Saturday, December 14, 2019
Friday, December 13, 2019
According to Malaysian media, the country's Sessions Court has made a ruling ordering Mun Chol-Myong, A North Korean businessmen living in the country, to be extradited to the United States, where he reportedly faces four counts of money laundering, and two counts of conspiracy to commit money laundering. Mun has been held in custody since his arrest in May; his defense is being paid by the local North Korean Embassy.
Though details are not known, Mun was engaged in the sale of goods, from Malaysia, to North Korea, through China. His attorney is claiming that the charges are politically motivated, aimed to pressure North Korea over its illegal ballistic missile program. The allegations, which have appeared in the local press, indicate a sophisticated money laundering operation, involving the use of front companies, and defrauding US banks, through the use of fraudulent shipping documents, all to support the illicit delivery of goods to North Korea, in violation of United Nations, and US, sanctions.
One report states that Mun had illegally purchased engines for maritime vessels, to be sent to North Korea, and there are also terrorism allegations against the defendant. His attorney has indicated that he will take an appeal to the High Court of the lower court decision. This case is believed to be the first involving the extradition of a North Korean national to the US on money laundering charges.
Posted by Kenneth Rijock at Friday, December 13, 2019
Thursday, December 12, 2019
Investors in the Grenada Sustainable Aquaculture/Citizenship by Investment program, whose funding for the GSA project was allegedly stolen by project managers, have demanded that the Government of Grenada reimburse each of them for the amount they paid into GSA, which was a government-approved project for individuals participating in the CBI passport program. There are estimates that eighteen million US Dollars was paid in, after which the project was abandoned by its operators, even before construction began.
The arguments made by investors, for Government relief, are supported by the fact that investment in an approved program was mandatory, for individuals seeking to acquire that prized Grenada passport. Investors assert that they relied upon the fact that GSA was a listed & approved project. They are claiming that they would not have invested otherwise, and that Government received lucrative fees in connection with the GSA program, which it should now disburse to the victims.
Additionally, there are well-placed concerns that, if Grenada declines to provide the requested relief to the investors, all of who are now bona fide Grenadian nationals, that litigation against the senior officials who were supposed to oversee and monitor the GSA program, both as individuals and as representatives of Government, will ensure, and the resulting scandal might destroy Grenada CBI, as consultancies that bring new clients into the program, will direct their customers to choose another jurisdiction, pending the outcome of litigation. Claims of Malfeasance in Office, and the acceptance of illegal kickbacks, as part of a scheme involving corruption, have been thrown about, which represent a direct threat to those officials allegedly involved.
For that reason alone, the reimbursement of investors' principal, since demand has been made, could be a solution that could save Grenada, especially its lucrative CBI program, from clear and present danger. Otherwise, expect litigation forthwith.
Wednesday, December 11, 2019
OFAC SANCTIONS ENTIRE MAHAN AIR FLEET - 48 AIRCRAFT - FOR PROVIDING LETHAL IRGC-QF MILITARY AID TO REBELS IN YEMEN
The entire Mahan Air fleet has been sanctioned by OFAC for the company's support of Iran's illegal ballistic missile program in Yemen. Readers who have bank clients in the aviation service industry may wish to review the list of Mahan Air aircraft sanctioned by Treasury, and notify their clients that these air frames cannot be serviced by US entities or individuals. The list appears here.
Posted by Kenneth Rijock at Wednesday, December 11, 2019
Tuesday, December 10, 2019
DUE DILIGENCE USING DATABASES OF HIGH-RISK INDIVIDUALS AND ENTITIES IS NO LONGER EFFECTIVE; WHAT'S NEXT ?
For twenty-five years plus I have been involved in anti-money laundering consulting, including seven years lecturing and writing for two companies selling commercial off-the-shelf databases of high risk individuals and entities, and a tour of duty with a major insurance firm, conducting enhanced due diligence of foreign applicants purchasing extremely large life policies.
While in the past, customer identification procedures and enhanced due diligence investigation at account opening, using databases and online resources, were generally effective to confirm client identities, that is unfortunately no longer the case. Standard commercial off-the-shelf databases, no mater how complete and how often they are updated, simply cannot cope with the current ability of financial criminals and terrorist financiers to obtain clean, bulletproof forms of identity, under aliases, that can stand up to the best Enhanced Due Diligence investigation, because even a deep dive will not expose a state-of-the-art passport, which has sufficient information support in place, to verify any and all inquiries as to identity. Customer identification can no longer be assured, at any level.
You can blame corrupt government officials, or the explosion of Citizenship by Investment (CBI) passport programs, which frequently afford financial criminals the perfect counterfeit identity, but we must focus on a solution. Thew only reliable Customer identification solution, the use of facial recognition technology to make a positive identification of a target, but there must be an extensive image library, of quality photographs, available to check the target's images against, and that does not yet exist for commercial, non-law enforcement, use. Whether it will ever be available, in a form adequate for CIP purposes, is not known; the sheer amount, and scope, of images required to be effective is huge.
So, if you cannot stop a financial criminal from opening an account, you must rely upon your ability to identify and interdict him, in real-time, using a financial crime detection platform. It is time to abandon traditional Customer identification techniques, as they are not effective today, and move on to identifying the money launderer by his transactions. If you do not have adequate programs for that purpose, you are advised to focus on acquiring them forthwith, lest you not only admit money launderers and sundry other types of financial criminals into your bank, but you fail to identify them in action.