Thursday, September 19, 2019
Jammal Trust Bank, a/k/a/ JTB Bank, recently sanctioned by the OFAC, and reputed to be Hezbollah's bank of choice, has advised the Central Bank of Lebanon that it will close, and be liquidated forthwith. The new sanctions, which deny the bank total access to the American financial structure, operates as a bank death penalty, for it can no longer properly service its international clients.
The Central Bank reportedly has given its approval to the liquidation; it has publicly said that the bank's assets, and existing deposit guarantees, will be sufficient to repay all deposits. We have previously reported on the bank's off-the-book loans to Hezbollah, secured by gold.
Compliance officers please note that the bank has 25 offices and branches, located in Lebanon, Nigeria, the Ivory Coast and the UK. The African jurisdictions are all known for Hezbollah money laundering activity, as well as transit centers for its narcotics trafficking operation into Europe from Latin America.
Wednesday, September 18, 2019
If you are a compliance officer at an international bank whose clients trade with companies located in Spain, be advised that the Banco de España (Bank of Spain), the country's central bank, is promoting massive evasion of US sanctions by allowing firms trading with Venezuela to funnel their payments through its facilities. This means that, as UAE companies do for Iran with sanctions evasion support, the Government of Spain is doing for Venezuela, freely using its banking structure to allow Venezuela to conduct international trade around existing sanctions.
The Bank of Spain, where it has responded to the charges of sanctions evasion at all, has denied the allegations. Compliance officers in the United States should now secure from their banks' clients engaged in trade with companies located in Spain, sworn End User affidavits, attesting to the fact that Spain is the final destination for their clients' goods and services, and for payments as well. To do otherwise will expose your US bank to potential OFAC Civil Fines and Penalties down the road.
|BANK OF SPAIN|
Under the circumstances, you will probably also want to raise Country Risk for Spain, and conduct Enhanced Due Diligence upon the Spanish companies who your clients are trading with ? Are any of them owned or operated by Venezuelan nationals ?
Two Moroccan nationals, wanted in France on money laundering charges, were arrested when they arrived in Gibraltar from Tangier this week. Zakariaa El-Abdallaoui, and his wife, Chaimae El-Fahassi, were taken into custody, on the basis of a European Arrest Warrant.
The alleged launderers were arrested due to charges filed in Bordeaux, consisting of multiple money laundering and conspiracy counts. The wife is reportedly a resident of Gibraltar.
Tuesday, September 17, 2019
The fugitive Alex Nain Saab Morán, who is wanted by the United States and the Republic of Columbia, got some more bad news this week. OFAC sanctioned his brothers Amir Saab, and Luis Saab, and partner Alvaro Pulido's son David Rubio Gonzalez.
Additionally, all the companies these newly sanctioned family members operate were also sanctioned; located in Colombia, Panama and Italy, the companies can be found here.
Monday, September 16, 2019
BRITISH COLUMBIA SUPREME COURT ENTERS MAJOR JUDGMENT ADVERSE TO LAW ENFORCEMENT EFFORTS, RELEASES CAD$2m
The Supreme Court of British Columbia, dealing a major setback to BC law enforcement efforts against drug trafficking and money laundering, reversed an ex parte Interim Preservation Order (IPO) that resulted in a seizure of over CAD$2m, and other assets. The Judgment released the currency, upon the request of the claimants, who allegedly operated Silver International, an underground bank. Legal observers have commented that the adverse decision represents a loss to efforts to reign in rampant BC money laundering.
The court cited a number of issues that it relied upon in its decision, which might serve as a guide for what law enforcement would best NOT do:
(1) The duty to make full disclosure in the ex parte application for the IPO was not observed.
(2) A fair and complete legal basis for the seizure on an urgent basis was not provided to the Court.
(3) The law was misstated at one point in the application, in favor of the applicant.
(4) The attorney for the Civil Forfeiture Office made no efforts to brief the probable opposing position, and did not cite any opposing views.
Readers who wish to review the 36-page judgment can access the complete text here.
Monfared, as seen from these pictures, is appearing in open court in Tehran. Note the presence of news photographers. We wonder how this news is being treated in Dominica, where Monfared's high-profile business fraud, and his Dominica diplomatic passport, exploded when he was detained in the Dominican Republic, by Iranian agents, and transported to Iran, Via Havana and Moscow. Monfared's very public relationship with Dominica PM Roosevelt Skerrit remains a major embarrassment in Dominica.
The defendant most likely faces either life in prison or, like Zanjani, the death penalty, unless he surrenders the missing billions. Zarrab, who is cooperating with law enforcement or intelligence authorities in New York, may have already withdrawn some or all of the funds, in a settlement with the United States.
Sunday, September 15, 2019
The government prosecutors in Panama have appealed the not guilty judgment, entered by a three-judge panel, in favor of former Panamanian President Ricardo Martinelli, seeking to annul the ruling of the Court of Justice. The appeal, brought by Organized Crime prosecutors to the Superior Court of Appeals, is an attempt to overturn the findings of fact, including that the government failed to prove that the electronic surveillance was not authorized by a judicial body. If convicted, Martinelli faced a maximum of twenty-one years' imprisonment.
Objective legal observers of the Panama judicial scene have concluded that the government proved its case, regarding illegal surveillance, and have concluded that the not guilty judgment constitutes reversible error, but have also admitted that the Panamanian courts are deeply flawed, and often fail to follow the Rule of Law, and that corruption may have been a major factor in the decision.
Rumors that multi-million dollar bribes being paid to members of the judiciary, to find Martinelli not guilty have swirled around Panama City since the ruling, even to the point of specific bribe figures being quoted. The decision has merely confirmed that litigants cannot have any faith in the integrity of the Panamanian judicial system, where bribes and kickbacks often dictate the outcome of court cases.
Corruption in the local courts is systemic and rampant. Foreign investors would be well advised to steer clear of the Republic of Panama, and in recent years, most have prudently sought to place their funds elsewhere, especially after a number of major financial scandals broke in the local press.
The American Rewards for Justice program, which pays cash rewards, as well as absolute confidentiality, and possible relocation to the United States, has recently been broadened to include information "leading to the disruption of the financial mechanisms of Iran's Islamic Revolutionary Guard Corps, and all of its branches, including the IRGC Quds Force."
Further information is available at www.rewardsforjustice.net
Saturday, September 14, 2019
CALIFORNIA ASSEMBLY SIGNS OFF ON THREE YEAR MORATORIUM ON POLICE USE OF FACIAL RECOGNITION TECHNOLOGY ON POLICE BODYCAMS
The California State Assembly this week followed the State Senate, and passed the Body Camera Accountability Act. The bill now goes to Governor Newsom for his signature. The law, if passed, becomes effective in January.
Note that the law not only prohibits the use of facial recognition software in police body cameras, it also bars downloading the body cam footage for FRS analysis; Federal law enforcement use is exempt. The moratorium expires in three years.
Readers who are not familiar with this story are advised to read our previous coverage:
Bill Imposing a Moratorium upon the use of Facial Recognition Technology in Police Bodycams passes the California Senate, September 12, 2019.
The United States, through an official statement from the President, as finally gone on record and admitted that Hamza Bin Laden, the son and heir apparent of Osama, has been killed in a military operation in Afghanistan or Pakistan. There have been no statements attributed to Al-Qaeda announcing his death, and there was a question as to whether he was indeed deceased.
The White House statement, which was published today, and which can be downloaded here. reads:
STATEMENT FROM THE PRESIDENT
"Hamza Bin Ladin, the high-ranking Al-Qa'ida member and son of Usama Bin Ladin, was killed in a United States counter-terrorism operation in the Afghanistan/Pakistan region. The loss of Hamza Bin Laden not only deprives Al-Qai'da of important leadership skills and the symbiotic connection to his father, but undermines important operational activities of the group. Hamza Bin Ladin was responsible for planning and dealing with various terrorist groups."
NEW YORK COURT CASE EXPOSES HOW ILLEGAL CARIBBEAN CBI PAYMENTS FROM A NON-EXISTENT BANK WERE FACILITATED BY SWITZERLAND
We are all familiar with "brass-plate" banks, those that have no brick-and-mortar physical location, and also virtual banks, which only exist online but are duly licensed, but what about so-called phantom banks, those that do not even have a charter, but are moving money in illicit international commerce ? Enter the " Bank of Dominica," which does not exist, in any legal form, in Dominica, in Switzerland, where it is transferring illicit capital, or anywhere in the world. How is it that Switzerland allows it to move millions of dollars ?
The bank's name came up recently, when an Italian American businessman, Paolo Zampoli, who holds a diplomatic passport from the Commonwealth of Dominica, one of the five East Caribbean states that sell Citizenship by Investment (CBI/CIP) programs, sued* Range Developments, a builder of CBI resorts, alleging that he was improperly denied a multi-million dollar finder's fee, due to him from the Cabrits Resort & Spa Kempinski Dominica. The Cabrits project was curiously built on national park land removed from park status. Did Zampoli facilitate that act we wonder ?
Zampoli alleges that Range completed, and opened, the project, without tendering payment to him of his fees, as required by a written agreement He states, in a sworn verified petition, that two Range officers, Mohammed Asaria, a Palestinian, and Kamal Shehada, a British national, received thirty million dollars each, from "a Bank of Dominica account in Geneva, Switzerland ."
No such bank exists anywhere, and given the strict manner in which the Swiss Government severely restricts the use of the term "bank" to licensed financial institutions, how is it that such an unregistered and unlicensed entity was permitted to exist in Geneva, and to receive, and fund, illegal payments from Dominica's CBI program ? We note that Chinese purchasers of Cabrits are alleging that Range committed fraud, but this has not yet been confirmed.
The law in Dominica requires that CBI escrow deposits must be held by local banks, and all disbursements must have three signatures, none of which can be that of the prime minister. Both Swiss regulatory agencies, and whatever Swiss banks transferred the sixty million dollars to the UAE officers of Range, should be investigated, to ascertain how a totally bogus "bank" was permitted to have accounts in local banks, as well as wire large amounts out of Switzerland. was FINMA asleep ? Which Swiss bank opened the accounts for a bogus bank ?
If you were wondering why the two $30m payments were illegal, Range Development sold 800 passports to investors, who paid Dominica $195m for real estate purchases, which is strange, because there were only 160 rooms sold, and even if the cost of constructing the hotel was double what is customary on the industry, say $44m, what happened to the other $150m ? Was it diverted into the Swiss bank accounts of corrupt senior Dominica officials ?
Dominica is presently in the middle of a crisis, after it was discovered that an estimated $1.2bn in CBI receipts is missing from the national treasury. The $60m represents an illegal diversion of Dominica treasury funds, and the transfers constitute money laundering.
Getting back to the ficticious "Bank of Dominica," we call upon FINMA, the Swiss financial markets regulatory authority, to open an investigation into the matter, and into the presence of illegal CBI funds, being CBI proceeds diverted into the hands of criminal conspirators engaged in CBI real estate construction projects. Perhaps they might want to speak to the Swiss bankers involved in this scandal, and close down all CBI accounts from the East Caribbean CBI states.
the relevant allegations from Zampoli's Petition appear below; you attention is directed to paragraph 14:
* Paolo Zampoli vs. Range Developments et al, Index No. 156698/2019 (NY Sup Ct).
Friday, September 13, 2019
Money launderers have been placing and sanitizing criminal proceeds for decades, by purchasing fine art and antiques for cash, quietly transporting these types of assets. from countries where the money is acquired, into countries where the cleaned cash can be openly invested, or to repatriate that wealth for their cartel clients.
After all, putting an Old Master worth many millions into a second-hand frame, assuring its obscurity by dumping it into a box of cheap art prints, to be thereafter shipped in international commerce, unrecognized by Customs officers, and sold to a local art dealer. Whether the laundryman's goal is to simply move wealth across international borders, or to clean the proceeds of crime, art and antiquities, an industry thus far excluded from the compliance requirements of the Bank Secrecy Act (BSA), is a favorite avenue of international money launderers working for cartels and transnational criminal organizations.
The United States is attempting to bring the arts and antiquities industry into the orbit of the BSA. House of Representatives Bill 5886, captioned the Illicit Art and Antiquities Trafficking Prevention Act, which amends the Bank Secrecy Act to require art and antiquities dealers to comply with the BSA provisions regarding creation of compliance program and manual, reporting, record keeping, training, and auditing.
Readers who wish to review the House Bill will find the complete text below.
EXECUTIVE ORDER IMPOSES SANCTIONS ON CORRESPONDENT ACCOUNTS OF FOREIGN FINANCIAL INSTITUTIONS THAT FACILITATE TERRORISM
The President of the United States has issued an Executive Order entitled Modernizing Sanctions to Combat Terrorism. Treasury is now authorized to target terrorists and terrorist facilitators, by imposing correspondent account or payable-through account sanctions on any foreign financial institution that knowingly conducts or facilitates any significant transaction for on on behalf of any Specially Designated Global Terrorist (SDGT).
Readers who need the original source material will find the complete text below.
US HAS EVIDENCE THAT OIL IN IRAN'S GRACE 1 WAS SOLD TO SYRIA, NOTWITHSTANDING IRAN'S SWORN STATEMENT TO THE CONTRARY
|The Adrian Darya 1 just off the coast of Syria, near Tartus|
The United States has clear and convincing evidence that the government of Iran sold the crude oil in the former Grace 1, now Adrian Darya 1, to the regime in Syria, after Iran made sworn, written assurance to the UK that the destination was not Syria.The oil is reportedly the property of the IRGC, and its intended use is terrorist financing, according to published reports. Iran's credibility on the international stage has taken a major hit due to this incident, and compliance officers are not to trust ANY information that originates from official channels in Iran, as it is most likely misinformation, or completely false.
The United Kingdom, which is also now aware of the sale of the crude to Syria, and whose Gibraltar officials were deceived by Iran's statement, has made its displeasure known to Iranian diplomats. You can bet that the next Iranian or IRGC-controlled crude oil tanker that enters the Mediterranean, bound for Syria, will be detained, this time by a very angry United States Navy.
Thursday, September 12, 2019
BILL IMPOSING A MORATORIUM UPON THE USE OF FACIAL RECOGNITION TECHNOLOGY IN POLICE BODYCAMS PASSES CALIFORNIA STATE SENATE
Some of California's municipalities have imposed bans upon the use of facial recognition technology, due to either human rights and privacy issues, or concerns regarding the accuracy of the software. After a test of Amazon's facial recognition software technology misidentified members of the California Legislature, the California State Senate passed a three-year moratorium on the use, by law enforcement, of facial recognition technology in body cameras.
Some experts advising government believe that the software programs currently in use are not accurate enough for law enforcement use, and have agreed that the three year moratorium will allow the industry to improve its programs.
The bill must now pass the California Assembly to become law. The law, as currently written, expires on January 1, 2023. readers who require the complete text of §832.19 may access it here.
Readers who were waiting for the Committee of Experts on the Evaluation of Anti-Money Laundering measures and the Financing of Terrorism, more commonly known as MONEYVAL, to finally publish its Fifth Round evaluation Report on Malta, it is now available. As expected, due to leaked portions of the Report previously appearing in the financial press, it is extremely critical of Malta's AML/CFT programs.Y and those deficiencies have been reported on this Blog. You may access the 233-page Report here.
Wednesday, September 11, 2019
PLAINTIFF TO APPEAL HIGH COURT OF JUSTICE DECISION APPROVING POLICE USE OF FACIAL RECOGNITION SOFTWARE PLATFORM
|Automated Facial Recognition|
The appeal will be filed by the civil rights group Liberty, which represents Bridges. the South Wales Police were reportedly the first law enforcement agency in Britain to employ facial recognition technology; it has used the platform to search for wanted individuals in public events, like football matches and rock concerts. Data on all other individuals not identified is discarded.
Readers who did not review the complete text of the High Court, Queen's bench, decision, should read our article on the case, High Court of Justice approves Law Enforcement Use of Facial Recognition Technology, which contains a hyperlink to the case. You may access it here.
Tuesday, September 10, 2019
US COURT SENTENCES TURKISH BUSINESSMAN TO 27 MONTHS FOR SHIPPING EQUIPMENT FOR MISSILE BOATS TO IRAN
The US District Court in Milwaukee, Wisconsin has given a 27 month sentence to Resit Tavan, for violating US sanctions on Iran, and the IEEPA, by illegally exporting specialized marine equipment, which was to be used on high-speed Iranian missile attack boats. Tavan funneled the equipment, consisting of marine engines, generators and surface drives, through Turkey, working in concert with Iranian officials.
Tavan had no OFAC or Department of Commerce licenses to transfer this equipment to Iran. His company was the Ramor Group (Ramor Dis Ticaret Ltd.), and the true end user was the Iran-based Qeshm Madkandalou Shipbuilding Cooperative. An OFAC Specially Designated National (SDN), he was extradited from Romania in2017.
A co-defendant, also a Turkish national, remains a fugitive. He is FULYA KALAFATOGLU OGUZTURK.
Sources inside Lebanon have confirmed that Jammal Trust Bank S.A.L. (JTB Bank), which was recently designated by the United States for its close association with Hezbollah, will be sold off, or liquidated. The primary reasons are that the bank no longer has access to the American financial structure, as its US correspondent banking relationships have been abruptly terminated, and it can no longer deal in US Dollars.
Reportedly, the bank has been known to American regulators as a financial conduit for Hezbollah since the early 2000s. This raises serious questions regarding how any US financial institutions were providing correspondent banking services to JTB. The US banks have not yet been publicly identified.
It is one of the very few Shi'ite-owned banks in Lebanon, and services the Shi'ite Muslim community there, especially in the rural south of the country, which is Hezbollah-controlled. One rumor appearing in local media claimed that the bank took gold as collateral for loans from Hezbollah, and failed to register the transactions, so as to evade any record of its providing financial service to the designated global terrorist organization.
Monday, September 9, 2019
Jeffrey Webb, the former Vice President of FIFA, and the ex-president of CONCACAF, and who led guilty back in 2015 to money laundering conspiracy, racketeering and wire fraud, is scheduled to be sentenced tomorrow, September 10. Webb's sentencing was rescheduled no less than nine times, while he was under house arrest in his Georgia mansion, raising questions about whether he was granted special privileges while testifying against his co-defendants in the massive FIFA corruption scandal.
Some in the media have accused the defendant of continuing to enjoy a "champagne lifestyle," while under Home Confinement. Webb, who allegedly received $7m in bribes and kickbacks, invested his criminal proceeds in several homes in Georgia, the purchase price of which were far in excess of his published salary and benefits. He is also wanted for white collar crime in his native Cayman Islands.
Posted by Kenneth Rijock at Monday, September 09, 2019