SHEER CBI MADNESS; NEW SIERRA LEONE PROGRAM WILL ALLOW REMOTE "RELATIVES" AND UNVERIFIED "BUSINESS PARTNERS" TO PIGGYBACK WITH THE PRIMARY APPLICANT !

Forty-two years after Saint Kitts' diplomat (and money launderer) WILLIAM HERBERT, JR. created the first functional Citizenship by Investment passport sales program, to offer to the Medellin Cartel, someone has just found a way to exceed his dark vision: the new, expanded SIERRA LEONE CBI scheme, as detailed in investment migration mouthpiece IMI DAILY, offers consumers the broadest definition possible of relatives, and even has a catchall category of Business Partners, without any qualifying factor of an established relationship. 

The country is a hornets' nest of rampant corruption; read the international media to verify.

Pure insanity; money launderers today must be booking the next available flight to Freetown ( being careful to cover their tracks), for it is the perfect storm in which to place career criminal clients ( with aliases, of course) and even themselves, as part of the crazy Friends & Family Sierra Leone scheme. I cannot wait until transnational white collar criminals, each holding this new career risk reduction device, start to get arrested around the globe. Is there no limit to the amount of pure greed behind these new African-based programs? has anyone considered the Unintended Consequences? I rest my case.

Nigerian wanted for murder who paid $25,000 for Sierra Leone passport showing him born in Freetown.

SPONSOR BANKS WOULD DO WELL TO SEE THAT REGULAR ADVERSE MEDIA SCREENING OF THEIR FINTECH PARTNERS IS CONDUCTED, AS PART OF A PRUDENT RISK REDUCTION PROGRAM

While we have been focused of late in concentrating upon the need for sponsor banks to insure, through a variety of way, that their fintech partners create and maintain an effective program of AML compliance, there is another area that requires attention: regular adverse media screening of all fintech clients. It is in the sponsor bank's vested interest to periodically troll for adverse media, including social media, to watch for retail customer complaints, civil litigation, regulatory issues, employee or leadership disputes, and other negative news that might indicate legal, regulatory, personnel, or public perception problems.

Sponsor banks must be able to anticipate operational, financial, consumer and legal problems that may befall their fintechs, as they could directly affect account traffic, and even sponsor bank reputation, due to the fact that they are linked in a number of ways to their fintechs. Consumer complaints, and issues with fintech product reliability, could be directed at the sponsor bank where payments were processed, irrespective of fault or blame.

There are a number of outstanding adverse media screening programs and tools commercially available; some go beyond what had been described as straightforeward screening to providing context behind potential risks. Whatever program you choose, do so after careful consideration, so that you can analyze risk to your bank early on, before rapidly moving events overtake your ability to take corrective steps.

Of course, as a retired and reformed career money launderer, I am concerned with the possibility that fintech misconduct could constitute a predicate act supporting a money laundering charge against not only the fintech, but involving the sponsor bank as well.

If you, as a sponsor bank, aren't using an adverse media screening platform, prudent risk management dictates that you acquire one, and monitor any emerging fintech controversies that appear.

SHOULD SPONSOR BANKS CREATE INTERNAL CLINICS FOR THE COMPLIANCE STAFF AT THEIR FINTECH PARTNERS, TO INSURE THAT EFFECTIVE AML PROGRAMS ARE OPERATIONAL?

Given the fact that the compliance programs in place at many fintechs have come under attack, for being sub-standard or ineffective, especially when it comes to anti-money laundering, should not sponsor banks take the bull by the horn and conduct compliance clinics to remedy the deficiencies? Full day programs, offered specifically by each sponsor bank to its fintech partners, would focus on customer identification procedures, transaction monitoring, money laundering tradecraft, and other relevant subjects that have been identified as fintech compliance shortcomings, to elevate the proficiency of each individual fintech compliance officer, and thereby reduce risk levels at sponsor banks.

A one-day in person program, and definitely not virtual, would foster the frank exchange of information, identify specific problem areas, and serve as a forum for fintech compliance officer feedback. Sponsor banks should use not just their own compliance staff, but industry experts to round out the program and keep it interesting, which would attract attendees. A document confirming attendance, and certifying it, could be an Important part of the continuing professional education of those fintech compliance officers, as well as further develop the relationship between fintech staff and compliance officers at their sponsor bank.

Finally, since so much of what sponsor banks do in the compliance sector has mitigation relevance, such a program, when presented to regulators in responding to any future compliance issues, could even serve to reduce or eliminate ultimate civil fines and penalties contemplated by regulators; think seriously about establishing such a program.

SOME OF THE TRICKS UNETHICAL CARIBBEAN ECONOMIC CITIZENSHIP SALESMEN USE TO DIVERT APPLICATION FEES

If you followed the MSR Media cases, you know that many of the Chinese-controlled companies selling passports from the five Eastern Caribbean states had their customers send the application fees to banks in Singapore and Hong Kong, rather than into financial institutions located ion the Caribbean. As the result, it is conservatively estimated that at least four billion US dollars was diverted from Saint Kitts & Nevis and Saint Lucia CBI & CIP programs.

For those following the outright theft of client application fees in the current RIF TRUST INVESTMENTS/LU GOLD LTD. story, the Nigerian company was manipulated into delivering the money, in cash, directly into the hands of RIF executive DENNIS GUTTIG, JR., who also forged the client's signature on funds reimbursement instructions. Remember none of these salesmen, or the passport vendor companies, has any sort of professional license subject to regulation, nor is the investment migration field regulated by any country other than those which sell the passports, and those can only cancel the permit to sell. This business operates outside any legal control, with the consequences I have detailed above. It gives Caveat Emptor a whole new meaning.

COMPLIANCE OFFICERS PLEASE NOTE; AMERICANS HAVE APPARENTLY REACQUIRED THEIR TASTE FOR COCAINE OF LATE, AND YOU KNOW WHAT THAT MEAN$

Major media, including the Wall Street Journal, has been repeatedly warning that American consumers seem to have rediscovered their affinity for cocaine, as they are reporting that their consumption of the drug has increased more than 150% in recent years. The increase has more notably occurred in the Western states, and has been linked to the increased focus on countering the Fentanyl problem rural America has been cursed with. The assessment is that counterdrug enforcement regarding cocaine has been neglected by the present administration, since it came into office in January.

As a former career money launderer of cocaine profits, during the 1980s, and an anti-money laundering consultant to law enforcement in the 90s, I know from personal experience that a large percentage of the proceeds from coke sales is moved through U.S. financial institutions, and a portion is laundered domestically, before being invested in cash-producing investments in the legitimate domestic economy.

Therefore, educate your frontline compliance and teller staff, who were not on duty during the "Miami Vice" era of domestic money laundering, to recognize legacy laundering tradecraft, those original methods and techniques that were in regular use back then. Think cash-intensive businesses; bogus consultancies; real estate with two sets of closing statements, and all those cleverly employed tricks of the laundryman's trade, which thrived before the Money Laundering Control Act of 1986. Do you know what they are?

Be alert, ladies and gentlemen of the compliance community, as the individuals who must now launder their clients' increased cocaine profits are on the job; catch them by identifying those legacy methods.

BUYERS OF SECOND PASSPORTS MUST INSURE THAT THE VENDORS AND AGENTS ALL PASS DUE DILIGENCE BEFORE RISKING ANY FUNDS

Wealthy individuals who are seeking to acquire a citizenship from a low-risk jurisdiction that has visa-free access to the EU, UK and Commonwealth states had best see that competent professionals conduct due diligence upon not only the companies involved in the sales process, but the actual individuals within those entities, lest they later find themselves victims of fraud, and never get that prized passport, or worse, find themselves in legal trouble, because they neglected to look before they leaped. The usually means they neglect to retain legal counsel to ascertain the level of risk in advance.

Take the case I have been reporting upon, involving a prospective purchaser of a Saint Lucia citizenship & passport. He engaged a Nigerian firm, LU GOLD, LTD, and apparently did not make the appropriate inquiries about its history as a vendor of economic citizenships & passports, for if he had, he would have learned that the company was new to the second passport business, did not advertise such services, and had just recently become a sub-agent qualified to sell economic citizenships. It had no track record of success in that business.

Going one step further, LU GOLD is also guilty of failing to conduct due diligence on RIF TRUST INVESTMENTS, LTD., who was its designated agent, for RIF was known to be selling passports for illegally-discounted rates. Indeed, the passport application which was the subject of the fraud, was to be sold for only 50% of the minimum sales price for Saint Lucia citizenships. Zero due diligence here.

Finally, the RIF sales executive himself, the American DENNIS GUTTIG JR., had a nasty 2017 civil suit filed against him, alleging misappropriation of trade secrets, fraud, fraudulent concealment, breach of fiduciary duty, unfair competition, unjust enrichment, conversion, breach of contract, claim for an accounting, promissory estoppel, abuse of control , and gross mismanagement. A simple Google search would have turned up this and other similarly disqualifying issues, but again no due diligence was performed ahead of funding by Lu Gold.

Dennis Guttig

So you see that, for the want of a horse, the kingdom was lost. Any good lawyer brought in to survey the players in the transaction would have killed it immediately. We cannot stress strongly enough the need to engage experienced legal counsel, before taking any steps to acquire a passport, lest you have an unhappy experience like the passport applicant in this case. He or she must conduct due diligence ahead of any investment payment, without fail, or your experience might be one of loss.

VICTIMS OF RIF TRUST FRAUD APPLIED FOR CITIZENSHIP BY INVESTMENT THROUGH CARIBBEAN GALAXY SUB-AGENT LU GOLD IN NIGERIA

Given the significant amount of interest shown by our readers in the recent articles detailing documented grand theft, fraud, document alteration and counterfeiting of client signatures. alleged by victims of Dubai-based economic passport seller RIF TRUST INVESTMENTS LLC, we are continuing our series on the unfolding story. 

The victims' passport application fees, which were diverted and stolen by RIF senior executive DENNIS GUTTIG, were submitted by a Nigerian firm, LU GOLD, LTD. which is a sub-agent of CARIBBEAN GALAXY GROUP, the Chinese company which we have extensively reported on in recent months, and which is known to have sold tens of thousands of SAINT LUCIA economic citizenships without any effective due diligence upon the applicants.

RIF TRUST agent Guttig not only admitted his criminal conduct in writing, through evidence confirms that he initially made small token payments, and part of a scheme of restitution that he failed to complete. Lu Gold subsequently made repeated efforts to recover its clients' funds, including a direct appeal to Caribbean Galaxy in Saint Lucia, but was unsuccessful.

We will continue to probe links between RIF Trust and Dubai-based RAYNUMA CAPITAL, where Guttig is currently the Vice President, as well as investigating the yet-unidentified Portuguese entity that is believed to have acquired the assets only of RIF, in an obvious scheme to defraud these victims, and any other clients which have a cause of action against the company, and its officers and owner, MIMOUN ASSRAOUI, for selling them illegally-discounted Caribbean citizenships, which are subject to cancellation and expose the purchasers to criminal prosecution in Caribbean jurisdictions.

RIF TRUST CEO Mimoun Assraoui

SPONSOR BANKS: WATCH FOR SYNTHETIC IDENTITIES BEING USED TO LAUNDER THE PROCEEDS OF CRIME THROUGH YOUR FINTECH PARTNERS

As a former career money launderer, I was extremely cautious about laundering illicit profits through American financial institutions, due to the ability of bank compliance officers to spot the deposit of funds which had no legitimate origin. I therefore tended to work with cooperating businesses which were cash-intensive, and would allow me to supplement their legitimate cash income being deposited with my clients' criminal proceeds.

Sponsor banks should be aware that a similar method can be employed to clean the proceeds of crime through fintechs; a "talented" money launderer first assembles a number of synthetic identities, which are created by using a combination of real and fabricated information to result in what are essentially fake persons. While we are familiar with the widespread use of synthetics to commit fraud, in this case, the laundryman's goal is to have them pose as fintech customers or clients, to add to its legitimate income stream. Thus, the bogus "business" passing through the fintech, and into its sponsor bank accounts, is cleaned.

A criminal element within the fintech, perhaps even working without the knowledge and consent of management, can later find a way to divert that now cleaned dirty money in a variety of ways, such as consultants' fees, or payment for phantom supplies and services. The solution for sponsor bank compliance officers is to periodically vet a sampling of its fintech clients, to confirm that those represented to be customers are actually real individuals, and not synthetics. A smart sponsor bank already has such a program in place; call it proactive KYCC, Know Your Customers' Customers.

UNITED STATES IMPOSES DRACONIAN CBI MEASURES ON CARIBBEAN COUNTRIES

US Deputy Chief of Staff STEPHEN MILLER

In a stunning turn of events, diplomatic sources have confirmed that Stephen Miller, the White House Deputy Chief of Staff, on behalf of the United States, has introduced sweeping new restrictions, targeting all Citizenship-by-Investment (CBI) programs across the Caribbean.

These new restrictions, which will most certainly be judged to be Draconian by all the Caribbean governments, were imposed following a two-year investigation by the Department of Homeland Security, during which American law enforcement  authorities reportedly uncovered massive fraud, money laundering, financial irregularities, not and through offshore accounts linked to CBI schemes in multiple Caribbean island nations. It is called the EASTERN CARIBBEAN CITIZENSHIP BY INVESTMENT REGULATORY AUTHORITY AGREEMENT BILL (104 pages).

White House Deputy Chief of Staff for Policy Stephen Miller has personally intervened, directing the implementation of new regulatory measures aimed at restoring integrity to the CBI framework. According to reliable diplomatic sources, the five Caribbean CBI and CIP nations now risk losing total access to the United States—including travel privileges—if they fail to comply with all the provisions presented by the United States.

These measures were formally presented last week in the Parliament of Saint Lucia, signaling the beginning of a regional overhaul that could redefine the future of the Caribbean’s multi-billion-dollar CBI industry. We have thoroughly reviewed the draft provisions, and they operate to completely reform all aspects of the Saint Lucia Citizenship by Investment (CIP) program, and which, in our opinion, require a level of compliance that has never before been seen in Saint Lucian Governmental history, meaning that, for all intents and purposes, the CIP program will be terminated, to avoid a universal block on entry of the nation's citizens into the United States. 

We are attaching herein the Outline of the restrictions, which according to our sources, must be enacted verbatim by each CBI state, without any changes or amendments, or the entry ban will go into immediate effect. In a subsequent article, we intend to cover all the major provisions in detail. This is a groundbreaking new measure, which will shake up the governments of  Saint Kitts & Nevis, Dominica, Antigua & Barbuda,  Saint Lucia and Grenada. Have the leaders of the five CBI Caribbean nations disclosed this information to their citizens, the international sales agents, and the CBI promoters?

AMERICAN EXECUTIVE AT RIF TRUST WHO STOLE CLIENTS' PASSPORT APPLICATION FEES IS NOW V.P. AT U.S. BASED PRIVATE EQUITY FIRM IN DUBAI

DENNIS GUTTIG, the senior sales executive at RIF TRUST INVESTMENTS LLC, whose alleged misconduct we described in detail in our previous article, MEET THE AMERICAN EXECUTIVE AT RIF TRUST WHO ALERED APPLICATIONS, FORGED SIGNATURES, AND STOLE CLIENT'S APPLICATION FEES, WHILE PROTECTED BY COMPANY MANAGEMENT AND CARIBBEAN GALAXY
https://lnkd.in/ennebKhc appears now, according to his Linkedin page, to be a Vice President of Raynuma Capital, identified as a US-based Private Equity firm. We wonder whether Raynuma conducted a due diligence inquiry on Mr. Guttig, prior to his assuming a VP role at the company.

We shall be providing further details on Mr. Guttig's egregious misconduct at while at RIF Trust, which included victim allegations that could give rise to charges of fraud and money laundering, when he stole deposits of African clients of RIF which were intended to be deposits towards a Citizenship by Investment (CIP) application at the Eastern Caribbean state of SAINT LUCIA.

RAYNUMA logo

We are so far unable to confirm whether RIF TRUST management sold all the assets of the company, and not the liabilities, to a Portuguese firm, and could be defunct, for all intents and purposes; Our investigation continues. We also are looking into any potential connections between Raynuma and RIF.