Kenneth Rijock

Kenneth Rijock

Wednesday, June 26, 2019

ANTIGUA SEEKS TO REPAIR ITS IMAGE AFTER CHOKSI SCANDAL, BUT FAILS

Mehul "Larger than Life" Choksi
 
The Prime Minister of Antigua & Barbuda, Gaston Browne, has now publicly stated that Mehul Choksi, the billionaire diamond fraudster, who has used his Antigua CBI passport and citizenship to delay his extradition to his native India for one year, will have his Antiguan citizenship revoked after the extradition process is completed. Unfortunately, what PM Browne has failed to mention is the well-known fact that Choksi's extradition, to face justice, may never occur.

We call it Antigua's "Leroy King Rule, " named for the former banking regulator, who was Allen Stanford's Blood Brother [we mean that literally] who has now evaded extradition to the United States for more than a decade. Choksi, like King, may never run out of bogus "appeals," judicial reassignments, court delays, motions for rehearing, and similar dilatory actions, all of which delay any case indefinitely, as can only occur in Antigua's corrupt court system.

If Choksi is never extradited,  Browne never has to revoke his CBI passport and citizenship, although his standing offer to do so improves his status with Opposition leaders, and undecided voters, and wins the PM political points. Of course, Choksi may indeed grow old in Antigua, but that little detail has been conveniently left out. As an offer, Browne's efforts have been rebuffed from all quarters; the PR effort has failed.

Observers of the Antigua political scene have said that Browne's unusual offer, which runs against Antigua's longtime support of its CBI citizens, may have come due to what medical professionals fear is a decline in the Prime Minister's mental acuity, which is not age-related, but is reportedly occurring due to his family mental health history. It is time for a change in leadership. 
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Note: Readers who are not familiar with the Choksi or King cases will find that there has been ample prior coverage of both matters on this blog.

TAX EVASION SETTLEMENT WITH KPMG AND ITS CANADIAN CLIENTS WAS KEPT CONFIDENTIAL FROM THE PUBLIC


Our ongoing survey of cases involving the global accounting giant KPMG has turned up a dark chapter in the company's operations. It operated a scheme whereby high net worth Canadians, with assets that exceeded CAD$5m, were advised to secrete their funds in the Isle of Man, using shell companies. KPMG  received fees equal to fifteen per cent of the amount of the amount of taxes evaded by its clients. Over one hundred and thirty million dollars was placed into the scheme.

When Canada Revenue Agency regulators learned of the illicit program, it offered KPMG clients a sweetheart deal, involving no penalty, nor any jail time for the offenders. The agreements were made confidential, meaning that the public and the media were unaware that neither the investing public, nor the media, would learn of the arrangement. Furthermore, KPMG was NOT fined or sanctioned in any way. The entire settlement was kept out of the public eye, until it was leaked to the media by an anonymous whistle blower.

What we are seeing in a pattern whereby KMPG, and its officers, is repeatedly implicated, in case after case, of misconduct, verging at times as criminal, and due it its size, politics, or some other reason, is not held accountable for its misdeeds. This blog will continue to examine cases where KPMG's conduct has been found to be improper, unethical, amoral or criminal.  



 

Tuesday, June 25, 2019

THREE CHINESE BANKS LINKED TO NORTH KOREA



Three Chinese banks have been reportedly linked to money laundering for the North Korean-owned  Foreign Trade Bank (FTB). All three have allegedly declined to comply with a subpoena issued by the United States.



The banks named are;
(1) China Merchants Bank.
(2) Shanghai Pudong Development Bank a/k/a/ SPD Bank.
(3) The Bank of Communications.



None of the banks have been charged with any criminal activity as of this date. While we generally do not alert compliance officers to mere allegations of violations of international sanctions, any proven North Korean connection to these banks could result in a loss of access to the US financial structure. It is considered prudent for compliance officers at international banks whose clients trade with Chinese companies to check their records for any transactions with the banks listed above. 


Monday, June 24, 2019

YURY YEVGENYEVICH SAVIN - VIOLATION OF IEEPA


OFAC DESIGNATES RUSSIAN BANK FOR ASSISTING NORTH KOREA IN EVADING SANCTIONS



Treasury's Office of Foreign Assets Control (OFAC) has imposed sanctions upon a prominent Russian bank, the Russian Financial Society (RFS), for providing financial services to a company owned and controlled by the Foreign Trade Bank of the Democratic Peoples' Republic of Korea, North Korea's primary foreign exchange bank. FTB is the subject of American and United Nations sanctions.

Foreign Trade Bank links to DPRK entities


The precise legal names for RFS are :
(1) Limited Liability Company Non-Bank Credit Organization Russian Financial Society.
(2) LLC NCO Russian Financial Society.

Readers who wish to review the SDN listing can access the complete text here.
The Treasury press release details the linked North Korean entities. Treasury Designates Russian Financial Institution supporting North Korean Sanctions Evasion here.




ANTIGUA'S NEW CHINESE COLONY; BEACHHEAD IN AMERICA'S BACKYARD WILL INCLUDE AN OFFSHORE FINANCIAL CENTER


The Yida project, China's 2000 acre Special Economic Zone, presently under construction in Antigua, and labeled the "Chinese Colony" by Antiguans opposing it on environmental grounds, will be an autonomous entity cementing China's expanding footprint in the East Caribbean. The Peoples' Republic, which has been constricting huge embassies in the region, is seeking to displace the United States as the dominant local economic power. The project has been described by local opponents as "economic terrorism," and there are valid reason for the concerns. China often controls developing countries through loans that they are unable to repay.

There is another issue which is extremely disturbing; buried in the project description is a reference to the fact that the project will also contain an offshore wealth management center. This is an oblique reference to a tax haven; a Chinese-controlled offshore financial center, in a region known for poor anti-money laundering and counter-terrorist financing compliance, this facility could pose a direct threat to the foreign policies of the United States and Canada in the region, advance China's financial influence among the already non-democratic Strong Man-led republics of the East Caribbean, and destabilize Latin America.



Allowing China to construct a city-state in Antigua, and build a tax haven inside it, could alter the balance of power in the Caribbean, vastly reducing the already declining American influence there. We do not need another criminal tax haven in America's backyard.

Saturday, June 22, 2019

PANAMA'S CORRUPT SUPERINTENDENT OF BANKING WAS BAD ACTOR IN KPMG CENTRAL AMERICA SCANDAL



Alberto Diamond Rodriguez

 If you read our recent exposĂ© about misconduct of KPMG in Latin America, CPA says KPMG  Shortchanged its Latin American Partners and then Fixed the Courts, denying them Access, you probably wondered which KPMG executives ordered the amoral, and obviously illegal, denial of partner compensation. At the center of the misconduct is someone whom you may be familiar with, if you follow financial crime in the Republic of Panama.


The bad actor is the former Panamanian Superintendent of Banking, Alberto Diamond Rodriguez. Diamond , while acting as president of KPMG Central America SA, presided over the slashing of partner compensation, at KPMG offices in the region, to only three per cent (3%), less than one tenth of what their contracts provided.  When the partners filed suit, in El Salvador, Diamond ordered that bribes be paid to not only members of the local judiciary, to delay the cases for many years, but he personally saw to it that the settlements forced upon the partners amounted to only pennies on the dollar, as to what they should have received.

There were also issues regarding covert payments, to US-based partners, made from accounts in offshore tax havens, which were not disclosed to American regulatory or tax authorities.  

It is believed the reason that Alberto Diamond hastily left Panama, when Martinelli's presidential term expired, because he feared that criminal charges would be filed against him should he remain. Appointed largely because he was related to Martinelli through marriage, he was totally unqualified to serve as Superintendent of Banking, While in office, he not only failed to indict a single Panamanian bank on money laundering charges, be openly bragged that he facilitated deposits of approximately seventeen billion ($17b) US Dollars [known as Balboas in Panama], coming in, largely in the form of bulk cash, from Venezuela.

Diamond also extorted large sums from Panamanian bankers, whose banks he often threatened to indict for money laundering, due to some phantom regulatory violation he would charge them with, unless $50,000 was paid to him.

We shall be making further inquiries into Diamond's multiple criminal acts, while serving as president of KPMG Central America, and report back to our readers, as we further explore the scandal. 

 

Friday, June 21, 2019

ISMAEL ALI - WANTED FOR SKYJACKING AND MURDER OF EIGHT AMERICANS IN ST CROIX


MAJOR HEZBOLLAH MONEY LAUNDERER EXTRADITED FROM PARAGUAY TO MIAMI; LEBANON SEEKS TO INTERFERE WITH PROCEEDING

Nader Farhat, in custody in Paraguay, prior to his extradition

Nader Mohammad Farhat, a Lebanese national who is a senior Hezbollah financier, was extradited to Miami from Paraguay this week. He is reportedly linked to, or named in, four Federal criminal cases in New York and Miami. Farhat's Ciudad del Este money service business, Unique SA, is connected to a $1.3m money laundering scheme. He is allegedly a member of a Hezbollah division conducting  a massive international illicit finance and drug trafficking scheme.

The Hezbollah-controlled Government of Lebanon had sought to stop the extradition, in violation of the rules of international diplomatic protocol, through its local ChargĂ© d'Affairs in Asuncion, who ´urged that Paraguay's Attorney General should reject the extradition. Farhat was detained in 2018, on an American request, due to multiple arrest warrants in the United States.

Farhat, whose alias is reportedly "Diesel," faces charges of money laundering conspiracy, operation of an unlicensed money laundering transmitter, and wire fraud. He was involved in laundering drug proceeds, and cleaning the illicit profits of a counterfeit electronics sales operation. Lebanon has denied that it obstructed the extradition of Farhat to the United States.




Thursday, June 20, 2019

SYRIAN ARMS TRAFFICKING AND MONEY LAUNDERING THROUGH ANTIGUA WITH LOCAL SUPPORT


A number of Syrian nationals with Antigua CBI passports have been engaged in arms trafficking and money laundering, protected by the most three senior officials in the Government of Antigua. There are reports that three Syrians who are on the OFAC sanctions list hold Antigua CBI passports, but due to the fact that the identities of these individuals are restricted, we cannot name them at this time.

 The first Syrian to obtain an Antigua CBI passport, back in 2014, curiously maintains offices in Dubai, UAE. Since then, a number of Syrians have obtained Antigua CBI passports.  Reliable sources inside Antigua have confirmed that approximately $600m has been laundered from Syria, into and through Antigua, since Syrian nationals first acquired CBI passports there.



Syrian agents who facilitate Iran's program of evasion of international sanctions are known to be operating in the West Indies, especially in those countries who offer Citizenship by Investment (CBI/CIP) programs and/or are tax havens. If you have not read our recent article Iran Evading Sanctions by Using Syrians with Antigua CBI Passports Operating in the East Caribbean States, May 21, 2019, you may access the complete text  here.

Syrian terrorist financial with ANTIGUA CBI PASSPORT









CPA SAYS KPMG SHORTCHANGED ITS LATIN AMERICAN PARTNERS AND THEN FIXED THE COURTS, DENYING THEM ACCESS


  An accountant who was a partner at KPMG in Latin America, in violation of its contractual obligations, suffered arbitrarily reduced compensation, done across the board to all partners, to less than ten percent of what their contacts required to pay them. This was reportedly part of a scheme to deny partners their rightful compensation.

When the KPMG partners sought access to the court system, he alleges that KPMG paid bribes to court officials and judges, to delay the case for more than eight years, in order to coerce a small settlement. The unconscionable settlement prohibited the partners from taking any subsequent legal action, upon pain of losing the little amounts that they received.

This appears to be the tip of the iceberg, regarding widespread misconduct at KPMG. A fair review of the recent cases involving the accounting firm turns up arrests of KPMG officers arrested for fraud allegations, a huge $600m judgment in Hong Kong, audit fraud, data and exam fraud, and many more. Who will clean up KPMG, or should legal action be taken to dismantle it for racketeering ?





  

Wednesday, June 19, 2019

AMBROSE MONTFORT - FUGITIVE AIRCRAFT HIJACKER


SENATE INTRODUCES ILLICIT CASH ACT OF 2019

Four Members of the Senate have introduced what has been described as a complete overhaul of significant portions of US anti-money laundering laws. Entitled Improving Laundering Laws and Increasing Comprehensive Information Tracking of Criminal Activity in Shell Holdings Act, and also known as the ILLICIT CASH Act, the 102-page Discussion Draft of the legislation can be accessed here.

While this is very early on in the legislative procedure, we believe that our readers should have this Draft in hand, should  they be called upon to comment upon some of its provisions.

Sunday, June 16, 2019

JOANNE CHESIMARD, DOMESTIC TERRORIST EVADING JUSTICE IN CUBA


READ NEW OECD MONEY LAUNDERING AND TERRORIST FINANCING AWARENESS HANDBOOK


The Organization for Economic Cooperation and Development (OECD) has published a Money Laundering and Terrorist Financing Awareness Handbook for Tax Examiner and Tax Auditors.This 90-page white paper may be accessed here.

Saturday, June 15, 2019

LATVIAN BANK LINKED TO MONEY LAUNDERING AND PILATUS BANK OFFERED MALTA CBI PASSPORTS TO CLIENTS



Just when the dust was starting to settle over Malta's Pilatus Bank/Ali Sadr Hasheminejad scandal,  news about the link between Latvia's ABLV Bank and Pilatus, regarding joint money laundering activities, has again focused EU attention upon Malta. To make matters worse, ABLV was actively marketing Malta's CBI passports to its dodgy Azeri and Maltese PEP clients. Latvia is high-risk when its comes to Country Risk; did Malta and Pilatus miss that detail ?



Who was watching the store over in Malta, in its CBI as well as financial regulatory agency ? Or did just too much cash quietly change hands under the table ?



The fact that ABLV blatantly advertised Malta's CBI passport sales program on the bank's website, through its corporate services subsidiary, while engaged in money laundering operations for its clients, including designated State Sponsors of Terrorism, raises the possibility that terrorists, in addition to financial criminals, obtained Maltese CBI passports through ABLV. We are especially concerned about Iranian and North Korean agents inside the Schengen Zone, evading international sanctions.

For those who have opposed the EU's valid objections to ANY Member offering Citizenship by Investment (CBI) passports, we rest our case.



US FILES REPLY IN SUPPORT OF ITS MOTION TO DISMISS RICHARD CHICHAKLI'S FEDERAL TORTS CLAIMS ACT SUIT

 
Regarding the pending lawsuit, filed by Richard Chichakli against the United States, pursuant to the Federal Tort Claims Act, which has been extensively covered on this blog, the Government has filed a Reply to its Motion to Dismiss.

It is seeking to dismiss the Complaint for three reasons:

(1) The plaintiff has not met his burden to show that he exhausted administrative remedies under the FTCA.
(2) The plaintiff's attempt to confer jurisdiction on the Court for his Takings Claim is insufficient.
(3) The plaintiff has failed to allege as Waiver of Immunity for his Fourth Amendment claim.

The Motion to Dismiss raises questions of fact and issues of law, but Federal case law states that, for the purpose of examining whether such a motion has merit, all well-pleaded allegations of the complaint are considered to be true. When the Court rules on the motion, we shall update our readers.

IRAN'S FOREIGN TERRORIST FUNDING BUDGET


Wednesday, June 12, 2019

THE DUE DILIGENCE CHALLENGES PRESENTED BY MEDIA CENSORSHIP IN THE CARIBBEAN

Maurice Merchant, Antigua's unofficial media censor
 
If you are a compliance officer at a financial institution located in North America, or in the countries of the European Union, and you routinely conduct customer due diligence, or enhanced due diligence investigations, be aware that most Caribbean media is censored, directly or indirectly, and that it should not be relied upon as an objective source of customer or client information. Allow us to explain why you must  take this position.

1. The governments of the English-speaking republics of the five East Caribbean States that operate Citizenship by Investment (CBI) programs exert powerful influence upon local media, whether it be in electronic, print, Internet, unofficial or alternative form. Leaders in those countries fear any news that could be construed as negative might result in decreased foreign investment, tourism, or applications for CBI passports and citizenship.

 As the result of those concerns, they lean hard upon any journalist who publishes stories about corruption among government officials, court decisions that appear to be influenced by the wishes of the local Prime Minister,  or news about the crimes committed by foreign nationals with CBI or diplomatic passports that they purchased  at great expense. Civil suits, bogus criminal charges, or even threats and intimidation are employed to deter the publication of important news.

2. Threats of withholding valuable revenue, such as government advertising on media, or influencing large private advertisers to desist from placing ads in media that publish news the government does not want to see, in print media and online, also acts to censor news in the region.

3. Many articles published in East Caribbean online media are thinly disguised press releases, or articles drafted by government supporters, posing as real news. Some of those actually fail to remove the telltale "Press Release" title from the material. What you are reading, trying to ascertain facts about a prospective new bank client, is sponsored material that depicts the individual in glowing terms that do not reflect the truth.



If you were wondering why we posted the image of Maurice Merchant, who refers to himself as the "Director-General of Government Communications" in the office of Antigua's Prime Minister, Gaston Browne, he functions as the government's PR flack, as well as its unofficial censor-in-chief. A Bahamian national who is not a lawyer, Merchant fills online Letters to the Editor pages with pro-government material, attacking the credibility of all who dare to expose local corruption, using an alias (Tenman), appearing to be only a concerned private citizen, pontificating on legal issues, as a spin master, posting disinformation ad nauseum.

There are other individuals in the region that hold similar roles. Therefore, take all media sources from the region with a huge grain of salt, and possibly even deliberately misleading, when seeking facts. They are generally not trustworthy for due diligence purposes; look elsewhere for your information.

 

Tuesday, June 11, 2019

LI FANGWEI a/k/a KARL LEE- WMD AND BALLISTIC MISSLE SUPPLIER-$5m REWARD


INDIA'S FINANCE MINISTER SLAMS ANTIGUA'S CBI PROGRAM FOR HELPING OFFENDERS ESCAPE JUSTICE



The Government of India has come down hard on CBI jurisdictions, such as Antigua, who "allow economic offenders to use investment-type schemes to obtain residence or citizenship to escape from [the] legal consequences"of their crimes. Nirmala Sitharaman, the Minister of Finance of India, speaking at the G20 Finance Ministers and Central Bank Governors Conference in Japan, called upon nations to strongly deal with such practices," implying that punitive international action is warranted. India is extremely displeased with Antigua for not speedily extraditing Choksi, after it sold this known fraudster an Antiguan passport.

Antigua & Barbuda, which operates a Citiizenship by Investment (CBI/CIP) program that sold a passport & citizenship to India's most wanted white collar fugitive, Mehul Choksi, has refused to extradite him to face a criminal trial in India, relying upon dilatory procedural legal delays that have allowed criminals to cheat justice abroad. The case has resulted in Antigua sustaining serious reputational damage in North America and the European Union, due to increasing distrust of the country's court system. If a country's court system is rigged, foreign investors have no place to settle legitimate disputes, and as a result they steer clear of that country.

The Leroy King case, in which the former chief Antiguan financial regulator has evaded extradition to the US for more than a decade, is a prime example of the Antiguan judiciary's corrupt conduct, when it comes to intentional disregard of the Rule of Law, based upon the wishes of senior political leadership. If Chokli is not extradited, Antigua will most likely be elevated to High Risk status by bank compliance officer charged with the calculation of Country Risk, which may cause major economic damage.

Monday, June 10, 2019

JARED KUSHNER REAL ESTATE INVESTMENT FIRM MOVED FOREIGN CAPITAL THROUGH THE CAYMAN ISLANDS


CADRE, a real estate investment firm co-founded by Jared Kushner, (who still owns 25%), accepted $90m in foreign funding, placed through an opaque offshore vehicle in the Cayman Islands, and coming in from yet another tax haven, effectively concealing the identities of the investors. the largest investors are said to include citizens of Saudi Arabia. What's wrong with this picture ?

Kushner's stock in Cadre is said to be currently worth $50m;  Who are the principal foreign investors in the company ? This appears to be a textbook example of Conflict of Interest, suitable for a law school casebook. Unfortunately, it is true.





HAMAS TERRORIST SALIH AL-ARURI, WANTED UNDER REWARDS FOR JUSTICE PROGRAM $5m


HEARING OF DOMINICA OPPOSITION LEADERS WILL BE CLOSED TO THE PRESS AND PUBLIC


 
In yet another sign that basic Constitutional freedoms have been rescinded by the Skerrit government in the Commonwealth of Dominica, the upcoming hearing on the Incitement case against senior Opposition leaders is closed to the press and the public, by order of Magistrate Asquith Riviere. The defendants are former Prime Minister Edison James, Senator Dr. Thomson Fontaine, and Opposition leader Lennox Linton.

The case, which most legal observers agree was filed for purely political reasons, and is totally devoid of legal merit, is part of a grand scheme to discredit the Opposition, and possibly see them imprisoned, in advance of the next national elections. The Freedom to Assemble is one of the basic Constitutional freedoms; the Opposition leaders are targeted for inciting and provoking unlawful behavior at an organized, peaceful protest; The charge is, to be blunt,  bogus.

There is no security or other issue present that would justify closing the courtroom, and the magistrate's action has essentially closed the proceedings to public and media scrutiny, much as is the case in non-democratic states. especially in the Peoples' Republic of China, whose representatives have been advising Dominica's Prime Minister Skerrit since it built a huge embassy in the country.  
English Common Law, which forms the historical basis for Dominica's legal structure, requires that all trials be open to the public. It is clearly an abuse of discretion for the magistrate to close the proceedings.

Defense counsel has complained to the Court that Senior Counsel Israel Kahn, who is prosecuting the action on behalf of the Government of Dominica, has not only failed to deliver required discovery documents, but that this failure has interfered with the planned cross-examination of the 64 witnesses the Government has listed for trial.  The next hearing is scheduled for tomorrow, June 11, 2019.


Sunday, June 9, 2019

UK SEIZED THREE TONNES OF EXPLOSIVES FROM HEZBOLLAH NEAR LONDON


British media is abuzz with news of a terrorist incident, apparently now declassified, regarding the seizure of three metric tonnes of ammonium nitrate, an explosive component, in 2015, from Hezbollah agents operating from a secret bomb factory located near London. The material, which was packed in thousands of disposable ice packs, was destined for attacks which were planned against targets said to be in Thailand, New York, London & Cyprus. 8.2 tonnes were found in Cyprus, and an arrest made.

Reportedly, UK security services, acting on a trip supplied by a foreign government, raided four homes in northwest London. Hezbollah's "Military Wing " was sanctioned in the United Kingdom in March, 2019. previously only the so called- Political Wing was sanctioned in the UK.  Hezbollah is classified as a terrorist organization by the US, Israel and the Arab League.


There is speculation that information about the 2015 seizure, which is larger than the material used in the Oklahoma City bomb, was not released to the public, in an effort not to derail the Joint Comprehensive Plan of Action, the Iran nuclear agreement. Had this information been released timely, would public pressure in the UK have resulted in an earlier sanction against the Hezbollah Military Wing ? We cannot say, but denying the public the truth about terrorist threats that represent a clear and present danger is never prudent. Obviously, politics trumped public safety.

WHO WILL CLAIM $10m REWARD FOR DISRUPTING HEZBOLLAH FINANCIAL STRUCTURE ?


Saturday, June 8, 2019

CHOKSI'S MERITLESS APPEALS IN HIS ANTIGUA EXTRADITION CASE DELAY JUSTICE

Mehul Choksi
  As we approach the one year mark since India requested that Antigua & Barbuda extradite its most wanted super-fraudster, Mehul Choksi, his bogus legal tactics and dilatory actions continue, enabled by a local court system influenced by utterly corrupt government officials at the highest level.

Choksi's legal team has asked the Eastern Caribbean Supreme Court to allow him to petition it, to review a decision of the trial court denying Choksi's application to allow an "expert witness" to testify, regarding the validity of India's extradition request. If and when Choksi receives an adverse decision, his lawyers have already indicated that they will petition the Privy Council. Legal authorities have already indicated that there are no valid grounds for the Privy Council to accept jurisdiction; his action is without legal merit.

One member of Choksi's legal team is, coincidentally, one of the well-connected Antigua attorneys who have delayed the extradition of the former financial regulator, Leroy King, for more than ten years. King faces a potential life sentence in the United States, for assisting the mega-Ponzi schemer, Allen Stanford, steal billions from his victims.  The Choksi anti-extradition strategy appears to be a cookie-cutter copy of the King case, so do not expect a swift resolution.

The intentional delays in Choksi's extradition to India, while he is free to spend his criminal proceeds there, have seriously damaged Antigua's international image, especially in North America. Whether he will reside indefinitely in Antigua, and cheat justice, remains an open question that only the country's Prime Minister, Gaston Browne, can answer.

Friday, June 7, 2019

UN DENIES ACCESS TO LEBANON-BASED NGO THAT IS HEZBOLLAH FRONT ORGANIZATION



A majority of the members of the United Nations Economic & Social Council have voted against the admission of the Palestinian Association for Human Rights - Witness, which applied for special status, where the NGO  would be able to advise the UN and take part in its activities. Witness is classified as a terrorist organization in the State of Israel.

Witness, which is a front organization for Hamas, itself a designated global terrorist organization in several Western countries, claims to support Palestinian prisoners incarcerated in Israel for terrorist acts, and to assist Palestinians living in Lebanon.  Its leader, Mahmoud al-Hanafi, is known to have had meeting with the Hamas leadership, as well as those of Palestinian Islamic Jihad, which the United States asserts is actually a close ally of Hamas, but which maintains a separate identity to allow it to conduct terrorist actions against Israel as an alleged independent organization outside of Hamas control.

The fact that the Government of Lebanon allows such an obvious front organization for Hamas to freely operate there is not only disturbing, It is one more piece of evidence in support of the fact that Lebanon has become a State Sponsor of Terrorism, whether it be Hezbollah, Hamas, Palestinian Islamic Jihad, the Islamic Revolutionary Guard, or others. Consider that when assessing Country Risk for Lebanon.



 

WADOUD MUHAMMAD HAFIZ AL-TURKI, INDICTED TERRORIST BOMBER


DID ACCIDENTAL EXPOSURE OF PEP DATABASE TIP OFF HIDDEN PEPS ?



A "Hidden PEP" is a Politically Exposed Person who holds himself or herself abroad as a non-PEP, using a carefully constructed occupation or profession to deceive bankers into thinking that they have a low-risk, yet affluent, client. Typically, they open an account at an international bank, wait until a short period elapses, and then move the proceeds of corruption quickly through the account into a tax haven jurisdiction, or to a money launderer, abandoning the account, and moving on to another bank, to repeat the process. Later, the money laundering is exposed, but the PEP is long gone.

Another variation is to purchase a Citizenship by Investment  (CBI/CIP) passport from an East Caribbean State, under an alias, where money talks, and effective due diligence can be quietly "waived" by a greedy government official. Either way, the PEP succeeds in his quest to move dirty money through your bank.



Now, since some third party provider negligently left off password protection of a major PEP database, said to contain between two and four million names, some of those Hidden PEPs may know now tat they have been made. With the benefit of facial recognition software, those with aliases can still be properly identified. We wonder if, somewhere, certain PEPs have been advised, by their money laundering advisors, that they are at risk, and that they must cease their dark activities.


US SANCTIONS IRAN'S LARGEST PETROCHEMICAL HOLDING COMPANY



The US Treasury Office of Foreign Asset Control (OFAC) has sanctioned the Persian Gulf Petrochemcial Industries Company, also known as PGPIC. The stated reason was that PGPIC provides financial support to the engineering component of the Islamic Revolutionary Guard Corps. In addition to PGPIC, thrity-nine of its subsidiaries and agents have also been designated.

The names of the subsidiaries can be located here.

CANADA: ESTIMATE OF MONEY LAUNDERING BY PROVINCE

This graph is based upon estimates, by province. The actual amount, most of which consists of the proceeds of crime laundered through real estate purchases, may be higher. Please note that the sums are in Canadian Dollars ($CDN) in billions.


COMPLIANCE PROGRAMS ARE NOT AFFECTED BY MUNICIPAL RESTRICTIONS ON FACIAL RECOGNITION SOFTWARE USE BY LAW ENFORCEMENT



If you are a compliance officer at a bank that is employing facial recognition software systems in your Customer Identification Program to verify identity, non-PEP status and correct legal name of new or prospective clients, do not be overly concerned by news regarding municipalities, or even states, passing statutes banning its use. Those laws are specifically directed to law enforcement and other government agencies who are using CCTV footage in mass surveillance programs, where the targeted individualS neither know of, or consent to, its use.

The use, by private industry, of facial recognition software, where the individuals involved give informed consent to its intended use, is outside the scope of the new legislation. Therefore, if you are deploying a facial recognition software platform to search social media, social networking sites, the Internet and image databases, to identify a new or prospective bank client, consent should be obtained.

It is humbly suggested that your counsel prepare a consent form, to be signed by new clients at account opening, or upon application, in which the client acknowledges that, in order to properly identify them, additional measures will be employed, including but not limited to facial recognition software, social media & social networking, Internet searches, database searches,and other resources. Consider this only broad guidelines, as your counsel may be aware of additional or alternative language that is more appropriate or relevant.



Compliance officers, at financial institutions, who are not currently using facial software programs searching social media, Internet and image database resources, to properly identify their customers, should seriously consider obtaining such a program, as the failure to effectively verify customer identity is generally considered compliance malpractice by regulators.

Thursday, June 6, 2019

LEST WE FORGET: BOB LEVINSON STILL HELD IN IRAN SINCE 2007


WHEN USING FOREIGN NEWS ARTICLES FOR ENHANCED DUE DILIGENCE, USE PRESS FREEDOM CHART TO ASCERTAIN RELIABILITY OF INFORMATION

If you are a compliance officer conducting an enhanced due diligence inquiry on a new prospective foreign bank client, and you are accessing media from his or her country, one of the ways you can judge whether the material you find is reliable (or truthful) is the degree of pres freedom in that nation.

Here is the latest Press Freedom Chart; with it, you may ascertain the extent of press freedom that exists in the client's country. Given that many non-democratic nations either censor news about corruption among government officials, or PEPs, or self-censorship is practiced by press in other with similar totalitarian governments, you may use the chart to validate the level of accuracy of negative  information you obtain from that country.



Alternatively, where there is absolutely nothing available about your client, from a non-democratic jurisdiction, you may not draw the conclusion he or she is clean. You then must seek out information from other sources, in countries known for press freedom, and lack of government interference in media coverage.

Sometimes, even this chart and your other public sources are not helpful; in that case, you must entertain whether non-public sources must be enlisted to get to the truth about your new, affluent and promising, client.