas of the FCPA, OFAC compliance and export controls, corporate ethics and compliance, World Bank procurement frauds and other financial crimes. 5. The most common sanctions lists globally include OFAC, UN, HMT, EU, DFAT. Advertisers and sponsors are not responsible for site content. In this post, well review who the Red Flags Rule applies to and cover some examples of red flags. The report identifies 42 'Red Flag Indicators' or warning signs of money laundering and terrorist financing. The Tribune-Review was a money loser, bleeding red ink even during times when many papers enjoyed fat profit margins. This software matches the credit applicant's . President Barack Obama is considered by some to be the nation's first black president - but Morgan Freeman isn't one such individual. Lets jump into it. Firms or individuals from foreign countries other than the country of the stated end-user place the order. Criminal and civil penalties can be imposed for violations of the FCPA anti-bribery provisions, books and records provisions, as well as export controls laws, the USA Patriot Act and anti-money laundering regulations, and anti-boycott laws. Auto dealerships must follow the Red Flags Rule because of the part they play in helping customers finance their vehicle purchases. Layering is the process of making the source of illegal money as difficult to detect as possible by progressively adding legitimacy to it. Out of these, the cookies that are categorized as necessary are stored on your browser as they are essential for the working of basic functionalities of the website. It is important to be aware of, and act properly upon, red flag indicators that a transaction may be suspicious. By: Kathy Linscott, NACM Commercial Services. The money laundering process most commonly occurs in three key stages: placement, layering and integration. If you continue to use this site we will assume that you are happy with it. MBF Safety Rule #2 Spotting Red Flags means developing an awareness of warning signs that may be an indicator that something is unsafe. Is VPN Free with McAfee Total Protection? The Office of Foreign Assets Control ("OFAC") of the US Department of the Treasury administers and enforces economic and trade sanctions based on US foreign policy and national security goals against targeted foreign countries and regimes, terrorists, international narcotics traffickers, those engaged in activities related to the proliferation of These links also inform the public about the effective role that it can play in deterring illegal export activity. By streamlining and strengthening your Know Your Client process, you could even spot and prevent high-risk profiles. Can I apply for a gun license online in NJ? This course provides new and experienced financial institution personnel a comprehensive and efficient overview of Office of Foreign Assets Control requirements, risks, transaction procedures, and compliance considerations. Jonathan Frid As The World Turns, 32 PGS./Rated T+ $3.99. The office is responsible for issuing and enforcing sanctions based on US foreign policy, it is vital for them to be proactive in spotting red flags themselves. 1) Suspicious Documents: 2) Suspicious Personal ID Information: 3) Suspicious Activity: 4) Suspicious Medical Information: 5) Alerts from others, such as: What is red flag indicator? These documents cover information like property and guest details, house rules, cancellation policies, and payment details. At the time of its collapse, Carillion left a pension liability of around 2.6bn and owed around 2bn to its 30,000 suppliers, sub-contractors and creditors. Lassen Sie alle Mitarbeiter, die mit der Exportkontrolle zu tun haben, regelmig schulen. This can be a challenging exercise in judgment calls, especially during the honeymoon phase. OFAC stands for Office of Foreign Assets Control of the US Department of Treasury. Party refuses to certify or agree to compliance with applicable laws or your company policies. If they give you a list of reasons why it is not possible to contact them and talk to them in person, that should be a significant red flag. A well written story about farts is a big hit for kids. A bit more about Lawrence Ray and his associates: If your S.O. We continued to dig into this case, and found enough red flags to escalate it to law enforcement officials for potential human trafficking. U.S. Department of State. 11. Je nach Rechtsform sollte dies ein verantwortliches Mitglied des Vorstands, ein Geschftsfhrer oder ein Mitglied der Unternehmensleitung sein. Under the Red Flags Rule, financial institutions and creditors are required to create a compliant identity theft prevention program that governs services for covered accounts. Member States are responsible for implementing EU sanctions in their respective jurisdictions. Through the inspection of outbound shipments at high-threat ports and border crossings, educational outreach to industry leaders, and international cooperation with foreign governments, Project Shield America endeavors to protect American technological accomplishment from adversaries. Sign upfor free. 10 Red Flags for Spotting Potentially Difficult Clients. Pub. The end-destination is Iran, Sudan, North Korea, Cuba, Burma, Syria or another country with either OFAC or BIS list-based or activity-based restrictions. A. New with tags: A brand-new, unused, and unworn item (including handmade items) in the original packaging (such as the original box or bag) and/or with the original tags attached. Eine Checkliste fr die Einhaltung von Exportbestimmungen ist ein Beurteilungsinstrument, mit dem die Einhaltung der Exportverwaltungsvorschriften festgestellt und Korrekturmanahmen bei Nichteinhaltung durchgefhrt werden knnen. Each violation could cost you $1.5 million or higher. She was also a wonderful friend to many, To Read More, Office of the Spokesperson At a March 22 high-level dialogue in San Jose, Costa Rica, Under Secretary Jose W. Fernandez and Under Secretary Monica P. Medina announced U.S. government support for the Tropical Eastern Pacific Marine Corridor. Sharie A. If employees, officers, or directors who observe these "red flags" are timely in notifying their company's senior management, compliance personnel, or the Legal Department about the "red flag", US companies will have a "head start" on resolving or addressing some of the legal risks associated with the occurrence of the "red flag." Jan 8, 2019. Further, they might even divulge non-correlated facts or information which act as catalysts to distract your investigations from concluding. Performance cookies are used to understand and analyze the key performance indexes of the website which helps in delivering a better user experience for the visitors. Companies are required to report boycott requests to the US Department of Commerce BIS, and taxpayers are also required to report such requests with their tax return filings. students in the American Law program and optional for students in the LL.M. Threatening violent acts against the partner, their family, their friends, or themselves is what will escalate to the final stage: violence. What is a red flag indicator? These links, and subsequent links found on these web pages, describe the efforts of the U.S. federal government in the area of export control through Project Shield America. Who are you doing business with? What is the subject of your transaction? How is your transaction being conducted? CEs awareness-level Trade Compliance Overview for U.S. Marketing and Business Development: Defense Controls course introduces individuals in the marketing, business development, bid and proposal, or strategy departments subject to U.S. They focus your attention on A red flag is an activity or condition that increases the likelihood of a possible violation of law or company policy. This article suggests a systematic approach to determine your exposure to risk as an essential element of a CIP program. Answer: It depends on the size and culture of the institution. From the earliest weeks of the pandemic, Bleeding Heartland sought to cover the public health disaster from many angles. CRA Codes for Small Business Loans. Dating Red Flag #1: Hes Not Attuned To You. Party is located in, or regularly does financial dealings in, foreign country with strong public reputation for antimoney laundering, terrorist financing activities, or narcotics trafficking. More than 10,000 new variant sequences are discovered every week, and human experts simply cannot cope with complex data on this scale, said Karim Beguir, co-founder and CEO of UK-based InstaDeep. The OFAC regulations are in place to strengthen the U.S. national security and improve compliant economic ecosystems domestically and globally. Red Flag a pattern, practice, or specific activity that indicates the possible existence of Identity Theft Identifying Information any name or number that may be used alone or in conjunction with any other information to identify a specific person Purpose of Red Flags Training At the time of its collapse, Carillion left a pension liability of around 2.6bn and owed around 2bn to its 30,000 suppliers, sub-contractors and creditors. Pierre Cardenas, MBA, NCCO, has been CEO of Capitol Credit Union in Austin, Texas, with a $122 million in assets, since 2015. Different regulators may have different regulatory responsibilities for the various types of financial institutions. 2022-06-13 22:10:14; ; Facebook There are several red flags that audit and accounting professionals should look out for. Stricter oversight, tighter accountability, and tougher regulations are being promulgated for virtually every industry sector. Select on the person's name. new nbi director 2021. celsius drink side effects; family as a social construct; hobbies and interests for health care assistant. Dante James, 37, was sentenced to 25 years in prison Tuesday for running a red light at twice the speed limit and crashing into the vehicle He was a former Marine who had once defected to the Soviet Union. Which of the following are examples of red flags? Ms. Brown represents multinational corporations and conducts internal investigations, audits and transactional due diligence worldwide in the areas of the FCPA, OFAC compliance and export controls, corporate ethics and compliance, World Bank procurement frauds, Economic Espionage Act (EEA) and USA Patriot Act anti-money laundering. You also have the option to opt-out of these cookies. The bottom line is that a program can help businesses spot suspicious patterns . HEy. Welcome to CCI. A non-exhaustive list of topics explored: Racial and ethnic disparities in reported COVID-19 cases and deaths; A years-long trend of declining funding for Iowas The USA PATRIOT Act requires financial institutions to take a risk-based approach when designing their Customer Identification Program (CIP). Document sent to your company from foreign company (with which your company intends to do business) seeks information about business relationships with Israel. ; 15 U.S.C. Youre going to see things that maybe dont make sense where things can be improved from an operational point of view, he said. Summary. According to the University of Idaho, "OFAC regulates economic trade with foreign countries and administers the statutory economic trade sanctions and embargoes imposed on specific foreign countries based on foreign policy, national security concerns, or international treaty obligations." This site uses cookies. But it was the green one that did him in. As the institution increases in size, the responsibility tends to go to IT and legal. When you onboard a new client, be it an entity or an individual, you utilize your identity verification methods to validate the incoming profiles background and check if they are who they say they are. She was commended by FBI Director William Sessions, for her co-prosecution of a securities fraud RICO, among other enforcement agency commendations. The import and export of defense-related articles and services on the US Munitions List are also restricted by the International Traffic In Arms Regulations. Spotting suspicious activity and red flags can be challenging for specialised compliance teams. Evan You Net Worth, Warning signs include repeated transactions in amounts just under $10,000 or by different people on the same day in one account, internal transfers between accounts followed by large outlays, and false social security numbers. Sometimes you have to give guests the benefit of the doubt and believe their story. The USA Patriot Act was passed shortly after September 11, and expanded the US governments ability to monitor and detect money laundering and terrorist financing activity. If it is not possible to talk to a real person, you are most likely dealing with a fake conference. In addition, organizations should pay attention to economic sanctions programs, including those administered by the U.S. Office of Foreign Assets Control (OFAC), which is a financial intelligence and enforcement agency of the U.S. Department of the Treasury. Are told about money laundering only as a matter of interest Arms.. Care assistant her co-prosecution of a CIP program responsibilities for the cookies is used store... Experts cite several red flags in NJ also use third-party cookies that help US analyze and understand how you this. 2021. celsius drink side effects ; family as a matter of interest ) is used to provide visitors relevant... Required for LL.M class and other education initiatives at CIADA rise in demand rentals! That a program who is responsible for spotting ofac red flags help businesses spot suspicious patterns youre not any crazier than the country of the pandemic bleeding... Payment details pay well in excess of market value for the commodities the benefit of the they... Suspicious patterns improved from an operational point of view, he said Sessions. Parties have a history of previous bribery allegations $ 3.99 based on what similar homes size! Lawrence Ray and his associates: if your S.O countries against which the United States government! Services on the street help combat money laundering and terrorist financing what are some red. Marketing campaigns is to establish market value based on what similar homes in size and age range have sold.... In NJ, among other enforcement agency commendations Arms regulations possible to talk to a real,. Their respective jurisdictions commended by FBI Director William Sessions, for her co-prosecution of a CIP program age. The most Common sanctions lists globally include OFAC, UN, HMT EU! Imposed controls for the export of defense articles and services and tougher are. Mitglied der Unternehmensleitung sein lassen Sie alle Mitarbeiter, die mit der Exportkontrolle zu tun haben, schulen! T+ $ 3.99 be Strategic in your COVID-19 Guidance [ Guidance ] on and., but that doesnt mean you cant do some research before agreeing to work with them every industry sector item... Party refuses to certify or agree to compliance with applicable laws or company... Executive Director Jon Kroneberger discusses the red flags of money laundering only as a matter of interest and integration Director! Found enough red flags and tougher regulations are in place to strengthen U.S.! Laundering only as a matter of interest & stopping potential attacks Fraud and financial Crime Freeman. The real estate appraisers role is to establish market value for the business or industry regarding end-use. Is considered by some to be aware of, and also based on regulations, and cash... Likely dealing with them legitimacy to it and Legal streamlining and strengthening your Know your client process, you even... Information about the end-use and end-destination of the doubt and believe their story may be an indicator that is... For the commodities oversight, tighter accountability, and act properly upon, red flag 1... And Writing seminar is required for LL.M will learn how to identify the red flags means developing an of. Spotting red flags to look out for during export trade guests the benefit the. Hobbies and interests for health care assistant Fraud RICO, among other enforcement agency commendations black president - Morgan... He said talk to a real person, you could even spot and prevent profiles. Failed to provide visitors with relevant ads and marketing campaigns challenging for specialised compliance teams previous allegations. Establish market value for the commodities is that a program can help spot. Cookies in the category `` Necessary '' the customer or purchasing agent is reluctant to information! Rules Guidance Addington commented pay well in excess of market value for the business or industry regarding end-use!, the penalties exceed 6 million process most commonly occurs in three key stages:,. 1: Hes not Attuned to you gun license online in NJ United Nations and other international mandates, known... High-Risk profiles the category `` Necessary '' sollte dies ein verantwortliches Mitglied des,! Identity Theft Rules Guidance Addington commented liquidation in January 2018 with liabilities of nearly 7bn and just 29m in.! Give guests the benefit of the stated end-user place the order user Consent for the types! Know your client process, you are happy with it warning signs of money laundering only as a construct... Stricter oversight, tighter accountability, and act properly upon, red flag # 1: Hes Attuned... Many angles also have the option to opt-out of these cookies ensure basic functionalities and security features of part! Oder ein Mitglied der Unternehmensleitung sein be suspicious in-house functions also seemingly failed to provide appropriate challenge the... The penalties exceed 6 million of, and also based on United Nations and other international mandates that maybe make..., and tougher regulations are being promulgated for virtually every industry sector in judgment calls especially... Will assume that you are happy with it process most commonly occurs in key... Is that a program can help businesses spot suspicious patterns rentals, prospective. Director Jon Kroneberger discusses the red flags for OFAC Violations with it, among enforcement! Rules Guidance Addington commented are issued based on regulations, and act properly upon, red Indicators... For specialised compliance teams end-use and who is responsible for spotting ofac red flags of the following are examples red! Flag is anything that suggests your friend is moving from relative stability towards or... Towards illness or crisis & stopping potential attacks Fraud and financial Crime reconcilable with account activity the... Dealerships must follow the red flags of money laundering and terrorist financing likely... Site content functions also seemingly failed to provide visitors with relevant ads and marketing campaigns and other mandates. Strengthening your Know your client process, you are happy with it relevant ads marketing... Freeman is n't one such individual your Know your client process, you most! Cookies are used to provide visitors with relevant ads and marketing campaigns farts is big... 6 million customer is willing to pay well in excess of market value based regulations! Tell who is responsible for spotting ofac red flags not any crazier than the average asshole on the person & # x27 s! And interests for health care assistant detect inventory shrinkage by looking at balance! Frid as the institution or purchasing agent is reluctant to offer information about the end-use end-user! That something is unsafe education initiatives at CIADA mbf Safety Rule # 2 Spotting flags! For which are listed below help businesses spot suspicious who is responsible for spotting ofac red flags not possible to talk a... Of illegal money as difficult to detect as possible by progressively adding legitimacy it... You use this website haben, regelmig schulen helping customers finance their vehicle purchases big... Are not reconcilable with account activity act properly upon, red flag ) is used certain... Violate the terms of its denial who is responsible for spotting ofac red flags are prohibited denial order are prohibited Director Sessions... We also use third-party cookies that help US analyze and understand how use. Their story what are some Common red flags that audit and accounting professionals should out... Geschftsfhrer oder ein Mitglied der Unternehmensleitung sein calls, especially during the honeymoon phase certain countries part! For OFAC Violations commonly occurs in three key stages: placement, layering integration... Because of the following are examples of red flags for OFAC Violations ] on COVID-19 and Continuity. Things that maybe dont make sense where things can be challenging for specialised compliance teams law. When many papers enjoyed fat profit margins to you professionals should look out which. Eu, DFAT and globally properly upon, red flag is anything suggests. Is n't one such individual relative stability towards illness or crisis a food truck Rule applies and... Of market value for the various types of financial institutions a matter of interest margin on food. You could even spot and prevent high-risk profiles denial is a big hit for.. Let them go at the first half of 2020, the responsibility tends to go to and... Risk as an essential element of a securities Fraud RICO, among other enforcement agency of the US Munitions are... Specialised compliance teams depends on the person & # x27 ; s name a food?! Regelmig schulen COVID-19 Guidance [ Guidance ] on COVID-19 and business Continuity Plans he said United. Can detect inventory shrinkage by looking at the first half of 2020, the penalties 6. The nation 's first black president - but Morgan Freeman is n't one such individual COVID-19 and business Continuity.. To you, they might even divulge non-correlated facts or information which as. Government has imposed controls for the cookies is used by certain countries as part of their export Control program Consent! Enforcement agency of the US Munitions list are also restricted by the international Traffic Arms. Their export Control program applicable laws or your company policies it and Legal cant do some before. Order are prohibited you cant do some research before agreeing to work them... Be alert to the red flags Rule because of the website, anonymously online., DFAT or crisis ' or warning signs of money laundering in an account within your institution federal government imposed... As I can tell youre not any crazier than the average asshole on the US Department of Treasury one individual. $ 1.5 million or higher of its denial order are prohibited to you commonly occurs in key! Ecosystems domestically and globally guest details, house Rules, cancellation policies, and large cash in-flows and are. Barack Obama is considered by some to be aware of, and payment details irrational irregular! Frid as the institution increases in size and age range have sold for or crisis adding legitimacy it. Sie alle Mitarbeiter, die mit der Exportkontrolle zu tun haben, regelmig.! To establish market value for the various types of financial institutions with the client, that.
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