Kenneth Rijock

Kenneth Rijock

Wednesday, October 17, 2018

THE EUROPEAN UNION BLACKLISTS THE FIVE EAST CARIBEAN CBI STATES AS HIGH-RISK



As we have repeatedly warned would eventually happen, the European Union, acting through the OECD, has identified the five East Caribbean states with CBI programs, as constituting high-risk schemes. The Blacklist, which experts have warned might occur due to multiple failure of the CBI states to address misuse of tax residence, and their cooperation in assisting in hiding assets offshore, to escape the Common Reporting Standard (CRS), could seriously affect foreign investment, tourism, and trade.



Listed jurisdictions please note:  Removal from the Blacklist may require several years of proven local reform before it is granted by the OECD, if we take into account the efforts that were needed for removal from the FATF NCCT Blacklist.

All the five East Caribbean CBI states are on the list, entitled Residence/Citizenship by Investment Schemes:

Antigua and Barbuda
Dominica
St Kitts & Nevis
Grenada 
St Lucia

 Whether the OECD designations will affect the assessment of Country Risk on these jurisdictions by compliance officers at major international banks is not known at this time, but negative consequences are to be expected. Country Risk levels, though an individual appraisal by individual compliance officers, are based upon several factors, which include the jurisdiction's presence or basence from sanctions lists, or other indicators of high risk.



Additionally, increased De-Risking, meaning the termination of additional correspondent banking relationships at financial institutions located in North America, and in the European Union, may occur, especially due to existing risk-based compliance policies and procedures. Some EC states may lose all their correspondent relationships at a specific country as the direct consequence of the OECD action. One should not underestimate the impact of this decision of the European Union upon the jurisdictions designated as high-risk. Unfortunately, all of them had ample warning, but chose to ignore the probable consequences of inaction.

 
 

Tuesday, October 16, 2018

IS THIS DOMINICA DIPLOMATIC PASSPORT IMAGE AN EFFORT TO DEFEAT FACIAL RECOGNITION SOFTWARE ?


 Take a close look at the image on this Commonwealth of Dominica diplomatic passport. You should recognize the face; it is Alireza Monfared, the suspected Iranian intelligence agent who, with Reza Zarrab, and Babak Zanjani, ran the multi-billion dollar Iran oil-for-gold sanctions scheme. He is currently being held, indefinitely, in a Tehran prison, facing the death penalty, after Iranian agents took him into custody in the Caribbean, on corruption charges.

Why is the image a drawing, instead of a photograph ? You can clearly see that his Iranian passport, which contains a photo, betrays the fact that the drawing is a little bit off from a true life image.


Now look at his son's Dominica CBI passport; even he has a photograph.



For these reasons, we must assume that Dominica assisted Monfared in an attempt to make his passport confusing to facial recognition software programs. Perhaps someone should tell the individuals in Roseau, at the Citizenship by Investment Unit (CIU) that facial recognition software can identity, and has been used specifically for, identifying images that appears in painted portrtaits , through the application of facial recognition algorithms.

In fact, facial recognition software has been used, successfully, to identify unknown subject in some of the world's great paintings and portraits. Many paintings, over the course of time, pass through many hands, and in the case of some, the names of subjects, as well as minor figures, are lost. Facial recognition software is now employed to identify unknown faces in portrait art.

Lorenzo de Medici

The next time some bright soul in the East Caribbean CBI states thinks that he can outwit facial recognition software platforms, through portraits, and color drawings, of dodgy CBI passport holders, he might want to reconsider.

Lorenzo de Medici (posthumous portrait)


TURKISH BANKER CONVICTED IN ZARRAB IRAN OIL SANCTIONS EVASION CASE FILES HIS BRIEF



Attorneys for Mehmet Hakan Atilla, convicted of assisting Reza Zarrab's oil sanctions evasion syndicate in illegally selling Iranian oil, have filed their initial brief. The appellant received a 32-month sentence after his conviction.

Cousel for Atilla has framed these issues on appeal:

(1) The trial court erred when it instructed the jury that it could convict Atilla of violating the International Emergency Economic Powers Act (IEEPA) if it found that he conspired to evade ort avoid the imposition of secondary sanctions.

(2) The appellant should be entitled to a Judgment of Acquittal, because the Government presented no evidence that he know the alleged scheme would involve US banks.

(3) The defendant should be acquitted because of the Court's  interpretation of IEEPA sanctions regulations.

(4) The Court abused its discretion by precluding the defense from introducing recorded jailhouse conversations of Zarrab.

Most Federal criminal appeals statistically are affirmed, save obvious reversible error, as the courts generally do not wish to disturb a jury verdict, which in this case was unanimous.

As for Zarrab, he was seen by journalists staying in a downtown New York City hotel, under an alias, and not in law enforcement custody. This is extraordinary considering his previous guilty plea to criminal charges, which bring a possible life sentence. Given the strict nature of post-conviction policies, he may be cooperating with the intelligence services, who are more flexible in how they treat cooperating individuals.

 He is known to be assisting the Office of Special Prosecutor in its ongoing investigations, but whether his assistance involves Russian interference in the US 2016 Election, or some other issue, is not known. Zarrab is known to have shipped large sums to Russia, one of which was seized by Turkish authorities, in the possession of Zarrab's driver.


Monday, October 15, 2018

UNITED KINGDOM WILL NOT ABOLISH THE £50 NOTE; SUCH AN ACTION WILL NOT IMPACT MONEY LAUNDERING



The first time that I attempted to purchase a ticket on the Heathrow Express, and learned that one cannot use a £50 note for that purpose, I realized that the fifty was not generally accepted in the UK for all purposes. Recently, government officials have decided against eliminating the fifty Pound note, in what I regard as a wise move, for such an action will not take a bite out of money laundering.

Yes, money launderers engaged in bulk cash smuggling, tax evaders, and those who engage in illicit business, use large denomination currency, but the £50, which is presently worth slightly less than $66, is not a favorite vehicle for that purpose. Frankly, it is too small a value. In Europe, the  €500 note is favored; outside the EU, it is the USD$100 bill that, due in part to its hard currency status, is preferred. In short, the removal of the fifty Pound note from circulation will not seriously suppress money laundering activities.



A relevant note; most international money laundering takes place using non-cash methods; wire transfers, trade-based money laundering, international product diversion, and real estate purchases and sales. Moving large amounts of value is simply too difficult a task, with elevated dangers of discovery and seizure. Laundrymen today choose methods that are lower risk than bulk cash smuggling. Therefore, we agree with the UK Government action, as the effect of eliminating a high value note would not effectively stop crime; it would just inconvenience consumers, forcing them to carry more notes, of lesser value, to transact legitimate business. 


Sunday, October 14, 2018

DUTCH NATIONAL WITH DOMINICA CBI PASSPORT EXTRADITED TO FACE MONEY LAUNDERING CHARGES



A Dutch businessman who was known to be a wealthy resident of Dominica, and who held a Dominica Citizenship by Investment (CBI) passport, has been returned to the Netherlands, where he is said to face major money laundering charges in Europe. He is the latest dodgy foreign national who obtained a CBI passport in Dominica to have been subsequently arrested on serious criminal charges abroad.

Ronald Pieter Nolen was taken into custody by Dutch law enforcement authorities in Sint Maarten, Netherlands Antilles, and transferred to the Netherlands, where he reportedly has been accused of being a major money launderer. Nolen, who lived in Dominica, by virtue of his CBI passport, maintained an affluent lifestyle there for several years. He was known for throwing lavish parties in his home, attended by members of the ruling Labour Party, including the Prime Minister, Roosevelt Skerrit.


Is this a photograph of Ronald Pieter Nolen ?

These upscale celebrations are said, by those familiar with them, to be just like those hosted by another CBI passport holder, Alireza Monfared, the Iranian national now in custody in his native country, on charges he, together with partners that included Reza Zarrab and Babak Zanjani, stole billions of dollars in illegal oil sales profits. The circumstances of Monfared's arrest, by Iranian law enforcement agents in the Dominican Republic, are strangely similar to those of Nolen, who also was close to Dominica's most senior government officials, until he was removed from the country, after pressure from foreign law enforcement.

Dominica PM Roosevelt Skerrit & Alireza Monfared at dinner
 Nolen reportedly imported into Dominica as least fifty automobiles, many of which were luxury Mercedes Benz vehicles, which he gave as gifts to a number of prominent Dominicans. Automobiles, especially high value premium vehicles, are a well-known method of money launderers, who are seeking to clean dirty money; Hezbollah, for example was engaged in a massive operation to purchase cars in North America, and transport them abroad, for that purpose.

Nolen owned two Dominica shell companies, and used Dominica nationals as front men, to pose as the individuals in control; these companies were engaged in import operations, but whether they were a part of any money laundering scheme is not known. In fact, no details of Nolen's criminal case are not publicly available, and they appear to have been concealed by Dominica government officials, who fear public response to yet another arrest of a CBI passport holder.

One source stated that the name appearing upon Nolen's CBI passport is not his legal name,* but since Dominica is not transparent about public disclosure of the names of CBI passport holders, we are unable to confirm this information.

An individual with the same exact name is listed as being involved with corporations in Switzerland and we are investigating a number of leads, regarding details of Nolen's alleged money laundering acitivities, which will appear here when the research is completed. We gratefully acknowledge the contributions of our Dominica sources in assisting with this article.
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*Compliance officers have long known that neither East Caribbean CIP units, nor outside firms conducting due diligence, run applicant's photographs through facial recognition software programs, to confirm identities and legal names, and in truth and in fact, are complicit in allowing applicants to freely use aliases. There has never been a statement,  by any of the five East Caribbean states with CBI programs, that they employ facial recognition programs, notwithstanding the high-risk nature of most of the applicants, to confirm their identities.


Saturday, October 13, 2018

PANAMA SAYS ALEX SAAB HAS AN ARREST WARRANT IN COLOMBIA, BUT ANTIGUA PROMOTES HIM



Prominent members of Panama's legal profession have stated that they have personal knowledge of the existence of an arrest warrant for Alex Saab Morán, the Colombian businessman wno is allegedly the source of kickbacks and bribes paid to many of Venezuela's senior government officials. The Government of Colombia this week arrested Saab's reputed accountant and auditor, and charged them with multiple felonies, including money laundering.

The Saab case has focused, once again, upon the sale for cash of bogus diplomatic pasports by corrupt East Caribbean officials to foreign nationals engaged in white collar crime, international sanctions evasion, narcotics trafficking, espionage, tax evasion and fraud. Saab has held a diplomatic passport from Antigua & Barbuda for several years, and the Antiguan government, rather than disavow him after the news about the arrests in Colombia leaked out, has chosen to ally itself with him, calling him the country's "Economic Envoy," though failing to disclose whether he ever performed any diplomatic duties on its behalf.

Will any of the officers at the Antiguan banks that work with Saab be charged with money laundering in the United States, due to the fact that the funds moved were largely US Dollars ? We cannot say, but we will be watching events unfold n the Saab case, and report bank on all developments as they occur. 

INDIVIDUALS PERFORMING REGULATOR-ORDERED LOOKBACKS SHOULD USE FACIAL RECOGNITION SOFTWARE PROGRAMS TO CONFIRM IDENTITIES



If you carefully read the $40m Consent Order issued by the New York State Department of Financial Services, against Dubai's Mashreqbank PSC, you know that a Compliance Consultant must now be engaged to perform, among other tasks, a Lookback for a six-month period in 2016. He or she must then submit a report on the Transaction Review to NYSDFS. The methodology for conducting the Transaction review must be submitted in advance, to the regulator, the the individual, who has been designated in the Consent Order as the "Lookback Consultant."

It is submitted since "The sole and exclusive objective of this review ... is to inform the Bank's remediation efforts by determining whether suspicious activity involving high risk customers, or transactions or transactions or possible money laundering at, by, and through the Branch, were properly identified and reported, in accordance with suspicious activity reporting regulations and  New York Law." Consent Order at 10-11, that the Lookback Consultant, to more effectively prove that proper reporting actions were taken, or alternatively to show that they did not occur, all the individuals whose accounts the Branch reported on SARs should have their identites verified using a facial recognition software (FRS) program. Additionally, any transactions that the consultant deems, after review, should have been the subject of a SAR, must include FRS checks on all individuals linked to those transactions.

The object of the use of an FRS program in a Lookback is to verify that the Bank properly identified their customer, counterparties, transferees, and any other party to high risk transactions that were reported on SARs. It also allows the consultant to verify identities, or aliases, in transactions that he or she considers unreported suspicious transactions, where the bank failed to catch it.

In essence, the use of FRS programs not only checks the accuracy of a bank's ability to conduct Customer Identification, it can also expose an operational money laundering network whose participants are employing clean aliases, so as not to give away their dodgy personal histories. They will either help clear a bank, or focus in on compliance failures. These results can only occur when an FRS program is employed. While some compliance officers may still consider them optional, the ability of an innovative financial criminal to achieve a new identity at will requires that you rule out such possible actions of bank customers.

 FRS programs be deployed whenever Enhanced Due Diligence procedures are necessary. One can no longer depend upon government-issued forms of identification to identify a client. In the Mashreqbank case, it may be the only thing that actually clears the bank's compliance staff; use FRS as often as you check a customer or client on commercial off-the-shelf databases, to avoid being  deceived by smart financial criminals. Let the Mashreqbank $40m fine speak for itself.

 


Friday, October 12, 2018

ANTIGUA'S FOREIGN MINISTRY SAYS ACCUSED COLOMBIAN MONEY LAUNDERER WITH A & B DIPLOMATIC PASSPORT IS ITS ECONOMIC ENVOY



Our recent article,  Colombia arrests Accountant and Auditor of Alex Saab Morán, has generated an immediate reply from the Foreign Ministry of Antigua and Barbuda. Saab, who several investigative journalists, both in Venezuela and abroad, have accused of laundering the proceeds of corruption, for and on behalf of senior Venezuelan government officials, has never provided any proof that the transactions at issue were legitimate. Antigua claims that Saab has denied all allegations, but reports state that he is no longer in his native Colombia, and currently is living somewhere in Europe. We are therefore unable to verify whether the ministry was ever able to contact him, and assume that the denial it issued on his behalf was an unauthorized statement that purported to have come from Saab, but was merely a press release, attempting to place a spin on the arrests. There are close ties between senior Antigua government officials, and the corrupt Venezuelan officials Saab reportedly assists.

 The ministry, through a spokesman, stated to Carribean media that Mr. Saab, who holds a diplomatic passport from Antigua, is an "Economic Envoy." Our research has failed to find that he ever attended any economic conferences on behalf of Antigua, or assisted, in any way, in any economic matter involving Antigua. Saab has never presented his diplomatic credentials, and has never been appointed, as a working diplomat, to any state or jurisdiction. His title, which appears to be void under international law, allows him to circumvent customs inspection upon arrival at many international airports in the developing world.

Therefore, his diplomatic passport fails to comply with the requirements of the Vienna Convention, to which Antigua is bound, by virtue of its membership in the United Nations. Some legal observers are wondering why Antigua has not, of yet, revoked Saab's Antigua diplomatic passport, but cite the fact that he has an extensive relationship with at least two financial institutions in the country, as the reason he, and his business, are welcomed there. He is just the latest in a long line of dodgy individuals who come to the attention of the authorities for the wrong reasons, and who hold Antigua diplomatic passports.


NEW YORK REGULATOR IMPOSES $40m FINE ON MASHREQBANK FOR AML FAILURES


The New York State Department of Financial Services has levied a civil penalty of forty million dollars ($40m) upon the Dubai-based Mashreqbank PSC for massive BSA/AML failures, KYC inadequacies, and issues regarding the timely filing of Suspicious Activity Reports (SARs). Both the bank's UAE headquarters, and its New York branch, are named in the Consent Order, which was executed on October 10, and released yesterday (10/11/18).

Readers who wish to review the order may access the complete text of the 20-page document here.

Thursday, October 11, 2018

COLOMBIA ARRESTS ACCOUNTANT AND AUDITOR OF ALEX SAAB MORAN


Mendoza and Guerrero, in Colombian custody.


Colombian authorities have arrested Devis José Mendoza and Robinson Ruiz Guerrero, the accountant and auditor, respectively, of Barranquilla Businessman Alex Nain Saab Morán. Sr. Morán has close commercial ties to the Maduro government in Venezuela, and has been the subject of investigatory journalists seeking information on his alleged links to criminal activities in that country, after a Saab shell company obtained a contract with the Government of Venezuela for $685m.

The defendants have been charged with:

(1) Money Laundering.
(2) Acting in Concert in a criminal matter.
(3) Illicit Enrichment.
(4) Aggravated Fraud.

They are alleged to have facilitated the transfer, in international commerce, of $135m in goods; one report accuses them of laundering $25bn over a seven year period, 2004-2011.



Other family members of Saab are named as Persons of Interest in Colombia; his two brothers, an ex-wife, and  a cousin of the Auditor. Saab is represented by Abelardo de la Espriella, a Prominent criminal defense attorney, known for representing Colombian paramilitaries in criminal cases, and who maintains an office in Miami, through he is neither admitted to practice law in Florida, nor is he qualified there as a Foreign Law Expert. De la Espriella recently visited Antigua, where Saab holds an Antiguan diplomatic passport, according to public records. Saab has reportedly relocated to Europe.

Whether there will be any aditional defendants charged by Colombian authorities is not known, but we will be reporting on all further developments in this case.

Wednesday, October 10, 2018

ARE YOU BANKING ANY DIRTY NICARAGUAN PEPS ?

Events in Nicaragua could cause corrupt government officials, or Politically Exposed Persons (PEPs) associated with them, to choose to move some of their criminal proceeds out of the country, and into bank accounts in North America, or in the European Union.

The Financial Crimes Enforcement Network (FinCEN) has issued an Advisory, warning US financial institutions to be alert to the probability that affluent Nicaraguan nationals, professing to be business owners, independently wealthy individuals, purchasing agents for Nicaraguan trading companies, or other seemingly legitimate occupations, may seek to place dirty money at, or through, their bank, broker-dealer, or non-bank financial institution.

You are urged to:

(1) Read this Advisory.
(2) Show your front line staff photographs of all senior Nicaraguan government officials.
(3) Run your facial recognition software program on ALL Nicaraguan nationals that seek to open new account relationships, or to make large deposits to, or wire transfers into, existing accounts. Corrupt Nicaraguan officials, or PEPs working for them, will have valid passports with clean aliases, and only facial recognition software will properly identify their true names.
(4) Use bank staff members of Nicaraguan extraction, if possible, for any major new clients from Latin America, as they will be able to spot Nicaraguan nationals posing as citizens of other nations, through their regional accents and use of Nicaraguan slang.
(5) Decline their business, and document and report all such actions to your legal counsel, and consider the filing of a Suspicious Activity Report (SAR) .

Tuesday, October 9, 2018

WHAT INTEREST DOES THE OFFICE OF SPECIAL COUNSEL HAVE WITH REZA ZARRAB'S IRAN SANCTIONS EVASION SYNDICATE AND THEIR DOMINICA PASSPORTS ?

To be sentenced in December: Michael Flynn

According to the latest reports, General Michael Flynn, who is cooperating with the Special Counsel's office in the Trump Campaign/Russia probe, is linked to Reza Zarrab, the ringleader of the billion dollar Iran oil-for-gold sanctions evasion syndicate. If you read my recent article on Zarrab, you know that he is no longer in custody, and was photographed at a trendy restaurant in New York. Flynn's consulting company, Flynn Intel Group, had a number of foreign governments, companies and political figures as clients.



Zarrab, whose partner, Alireza Monfared, was the holder of multiple passports purchased from the Commonwealth of Dominica, and whose other partners reputedly also hold Dominica diplomatic and/or CBI passports, as well as those from other Eastern Caribbean States, is, according to many reports, giving important information to the Office of Special Counsel, the extent of which has not been made public. Zarrab's driver was arrested, in Turkey, en route to Russia, with $150m in cash, but Zarrab's relationship, if any, to the Russian nationals who are either defendants, or Persons of Interest, in the Trump/Russia influence case have never been made public, probably due to the fact that there are multiple pending investigations, in a number of Federal jurisdictions.


Dominica PM Roosevelt Skerrit and Alireza Monfared

 Dominca has been deeply involved in providing material support to Zarrab's sanctions evasion operation: Dominica-flagged oil tankers were used to transport illicit Iranian oil. Monfared hid behind a bogus diplomatic passport, when operating Zarrab's oil sale scheme in Labuan, Malaysia's obscure offshore financial center. How this is connected to the Trump Russia probe was cannot say, but the fact that our sources disclosed, in 2017, that the Prime Minister of Dominica, Roosevelt Skerrit, who was a close associate of Alireza Monfared, and is believedf to be under criminal investigation in the united States, further connects Dominica to the Muller Investigation.

There are a large number of sealed filings in Zarrab's NYSD Federal criminal case. Whether they represent sealed indictments, due to the fact that those defendants are outside the United States, and therefore not yet in custody, is not known,  but one must also remember that the Special Investigator's Office has unsealed cases, from time to time, and we will have to wait, to see whether our suspicions will be confirmed. Has Zarrab given evidence that the Special Counsel will use to bring additional indictments ?

SENATORS CITE CONTINUING AND UNSOLVED PROBLEMS WITH MONEY LAUNDERING THROUGH REAL ESTATE



US Senators Sheldon Whitehouse and Chris Van Hollen, in a letter to the Comptroller General, detailed their concerns about the use of real estate to launder the proceeds of crime. The Senators, well aware of the power of the real estate industry, which has successfully managed to exempt real estate from both the Bank Secrecy Act and the Money Laundering Control Act. They have asked the Comptroller to examine the effect of the Geographic Targeting Orders (GTO) upon the anti-money laundering efforts of law enforcement and regulatory agencies.

Readers are urged to read the entire letter, which appears below.


Monday, October 8, 2018

305 RUSSIAN INTELLIGENCE AGENTS IDENTIFIED THROUGH AUTOMOBILE RECORDS






These are the seven Russian GRU (Main Intelligence Directorate) agents who have ben charged with cyber-crimes in the United States. Three hundred and five other GRU agents have also been identified through their automobile registrations, all of which show their home addresses as the GRU barracks where the cyber-crime unit is based. Below are two of their passports.


Readers who wish to examine the Indictment can review the complete text here:
 https://www.justice.gov /opa/page/file/1098481/download
The style is United States vs. Aleksei Sergeyevich Mirenets, et al  Case No.: 18-263 Crim (WD PA).

HAMAS CONTINUES TO STAGE TERRORIST FINANCING OPERATIONS FROM TURKEY



It appears that the Government of Turkey was being lest than honest when it assured the West that Hamas was no longer conducting terrorist operations from its territory. The Jerusalem District Court in Israel has recently sentenced one of its own Arab citizens to a term of imprisonment of three and one-half years for transporting 300,000 Euros from Turkey, into Israel, and delivering the money to Hamas contacts there.

Dara'am Jabarim pled guilty to:
(1) Assisting a terrorist orgaization.
(2) Contact with a foreign agent.
(3) Using personal property for terrorist purposes.
(4) Prohibited personal property transactions.

Jabarim, a businessman, met with Hamas officials in Turkey, who handed the funds to him. which were salaries for Hamas terrorists. 91,000 Euros were confiscated from his home in Umm al-Fahm in northern Israel.

AMERICAN REGULATORS RULE THAT COMMUNITY BANKS AND CREDIT UNIONS MAY SHARE AML RESOURCES



The major US regulatory agencies for financial institutions, OCC, FRS, FDIC,  FinCEN and NCUA, have issued an Interagency Statement permiting the sharing of BSA/AML resources, through a collaborative agreement, providing for the pooling of assets. There are certain restrictions and limitations. Readers who wish to review the Statement can access the complete text here

Sunday, October 7, 2018

ELECTION FRAUD AND BRIBERY ISSUES NEED REFORM IN DOMINICA



This letter, from the organization leading the peaceful protests in the Commonwealth of Dominica, details the critical issues surrounding election fraud in that country. Widespread election time bribery, the inportation of expatriate Dominicans to Roseau by free airline travel, and the award of temporary and short-term election time employment, haveall contributed to the problem. Here are some suggested solutions.

APPEALS COURT DISMISSES PONZI SCHEMER SCOTT ROTHSTEIN'S APPEAL OF GOVERNMENT WITHDRAWAL OF HIS RULE 35 MOTION




The Clerk of the Eleventh Circuit Court of Appeals has dismissed attorney/Ponzi schemer Scott Rothstein's appeal of the District Court's order granting the Government's motion to withdraw it's motion for reduction of sentence, and denial of the Defendant's request for an Evidentiary Hearing. The dismissal, which was on purely procedural grounds, for for failure to file and Appendix within the time required by the Court.

Counsel for Rothstein, the Fort Lauderdale attorney who sold bogus court settlements of sexual harrasment and discrimination claims to investors, in a sophisticated Ponzi scheme, where Rothstein and his staff actually forged court documents and judicial signatures, has sought to reinstate the appeal, which has already seen a number of prior procedural errors and mistakes. The Court has not yet ruled on this issue.

The Government's motion to withdraw its pending Rule 35 Motion for Reduction of Sentence occurred after Rothstein attempted to improperly assist his then wife, and others, to secrete and sell valuable jewelry, to avoid its sale to repay victims. Kim Rothstein and two other individuals were convicted for their role in that illicit activity.



Rule 35 motions provide that the Government, in its sole discretion, may seek a reduction of an existing sentence from the Court, and that discretion is well-settled law, but Rothstein's counsel nevertheless sought to enforce the reduction, on the grounds that the motion failed to expressly provide for a method for its withdrawal. Rothstein, who has been in custody since 2009, and is being held in a secure location, drew a fifty-year sentence. While his official Release Date has not been published, a rough calculation shows him leaving Federal Prison sometime in the year 2051, at which time he will be 91 years of age.




Saturday, October 6, 2018

CBI PASSPORTS ISSUED IN EUROPE AND THE CARIBBEAN MANDATE FACIAL RECOGNITION SYSTEMS FOR CUSTOMER IDENTIFICATION VERIFICATION



The nations of Europe and the Caribbean that offer Citizenship by Investment (CBI) programs have issued large numbers of passports to their applicants. Some of these CBI passport holders, when arrested, are found to be in possession of several passports, under multipe aliases and bogus identities. This poses a clear and present danger to international banks that accept affluent foreign clients, for their Customer Identification Procedures, as presently constituted, are ineffective to verify the identities of these individuals.

Why is this happening ? Some of the issues:

(1) Citizenship by Investment Units (CIU), under pressure to accept the vast majority of applicants, to meet budgetary goals of their government, intentionally scale back their due diligence inquiries, often at the express direction of their superiors.

(2) Corruption is a major factor, especially in nations with poor economices, and underpaid government officials and clerks. The lure of easy money, paid by or on behalf of criminal elements, is often too powerful to resist. Others are simply accepting bribes because it has become part of the CBI culture, particularly due to to payments by foreign-based CBI consultants, who gain extremely high commissions from each approved application.

(3) Technological gains, which have now advanced far beyond Photoshop manipulation and counterfeitting of documents, allow applicants to present seemingly authentic instruments, under names other than their own, which end up as clean identities on CBI passports.

(4) The translation or transliteration of names, from languages not using the Latin Alphabet, generally from Asia and the Middle East, means anyone making a small alteration of an applicant's true identity easy, and impossible to catch during due diligence. The result is a new identity, which computer searches of sanctions lists, conviction records, and blacklists will not spot.

Therefore, since you cannot trust the names appearing on CBI passports, as well as the underlying identity documents that were used to obtain them, only an examination of the images of the individuals  will be effective, and dispositive, in verifying the true identities you are seeking.

Facial recognition software platforms, which access social media and social networking resources, Internet images, visa photographs, official sources, proprietary image databases, CCTV and other image resources, are the only proven method of positive identification of targets. Data can be manipulated. counterfeited, altered or erased, even from official sources, and in official records.

Photographs which confirm identity of individuals, taken from a wide variety of outside resources not under the control of your target, will tell if you he is a Politically Exposed Person (PEP) hiding his identity, a member of an organized crime syndicate, a corrupt government official, a known terrorist financier, or simnply a legitimate international businessman. In this chaotic world of  document manipulation, which is made much more dangerous by the issuance of CBI passports to financial criminals, sanctions evaders, foreign intelligence agents and other high-risk individuals, only facial recognition software can cull them out of your new client list; Anything else will fail to extract the truth, resulting in an unacceptable level of risk on your part.



 


Thursday, October 4, 2018

FOREX COMPANIES ENGAGE IN TRANSNATIONAL CRIME WITH IMPUNITY



A recent case, involving foreign exchange (Forex) fraud illustrates the transnational, unregulated nature of an industry that, to date, has been able to evade meaningful law enforcement suppresion. A California investor, who had a small amount placed with a Forex company, was solicited by a high-power salesperson, who convinced him that he could reap a 50% return, and who therafter placed a large sum with the company. When he sought to access his "profits," he was then talked into sending even more money, so that he could "draw" on his money. As you might have guessed, he lost it all, over $180,000, according to a report.

These Forex firms, often run by career criminals and fraudsters, are generally:

(1)   Incorporated in one tax haven jurisduction, which is totally opaque regarding beneficial ownership of company stock, and in a different part of the world from the clients a/k/a victims.

(2) Qualfied to do business in a second dodgy jurisdiction, with frontmen on the documents there. You have no chance to obtain redress through that country's courts, due to rampant corruption

(3) Maintaining bank accounts in a third offshore financial center. This is also a placew where you waste your money attempting to get justice in court.

(4) the company's owners reside in a country that does not extradite its citizens, allowing them safe haven from criminal prosecution abroad. This makes them bulletproof from their victims' criminal claims.



If an investor intends to participate in Forex, he would be best served by engaging a firm in his own country, after making sure, through due diligence, that it is reputable and dependable. When investors are lured by puffing statements of overseas firms, boasting of huge profits, it is too good to be true.