Kenneth Rijock

Kenneth Rijock

Friday, February 22, 2019

YET ANOTHER CONSENT ORDER AGAINST MITSUBISHI UFG BANK LTD FROM OCC



It would appear that M(itsubishi)UFG Bank Ltd*. cannot remedy the BSA/AML deficiencies in its compliance program, for again the Office of Comptroller of the Currency has imposed a Cease and Desist, captioned now as a Consent Order. We have seen prior C & D orders issued by US regulators, and the bank does not seem to be fixing its systemic defects.

Some of the many shortcomings detailed in the Consent Order:
(1) Failure to timely file SARs, Suspicious Activity Reports.
(2) Failure to implement effective compliance on correspondent accounts of foreign financial institutions.
(3) Failure to maintain and effective compliance program that covers BSA/AML.
(4) Systemic deficiencies in transaction monitoring systems.
(5) Gaps in trade finance monitoring.
(6)  Insufficient internal Audit functions.



Readers who wish to review the complete text of the 25-page Consent Order may access it here.

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* The bank changed its name to MUFG Bank Ltd., which may be considered misleading, as the prior regulatory actions were against the bank under its original name. American businesses might not know that the bank, now without any indication that it is a foreign bank, has a history of regulatory black eyes.


WHY CAN'T THE U.S. GET THIS DRUG KINGPIN FROM THE UAE ?

If this designated Kingpin, who is residing in the United Arab Emirates, and in India, truly presents a clear and present danger to the US as indicated by OFAC, why can't he be extradited to face the music in an American courtroom ? He has already been indicted in a Federal Court in Tennessee; what's the reason he is not in custody ?


IRANIANS CONCEALING THEIR NATIONALITY BEHIND EAST CARIBBEAN CBI PASSPORTS


 It seems that everyone affiliated with the shell companies surrounding Malta's dodgy and now-closed Pilatus Bank is Iranian, but prefers to be known only by whatever CBI passport of convenience they have. Take a close look at all the players, their jurisdictions of choice, what positions or titles they hold in the dark Pilatus empire, and how they fit in to the money laundering enterprise.

credit: France 24

FRENCH COURT FINES UBS $5.1bn FOR MONEY LAUNDERING VIOLATIONS


A Court in Paris levied a $5.1bn fine on UBS AG, and UBS SA (FRANCE), for money laundering, Illicit Solicitation, and Laundering the Proceeds of tax Fraud. The fine was specifically for €3.7bn, plus 15m EUR, and eight hundred million Euros in civil damages. This fine exceeded UBS' reported net profit for 2018, which was the equivalent of $4.9bn.

The bank has stated that it denies committing any criminal misconduct, and asserted that there is no evidence to support this ruling. It also alleged that "there was no offense committed in France," raising the defense of Swiss sovereignty. It stated that it will appeal the ruling.

The Court convicted the bank of soliciting high net-worth clients to assist them in tax evasion. It stated that UBC conducted the same covert tactics to solicit clients that it has done previously in the United States; sending its officers to sporting events and gatherings where large numbers of high net-worth individuals typically gather, and concealing their bank affiliation in a stealthy manner. The officers were operating under instructions to be covert; they were not authorized to solicit business in France.



Readers who wish to read the bank's response may access the English language press release here.

Thursday, February 21, 2019

SATABANK REPLACES PILATUS BANK AS MALTA'S BAD BOY DU JOUR


 Satabank, owned by Bulgarian interests, was placed under administration last year by Malta's regulatory agency, when the bank's 12,000 accounts were frozen as part of a clampdown due to money laundering concerns. The country's Financial Intelligence Analysis Unit found suspected ties to organized crime among the depositors, including several online gaming companies.

A large number of local businesses in Malta, who were Satabank customers, all suffered serious losses when their operating capital, which consisted of deposits at the bank, was frozen in October; some have been forced to close their doors. Whether clients of the bank were laundering money remains an open question, as well as why it took Maltese regulators years to act on suspicions.

Satabank's weekly press releases for bank clients appear to be vague and imprecise, and do not finitely explain either the examination process, nor exactly when refunds will be made to depositors, especially corporate clients. Coming on the heels of the Pilatus Bank scandal, it has left not only Maltese nationals but the financial world at large questioning the ability of Malta's regulators to adequately supervise their country's financial institutions, and have caused Country Risk to be elevated by many foreign banks, concerned about Malta's banking structure.

IS RUSSIA'S SEARCHFACE THE "WAYBACK MACHINE" FOR ENHANCED DUE DILIGENCE SEARCHES ?




Compliance officers all love the Wayback Machine (https://archive.org), for it allows us to view deleted, expired, removed and otherwise unavailable, webpages, during due diligence inquiries. It appears that an enterprising Russian group has done the same with social media head shots of Russians and certain Eastern Europeans. The website, SearchFace.ru,  allows users to drop in photo of a target, and the installed facial recognition software program searches Vkontakte (VK) profiles.


You drop your photo in there, and SearchFace goes to work

The beauty of the site is that it is not only searching currently available VK profiles, it is also looking through deleted, suspended, and even locked & private profiles. Inasmuch as searching Russian social media sites during due diligence investigations is often difficult to impossible, use this tool. There are many group short in the profiles, which allows you to identify individuals showing up in unexpected places.



Given the demonstrated usefulness of searching social media sites, using facial recognition software platforms, in due diligence and enhanced due diligence investigations, perhaps this Russian site can fill in a gap in your resources.


BRITISH PR CONSULTANT LINKED TO PAUL MANAFORT CHARGED WITH $3m MONEY LAUNDERING IN 1MDB SCANDAL



PAUL STADLEN, who handled public relations for former Malaysian Prime Minister Najib Razak, who was charged in the $4.5bn 1MDB embezzlement scandal, has now himself been charged with two counts of money laundering. The figure of three million dollars, representing the proceeds of crime, was allegedly the extent of his involvement.

Of special interest to American readers is Stadlen's period during which he worked fior FBC Media, which is a Paul Manafort connection. Manafort is the convicted former Trump Campaign Chairman who figures prominently in in the 2016 Presidential Election Campaign regarding alleged Russian efforts to fix the election in favor of Donald Trump.


Wednesday, February 20, 2019

REVISED GUERNSEY REGULATIONS TAKE EFFECT MARCH 31, 2019



If you live or work in Guernsey, or have clients that use the services of the offshore financial center of the Bailiwick, please note that the effective date of the Revised Handbook on Countering Financial Crime and Terrorist Financing, issued by the Guernsey Financial Services Commission, is March 31, 2019. You can access the complete text of the 31-page document here. 

FRAUDSTER WITH $22M INVESTMENT SCHEME TO BUILD AIRPORT IN BELIZE PLEADS GUILTY

Mr. & Mrs. Brent Borland
 
The owner and principal of a New York-based investment fund that promised a high rate of return from the construction of an international airport in Plasencia, Belize has entered a guilty plea in New York District Court, Brent Borland's Belize Infrastructure Fund I LLC failed, and 40 investors of record lost $22m. The investments, which were promissory notes, were supposedly secured by unencumbered real property located in Belize, was either pledged, or non-existent.

If the investors had simply conducted an effective due diligence investigation, they would have learned that the fraudsters used the same real estate over and over again, to "secure" the promissory notes, when the equity in that realty was insufficient to collateralize all the debt. Investors who do not have the foresight to check things out in advance through an attorney, and who are dazzled by the promise of double-digit returns, often end up with nothing.

The money was supposed to be a "bridge loan," pending permanent financing for the 10,000 ft. airport runways, associated structures, and medical center. There has been no construction, and the defendant used much of the money to fund a luxurious lifestyle, including his wife's $2m credit card debt. 



Borland, otherwise known as a principal in the Borland Capital Group, pled guilty to:
(1) one count of conspiracy to Commit Securities Fraud and Wire Fraud.
(2) One count of Securities Fraud.
(3) One County of Wire Fraud.

Tuesday, February 19, 2019

TRUMP ADMINISTRATION STILL SITTING ON 2015 PROPOSED AML REGULATIONS ON HEDGE FUNDS



Since the Presidential Election of 2016, there has been zero progress in advancing the 2015 FinCEN Proposed Regulation regarding AML programs for Registered Investment Advisers, (which includes hedge funds). When regulations upon hedge funds were postponed after the USA PATRIOT Act of 2001, hedge funds became a prime target of opportunity for money launderers who work for the world's largest criminal syndicates.

 The 2015 proposed regulation, which can be accessed here. is the last best hope to rein in hedge funds. Unless Unless FinCEN and Treasury wake up, and take this issue seriously, money launderers will still have access to place, and secrete, their clients' criminal profits within offshore hedge funds.

IRAN'S ANTI-MONEY LAUNDERING LAW ALLOWS BANKERS TO ALTER IDENTITIES


Iran's new anti-money laundering bill, as passed, reportedly has a number of shortcomings, but none so serious as the deletion of the provision that imposes an absolute ban on changing the identity on individuals and entities that conduct financial transactions. This means that anyone, or any entity, that is subject to sanctions may have their identities altered, so as to deceive the recipients, and all the banks handling the transactions.

What this is is a loophole that aids and abets money laundering and terrorist financing. Iranian bankers can now conceal the identity of account holders, meaning that they can knowingly change the name of a sanctioned client, and not violate the AML laws.

If you needed a reason to block ALL transactions that originated in Iran, irrespective of how clean the sender was, here are the necessary legal grounds to support that action.

IRAN TO EXECUTE ZANJANI AFTER HE REPAYS STOLEN BILLIONS

Zanjani in court
  Iran's deputy judiciary head publicly stated that billionaire oil sales proceeds thief Babak Zanjani will still be executed, and that he will be hanged after he returns the more than $3bn he stole from the Oil-for-Gold Iran sanctions evasion program. Zanjani was sentenced to death in 2016, for "Crimes on Earth, " after he and his partners diverted billions of dollars they received while operating a massive  global oil sanctions evasion sales scheme.

This is a departure from earlier government statements, in which Iran's judicial authorities promised to reduce his sentence, and not execute him, provided he return the billions stolen. It has been acknowledged that the missing money is outside Iran, and cannot be recovered. Zanjani's partners, which included Reza  Zarrab, now cooperating with the US Goverment, are believed to have control of the funds; it is not known whether Zarrab has turned over all or part of the money to the US. He is presently living in New York, released from custody in an unusual arrangement which would support the theory that he has rendered Substantial Assistance to the US Department of Justice.


Zarrab


The other known co-conspirator, Alireza Monfared, who is believed to be in Iranian custody, after he was detained in the Dominican Republic, and spirited to Iran, via a circuitous route that avoided US airspace, and the possibility he would fall on American hands, laundered the illicit oil profits through the Malaysian offshore financial center of Labuan, and some of the missing money may be located there. Monfared's abuse of a diplomatic passport, issued by the Commonwealth of Dominica, widely exposed the sordid business of selling "diplomatic" status in the East Caribbean States. 

Monfared with Dominica PM Roosevelt Skerrit
It has been anticipated that Zanjani's partners in crime would eventually save his life by paying Iran the $3.5bn it says he owes, which includes interest, but now, with this news that it will not stop his execution, it is doubtful that this will ever occur.

Monday, February 18, 2019

ACCUSED HEZBOLLAH MONEY LAUNDERER QUIETLY CUTS A $50m DEAL FOR SHORT SENTENCE


Kassim Tajideen
 If you read our recent article about the Lebanese businessman, Kassim Tajideen*, named as a Specially Designated National (SDN), he has entered a plea of guilty to Conspiracy to Launder Monetary Instruments. Tajideen is reportedly an "important financial contributor to Hezbollah", although his attorneys have contested that designation, and he was ultimately not charged with providing financial support to Hezbollah. After his attorneys objected, the Government reportedly removed all references to Hezbollah from a Superseding Indictment.

Obviously, the Government did not want to reveal material from ongoing investigations, or to expose itself to another Waked-type civil suit, testing the legal sufficiency of Tajideen's SDN sanction. Tajideen operated Hezbollah front companies all over Africa.

As you know, money laundering carries with it a maximum penalty of 20 years in Federal Prison, as well as a possible hefty fine. Tajideen has entered into a Plea Agreement admitting that he wired funds into the United States, as part of commercial transactions.

(1) He serves 60 months, with credit for time served to date. His Guidelines were closer to 10 years, but the Court could have applied enhancements, if his true status as a principal laundryman for Hezbollah came out at trial.
(2) He pays Fifty Million Dollars, in advance of sentencing.
(3) The Government agrees not to mention at sentencing that the defendant was a supporter of, or associated with Hezbollah.
(4)  The Government will not oppose any action by counsel for Tajideen, who also has Belgian citizenship, to transfer where he will serve his time to Belgium**, provided that he serves the full 5 year sentence, as computed by the Bureau of Prisons, with the appropriate credit for pretrial confinement.

His sentencing  was recently postponed, after the defendant's counsel advised that his client had not yet raised all the funds; a new date has been set. 
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*Aliases of the defendant: KASIM TAJI AL-DIN, KASIM TAYMUDIN, KASSIN MOHAMMAD TAJDDINE,QASIM TAJ AL-DIN, BIG BOSS, BIG HAJ, HAJ KASSIN.
** The defendant is also shown as a citizen of Sierra Leone.

FACIAL RECOGNITION SOFTWARE COMBATS ONLINE WILDLIFE TRAFFICKING




When smugglers and wildlife traffickers turn to social media and e-commerce to illegally sell live exotic animals, facial recognition software (FRS) programs can provide an effective solution. Trafficking in Great Apes and Chimpanzees are two examples of extremely lucrative illicit enterprises that facial recognition software platforms, when paired with existing extensive publicly-available documentary footage and image datasets, can identify trafficked animals in a very short time, especially when compared to manual searching. The manual approach is generally found to be unsuccessful due to its labor-intensive nature, and in being prone to user error, due to facial similarities.


One program under development, called ChimpFace, actually applies facial mapping technology, through an algorithm, to recognize individual chimp faces. Both conservation groups as well as law enforcement agencies can utilize FRS to positively identify trafficked animals offered for sale online, block the sales, arrest the traffickers, and return the stolen animals to their original habitat.

Facial recognition software platforms can be adapted to identify any type of wild animal subject to illegal trafficking and smuggling activities, provided that there is sufficient existing footage and datasets of the species.


CHINESE INTELLIGENCE AGENT WHO SPIED ON KEY WEST SENTENCED TO ONE YEAR


A Chinese "exchange student" who was an intelligence agent, was sentenced to one year of incarceration, and one year of Supervised Release. after he was apprehended taking photographs of an antenna array, outside the restricted JIATF-South* facility, within the Key West Navy Base. Zhao Qianli, who claimed to be a tourist visiting Florida, but who only had photographs of military installations on his camera and mobile phone, had waded into the surf to evade a security fence, and entered what was clearly marked as a restricted area, in Truman Annex, of NAS Key West.

He carried no identification, and claimed that he strayed onto the base by accident. His visa had expired. Zhao claimed to be only 20 years old, but he appeared much older. He admitted that he is the son of a high-ranking officer in the Peoples' Liberation Army (PLA), and his mother is in government.

ZHAO QIANLI


FBI agents found clothing in his hotel room in Miami that was evidence he was a member of China's Public Security Ministry Police, an intelligence and security service. Zhao was later found  to have failed to list his military background on his visa, which is required; his telephone showed that he had been in touch with Chinese intelligence officers located within the United States, before he illegally entered the naval base. His listed educational institution in China teaches only military science.

Zhao's target

Similar intelligence collection activities by Chinese "tourists' have been observed near US military installations in Alaska, Hawaii and Japan.
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* The Joint Inter-Agency Task Force-South has a counter-narcotics role in the Caribbean and Latin America, but also intelligence gathering, and coordination with US military in the region.




TEN ARRESTS MADE IN CLASSIC CAR FRAUD CASE RUN FROM BALTIC COUNTRIES

 
Indictments in US District Court in New York revealed a traditional fraud operation, operated by Latvian and Lithuanian fraudsters, that tricked victims into sending deposits, and later shipping fees, that they believed were payments for rare and classic automobiles which the defendants never owned. The FBI Eurasian Organized Crime Task Force appears to have been the lead agency; a number o the defendants were detained in Latvia & Lithuania, and extradited to New York.

The fraudsters reportedly impersonated classic car sales companies, and collectors; in addition to accepting payments for vehicles that they never owned, and had no intention of delivering, they drained the victims' bank accounts, once they had learned about their location from payments made to them. Some victims had taken out bank loans to pay for the cars, and were obligated to repay them.



The defendants were charged with  Conspiracy to Commit Money Laundering, and Conspiracy to Commit Bank and Wire Fraud. Readers who require the names of the defendants may access them  here. You may also download the indictments at that site.


RCMP IDENTIFIES FUGITIVES IN MASSIVE MONEY LAUNDERING NETWORK INVOLVING IRANIANS



The Royal Canadian Mounted Police have detained fifteen individuals in what has been described as an international money laundering network, with ties to organized crime. Seized, in addition to narcotics and $15m in real estate, was $1.7m in Canadian and foreign currency.

Still at large are:

(1) Victor Vargotskii, of Montreal.
(2) Mohamad Jaber, of Laval. He has been identified as one of the leaders of the network.
(3) Frederick Rayman, of Toronto.
(4) Francisco Javier Jimenez, residence unknown.

The suspects allegedly cleaned narcotics profits through Iran, Lebanon, the UAE, United States and China, en route to cartels in Colombia and Mexico. Iranian nationals arrested were all charged with money laundering, and various narcotics offenses, and several Iranian-owned foreign exchange firms were closed up.

The Iranian defendants, who have been identified to date are:

(A) Nader Geramian-Nik, of Vaughan, identified as one of the leaders.
(B) Ms. Tania Geramian-Nik.
(C) Ms. Sahar Shojaei.
(D) Mohammad Reza Sheikh Hassani.
(E) Ms. Shabnam Mansouri.

Local media reports indicate that the money, narcotics profits collected in Montreal, was moved through currency exchange houses in Toronto.

Sunday, February 17, 2019

UNIDENTIFIED ISIS-TYPE THREAT TO EXPLODE SKYSCRAPER IN LOS ANGELES




This photograph, which purports to show a plan to blow up on of the tallest buildings in Los Angeles, complete with what appear to be an ISIS flag, has appeared on the Internet. law enforcement has deemed it not a credible threat, but we will be monitoring California media, and if there is any more information, will publish it here forthwith.

PARIS POLICE ARREST SIX ENGAGED IN LUXURY GOODS RETAIL PURCHASE MONEY LAUNDERING SCHEME



All those Chinese "tourists" you see lined up in front of stores in Paris are not just buying something to show off when they return home. An English translation of a Chinese website reported that law enforcement authorities in Paris have arrested six individuals, all Chinese nationals, all engaged in the local purchase and resale in China of high-end luxury goods, for the purpose of laundering the proceeds of narcotics crime. The individuals allegedly were involved in more than the equivalent of more than USD$5m in purchases.

Lest you think that they were simply making profits on their purchases of five-figure handbags, expensive diamond jewelry, and other luxury goods that consumers acquire in pricey shops on Faubourg St HonorĂ©, and other Parisian boulevards, these people had counterfeit passports. The  "purchases" were shipped, or hand-delivered, to China, where the local demand brings them handsome profits, and those retail sales effectively clean the dirty money used to purchase the Vuitton, Gucci and other very expensive items.


WILL GAZPROMBANK LAUNDER PDVSA PROFITS THROUGH GAZPROM'S 100 SUBSIDIARIES ?



If you were expecting to see wire transfers boldly coming in from Gazprombank, in the wake of the announcement that the bank was going to facilitate oil profits earned by the OFAC-sanctioned Venezuelan government-owned PDVSA, think again. Gazprombank is a subsidiary of Gazprom, the world's largest oil conglomerate, ans Gazprom has over 100 wholly- or partially-owned subsidiaries throughout the world, including in a number of offshore tax havens where disguising the origin of funds is routine and totally opaque.

My advice is that if you are a compliance officer at a North American or EU financial institution, you familiarize yourself with the list of Gazprom subsidiaries on Wikipedia. This is especially relevant if your client base includes affluent Venezuelan nationals with connections to the present government.

RICHARD CHICHAKLI SUES THE UNITED STATES IN FEDERAL COURT



Richard Chichakli, who returned to the State of Texas to live, after serving his sentence for conspiracy to commit sanctions violations, continues to seek to hold the US Government accountable for actions it took against his assets after he was named a Specially Designated National (SDN) by the Office of Foreign Assets Control. He has alleged that property improperly seized from him was never returned, or was damaged through negligence.

Mr. Chichakli's first legal action, filed in the Federal Court of Claims, was recently dismissed by the Court on jurisdictional grounds, after it found that his claims sounded in tort. See Richard A Chichakli vs. The United States of America,  Case No.: 18-cv-00978-EDK ( Fed. Cl. 2019) 

Subsequently, on February 14, 2019,  he filed suit in US District Court for the Northern District of Texas, under the Federal Tort Claims Act, seeking return of real and personal property, precious gems, and cash, that he asserts has an assessed value of over $1.65m, plus accrued interest, plus damages in an unspecified amount, but within the jurisdiction of the Court. See Richard A Chichakli vs United States of America,  Case No.: 19-cv--0372-C (ND TX).

Readers who wish more details can access Mr. Chichakli's files on his website here. 





 

BULGARIA REPORTS LARGE FUNDS TRANSFERS FROM VENEZUELA - PDVSA



Apparently, corrupt Venezuelan officials are still quietly moving what are left of government funds out of the country in large amounts. A bank in Bulgaria, Investbank, reports wire transfers, originating from PDVSA, Venezuela's government oil company, arriving through US and EU intermediary financial institutions.

A government source in Sofia has advised that the amount transferred is around €60m; the bank has stated that no regulations or international sanctions have been violated. A local law enforcement investigation is in progress, and there is a mention of funds being blocked, but details are lacking.


Most observers of Venezuela's corrupt leadership believe that much of the funds stolen from government coffers and accounts resides in Switzerland; a new white-collar crime website, concentrating on Switzerland, has named a number of local banks, as well as branches of international banks, as holders of what could be billions of dollars of oil profits, diverted to accounts there. Given that the position of the Venezuelan Opposition is to recover those funds, expect Switzerland to become a legal battleground after the Maduro regime is ousted, or falls.

Saturday, February 16, 2019

RUSI PUBLISHES BRIEFING PAPER ON THE SCALE OF UK MONEY LAUNDERING


Readers in the United Kingdom and the Commonwealth may wish to review the latest relevant Briefing Paper, issued by the Royal United Services Institute for Defence and Security Studies. It is entitled The Scale of Money Laundering in the UK: Too Big to Measure ? You may access the complete text of the pdf document here.

TRIAL OF PILATUS BANK CHAIRMAN IN SANCTIONS CASE SET FOR OCTOBER: IS HE COOPERATING ?

 
The trial date, in US District Court in New York (SDNY), of the Iranian national Ali Sadr Hashemi Nejad, the Chairman of Malta's Pilatus Bank, closed by regulators, has been set for October 21, 2019. The defendant remains free on bond, which may be a signal that he either is, or shortly will be, cooperating with the authorities, regarding Iran sanctions evasion activities conducted through Pilatus Bank.

We are not buying the officially-stated reasons for such a lengthy delay of trial, Ends of Justice, and allowing the defendant sufficient time to prepare for trial. Nejad is charged with, among other counts, money laundering, bank fraud, and Iran sanctions violations. Would not the US Government wish to have Iran sanctions evasion cases tried as soon as possible ?

Also, given his possession of a St Kitts CBI passport, which affords him visa-free admission around the world, and his Iranian nationality, would he not be a major flight risk ? There must be another reason for both bond and the 10 month delay in trial date, and it is most likely cooperation with US law enforcement.


 

AFTER SIX MONTHS OF DELAY, ANTIGUA RUNS OUT OF EXCUSES WHY IT WILL NOT EXTRADITE CBI FUGITIVE

Mehul Choksi, Antigua's "Jabba the Hutt"
 
Last August, the Government of India notified Antigua & Barbuda that Mehul Choksi, an Indian fraudster who had cheated one of the country's biggest bank out of millions, was wanted for multiple crimes, and requested his extradition, as a fellow Commonwealth of Nations member.

Here is what the Government of Antigua's response has been to date:

(1) Sent its Director of Public Prosecutions, Anthony Armstrong, the most senior law enforcement official after the Attorney General, and the individual in charge of extradition, packing on a 30-day vacation, which insured that no action would be taken during that period.

(2) Held  several meeting with visiting officials from India, telling them each time that the matter was under legal consultations among local law enforcement, when no such action was under consideration.

(3) Arrogantly told the local press that, since India has revoked Choksi's passport, for his violation of his country's prohibition on dual citizenship acquisition,  that he would be stateless, if Antigua revoked his CBI passport.

(4) Insured that Choksi engaged one of the attorneys that represents disgraced former government banking regulator, Leroy King, who has evaded extradition to the United States for eleven years.

(5) Buy into Choksi's fable about how his excessive weight, and poor health, bars a long flight to India to face the music. Meanwhile, he is free to stuff himself in Antigua's restaurants, with no ill effects.

Now, we learn that the Director of Public Prosecutions has still NOT initiated any extradition proceeding in Antigua. Six months after he was allegedly engaged in intense consultations with Antigua's government attorneys, he has done absolutely nothing, as he follows the orders of the most senior officials in Antigua who now say that, if Choksi is extradited, which will be within one year of obtaining his CBI passport, that Antigua will lose revenue because other potential "investors" will fear that their CBI passports are subject to revocation, and stop coming to Antigua. That is the true reason why Choksi remains in Antigua, and will remain there, immune from the long arm of Indian justice.


Friday, February 15, 2019

DISTRICT JUDGE RULES PAUL MANAFORT INTENTIONALLY GAVE FALSE TESTIMONY


 Due to the extraordinary nature of the Court's ruling against Paul Manafort, we are publishing below the complete text of the Order, which included extensive Findings of Fact.



AMERICAN FINANCIAL INSTITUTIONS ALSO TARGETED IN PHISHING ACTIONS



Readers who saw our recent article Alert regarding Phishing Emails sent to BSA/AML Officers, which detailed how compliance officers tasked with anti-money laundering at US credit unions have been targeted through emails advising of a suspicious transactions, and asking recipients to open an attachment, which contained malware, should be aware that there are now additional victims.

Bank Secrecy Act officers at American financial institutions have now also been the subject of phishing actions. Any unusual emails that compliance officers receive, that ask you to open an attachment, please delete it immediately, after first taking a screenshot, which you should forward to your legal counsel.   

CORRUPTION SCANDAL OVER VISAS EXPOSED IN MALTA

Flag of Algeria
The Republic of Malta, already reeling over multiple corruption scandals involving the identification of officials in the Panama Papers, Pilatus Bank, and the country's Citizenship by Investment (CBP) program, now has yet another scandal exposed, which should be of serious concern to an already alert and unhappy European Union. Thousands of Visas reportedly issued to African nationals were obtained after bribes and other illegal compensation were paid to government officials.

The investigation centers around Visas issued to nationals of Algeria, both to "students' allegedly coming to Malta to learn English, and Visitor Visas. Records reported in Maltese media indicate that a large number of the Algerian arrivals failed to show up for their hotel reservations; this means that these individuals went right on into the other Schengen Zone countries, and did not even stay over one day in Malta, a violation of the terms of their Visas. Many of these arrivals, who were no-shows at the hotels, came to Malta during the holiday period, which raises suspicions that Maltese Visas have become a favored method of entering the other EU countries, illegally.

Also, Algerian arrivals far exceeded departures back home, confirming that these individuals did not remain in Malta, which was the puirported sole reason for their arrival via Visa.

An additional indicator of fraudulent activity was the immediate approval by the the Maltese Government of an Algerian Consulate, in record time, notwithstanding that there was no apparent need for one, nor was any evidence supplied in support of such a facility. A relative of a senior Maltese government official was named Consul-General, notwithstanding that he has no diplomatic experience or training. Bribes end up in the pockets of Malta's senior officials, in a country that is looking less and less like it belongs in the European Union, and more like a corrupt Banana Republic.



Thursday, February 14, 2019

PROBATION FOR MONEY LAUNDERING IS INSUFFICIENT DETERRENT


 A Turkish-American lobbyist who illegally used money supplied by  the state-owned Azerbaijan oil company, SOCAR, to fund a Congressional junket to Asia for ten lawmakers, and then lied about it to Congress, was sentenced to two years probation, 100 hours of Community Service, and a $20,000 fine, in what was essentially a money laundering case. Kemal (Kevin) Oksuz pled guilty to lying to the US Congress. in addition to the probation and fine, he was also sentenced time served, as he spent three months in custody, before he was extradited from Armenia.

The US Attorney from the District of Columbia  had requested that Oksuz serve one year in Federal Prison for his crimes. He was originally charged with five counts in the indictment. At the sentencing, the government also brought up that Oksuz had previously been engaged in arms trafficking. Failure to charge the defendant with the crime of money laundering, with the result that he only received probation, is insufficient to deter others from considering similar actions.

Wednesday, February 13, 2019

EUROPEAN COMMISSION PUBLISHES ITS 2019 BLACKLIST



Here is the much-anticipated list of countries with weak anti-money laundering and terrorist financing regimes. Readers who wish to review the complete text of the European Commission press release can access it here.

AFGHANISTAN
AMERICAN SAMOA
THE BAHAMA ISLANDS
BOTSWANA
DPRK (NORTH KOREA)
EITHIOPIA
GHANA
GUAM
IRAN
IRAQ
LIBYA
NIGERIA
PAKISTAN
PANAMA
PUERTO RICO
SAMOA
SAUDI ARABIA
SRI LANKA
SYRIA
TRINIDAD AND TOBAGO
YEMEN