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KENNETH RIJOCK - THE LAUNDRY MAN
Money Laundering, Terrorist Financing and Financial Crime
The method of operation over at Christian Nesheim's industry publication IMMIGRATION MIGRATION INSIDER (IMI) is to acquaint prospective investors regarding specific second passport programs (Citizenship by Investment, or CBI/CIP), but only telling them part of the whole story, while failing to disclose material facts and issues which could cause them to turn away from making that six figure investment, and all the while steering them to CBI consultancies that prominently advertise in IMI, publish Infomercials on its pages, and are featured therein as competent guides to assist purchasers find what is always described as the second pasport of their dreams, which will satisfy their needs for visa-free entry into just about every significant country in the world. It's a clever hustle.
CBI passport of a convicted Chinese national |
New Years' Day was the deadline for individuals who purchased a Citizenship by Investment (CBI/CIP) passport from the Federation of Saint Kitts & Nevis at an illegal discount to make arrangements to pay the difference between the amount they paid and the legal price. Although the country's prime minister, TERRANCE DREW, had publicly promised swift action against that those who failed to pay the sum they owe under Kittitian law, his government has, to date not revoked or cancelled the passports of any of the offenders, who bypaying an illegally discounted sum, have committed a criminal act under the Saint Kitts law. We have checked all Saint Kitts media, and all official government publications, and there has not been any such action to date, more than two weeks after the announced deadline, but imminent action is expected.
We do note that the SKN government never identified Galaxy as being the fraudulent promoter in their public announcements, obviously not to offend them and not to disrupt the ongoing fraud that they are perpetrating in Saint Lucia. Additionally, and even more problematic, the government has NEVER sent out such notices to the over 22,000 CBI passport holders of the Jail Project. How can it possibly hope to recover from those individuals if it conveniently neglects to solicit them for the balances owned?
The legal status of those illegally-obtained SKN CBI passports has been called in question by attorneys who are concerned that a court of competent jurisdiction will at one point rule that they should now be considered void ab initio (from the beginning of their issuance), which raises liability issues for any financial institution that accepts them at account opening as identification documents. This is due to the fact that they have effectively been declared illegal by Saint Kitts officials. Bank compliance officers, immigration officials, and other professionals who must secure proof of identity for real estate transactions, are urged to verify that any individual who proffers a SKN passport for any purpose, conduct an enhanced due diligence investigation, to rule out the possibility that it is one of those which have been illegitimately-obtained. Accepting a discounted passport, given actual notice of their illicit status, may constitute negligence and give rise to personal liability, if they are used for criminal acts.
This week's announcement, by British Virgin Islands Premier NATALIO WHEATELY, that the BVI government intends to explore the possibility of creating a Residency by Investment (RBI) program, similar to the one currently being offered by Portugal, in an effort to attract increased foreign investment to the British Overseas Territory. While we understand the Premier's good faith efforts to positively impact his jurisdiction's economy, The BVI's long history of official corruption would seem to indicate that such a program might facilitate an increase in money laundering, as well as other financial crime, in a territory which recently saw its then-sitting Premier, and others, imprisoned in the United States for long sentences for money laundering and narcotics trafficking. Additionally, a recent official UK-sponsored report highlighted systemic problems that plague BVI's autonomous local government.
Speaking from the compliance viewpoint, individuals who would be approved for Residency by Investment appear to then become British Overseas Territory Citizens (BOTC) a category of British Citizen that is allowed visa-free entry into the UK, to stay for up to six months, with other rights, including obtaining indefinite leave to remain there, and run for election to the House of Parliament. This is, in essence, a backdoor method of entry, which would potentially become available to career criminals, and frankly, I do not trust the corrupt BVI government not to accept bribes and kickbacks to grant them RBI, as occurs in many other CBI jurisdictions.
Will flack from the United Kingdom scotch this RBI program, before it becomes a reality? We cannot say, but in our humble opinion, based upon decades of observing and reporting upon the CBI/RBI debacle, the Foreign Office would best kill this idea in its infancy. There are enough career white collar criminals who sneak into the UK through CBI/CIP, from the Caribbean and from Malta, already; we don't need more.
The recent action, taken by the ECCB, the regional financial regulator for the East Caribbean, to take over management and administration of Saint Lucia's principal indigenous non-bank financial institution, FINANCIAL INVESTMENT AND CONSULTANCY SERVICES, has caused us to make further inquiries concerning the grounds believed to be the reasons for the regulator's swift action to take immediate control of the formerly majority family-owned and operated entity.
While the Eastern Caribbean Central Bank has not officially announced upon which basis it made the decision to intervene, in order to protect the bank's depositors, we have learned that some of its shareholders sought to sell their share of stock last year, without success. Most financial observers of the bank's operation believe that the ECCB action was taken after well-founded fears of the bank's solvency surfaced in the business community, causing the regulator to quietly open an investigation of the conduct of management of the principal officer, LORNE THEOPHILUS.
Any investigation into Theophilus would also inquire into his other activities, which means that his role as de facto Chairman of Saint Lucia's CIU, where he has come under fire for allowing alleged widespread misconduct by that agency in the sale of Citizenship by Investment (CIP) economic passports, and his potential exposure to criminal charges, both in Saint Lucia and in the United States. Additionally, even the most rudimentary investigation of Theophilus could reveal his prior arrest for Sexual Battery, which constitutes a crime of Moral Turpitude; Such a morally reprehensible act would affect the regulator's judgment regarding his fitness to lead a financial entity under its supervision, especially since the case was closed under questionable circumstances, concerning whether justice was served, due to Theophilus' privileged status. We have read the victim's statement in that case, and it is damning.
So, did the ECCB step in because it had serious reservations regarding Mr. Theophilus' ability to lead the FICS profitably, questions about his moral compass, or some additional grounds of financial mismanagement not yet made public? We cannot say, but we welcome the injection of Administrator Streete, to protect the assets of the depositors, and keep FICS solvent and operational for its customers, and will be seeking to learn further details as they unfold.
Longtime readers of our financial crime articles may recall that, back in 2021 and 2022, we covered the Land Registry fraud being conducted in Saint Lucia, whereby corrupt government officials in the land registry department altered deeds and other indicia of ownership of real property, to deprive expat Saint Lucians, as well as the heirs of local landowners who passed away, and whose assets were in probate. This, which is still being perpetrated upon the people of Saint Lucia, is accomplished through forgery, alteration and counterfeiting of deeds and conveyances, and outright theft and destruction of legitimate evidence of title, all by a group of clerks, lawyers and government ministers engaged in a conspiracy to take possession of valuable land, and sell it to unsuspecting purchasers.
The ruling Labour Party, which had promised when coming into office to abolish this illegal and amoral practice, has utterly failed to initiate a Land Registry Audit, as promised at election time. The organized fraud has continued, and our reliable sources have confirmed that the principal reason no reform has occurred, is that the country's Prime Minister, PHILLIP JEAN PIERRE, is receiving a portion of the illicit profits from the scheme, and has therefore blocked all efforts for an audit of the Land Registry records, and the claims of legitimate landowners for either their property, or the fair market value thereof. It appears that only regime change in Saint Lucia will result in effective land registry reform, to obtain justice for the victims, and PM Pierre must be called to account for his unexplained wealth in a court of law.
If you are a compliance officer at an international bank that encounters customers at account opening who are using economic passports of Citizenship by Investment (CBI/CIP) jurisdictions in the Caribbean or Europe, DO NOT use the information about those programs' due diligence that you read in the online industry media, for it is not only inaccurate and misleading, it deliberately misinforms investors, regarding the effectiveness and quality of such programs.
Industry publications, such as Immigration Migration Insider, or IMI, run by Christian Nesheim, (who is not a lawyer), portray CBI due diligence as being at the same level as those found in major financial institutions, but in truth and in fact, are often intentionally ineffective, and unevenly applied, resulting in career white-collar criminals, sanctions evaders, narcotics traffickers, and fraudsters obtaining CBI passports. Many of these criminals are subsequently arrested and prosecuted, a fact that IMI and its sister publications cleverly omits from its articles touting CBI due diligence programs.
Compliance officers should conduct their own de diligence investigation into the holders of CBI or CIP passports in specific jurisdictions, to include:
Remember the multi-billion dollar 1MDB Malaysian sovereign wealth fund fraud? There is new litigation, filed in the British Virgin Islands, against the HK multinational, AMICORP, and alleging that its subsidiary, Barbados-based AMICORP BANK, repeatedly fraudulently recycled funds, using shell companies, to make it appear that there were returns on investment.
We note that BVI companies were the predominant shell company vehicles asserted to be the tool employed by Amicorp, to perpetrate the fraud; Malta also shows up in the mix, which is no surprise. 1MDB waa the victim of a sophisticated money laundering scheme which successfully fleeced the sovereign wealth fund, and thereby cheated the people of Malaysia, the intended beneficiaries. We have a number of articles already on the blog, detailing the case, and some of its participants.
Online media in the Citizenship by Investment (CBI/CIP) industry, which is relied upon to a large part by investors seeking to acquire a second passport, and which purport to be a source of objective information about economic citizenships, fail to detail the risks consumers are taking on when they apply for a CBI investment. This is because companies such as Immigration Migration Insider (IMI) have a major Conflict of Interest, due to the influence of passport vendors and consultancies, which are major financial contributors to the publication, and frequently publish articles about CBI that fail to disclose the complete truth, concerning risks, as well as events which the investors should be advised of, prior to paying six figure fees and costs to purchase an economic passport. Don't expect the full truth from any publication who leading contributors are from the industry it is reporting upon.
The CBI media industry itself misleads the public, categorizing CBI as a valuable tool for wealthy individuals in high-risk jurisdictions to relocate to safer countries, or to give their children better educational opportunities. In truth and in fact, visa-free access to the Members of the European Union and the United Kingdom and Commonwealth countries is the principal reason for purchase.
Due to the Conflict of Interest, IMI and other online publications fail to detail several major risks that CBI purchasers potentially face, and which, had they known these shortcomings, might make them change their minds. Some of these are:
(1) Many of IMI's vendor clients have been selling illegally discounted CBI products for years, the sale of which constitute criminal acts under Saint Kitts & Nevis law, and also subject the purchasers to summary revocation of their expensive passports. IMI continues to support these companies and allow them to contribute content and advertise on its pages.
(2) Many of the CBI jurisdictions, such as Saint Kitts, Saint Lucia, Dominica and Malta, have a long history of not only being rogue tax havens, but as centers for money laundering, fraud, international sanctions evasion and corruption, and who openly sell CBI passports to career criminals involved in such illicit activity, who wish to conceal their true identities.
(3) There is a major ongoing criminal investigation in the United States, which could result in the indictment of CBI vendors and consultants, the loss of those valued EC and UK visa privileges, and even the complete termination of CBI programs. The risk to investors of loss of a substantial amount of money is again, not disclosed by IMI to its readers. Additionally, The role of Christian Nesheim, the CEO of IMI, who facilitated the CBI industry's program on disinformation and nondisclosure, through allowing vendors and consultants a forum which was supposed to be truthful and objective, needs further investigation.The role of Christian Nesheim, the CEO of IMI, who facilitated the CBI industry's program on disinformation and nondisclosure, through allowing vendors and consultants a forum which was supposed to be truthful and objective, needs further investigation.
Therefore, obtain advice from competent legal counsel before engaging in any application for the purchase of a second citizenship & passports. Know the risks before you buy.
FOR FURTHER INFORMATION: