DISTRICT JUDGE: YOU HAVE A "FUNDAMENTAL DUTY" TO CONFIRM YOUR AI RESEARCH, OR THERE WILL BE CONSEQUENCES.

Buried towards the end of the latest court ruling in the $2m judgment for Defamation, entered against MY PILLOW owner, MIKE LINDELL, is a scathing attack on Lindell's attorneys, who used AI for research, and failed to check what the program gave them as legal authority, when they cited it to the Court. The trial Judge pointed out the serious factual errors, regarding the court decision they cited. See the portion attached hereto.

The judge ruled that they had a FUNDAMENTAL DUTY to check all the material that artificial intelligence they proffered to the Court, and it appears that their negligence will possibly result in sanctions where they hold their law licenses.

Compliance officers, when you use AI to conduct due diligence, ALWAYS check the results independently through a known, trusted resource. Failing that,, you could approve or disapprove a new client, based upon fictitious "information," which might come back and bite you, and your bank, later. Check your AI results, please, every time.

A FORMER CAREER MONEY LAUNDERER EXPLAINS IT ALL REGARDING SUCCESS IN TRADE-BASED MONEY LAUNDERING

Inasmuch as most compliance professionals don't have a lifetime of experience in the identification of trade-based money laundering, like AVRAAM DEMETRIOU, I believe it is important for frontline compliance officers to understand how competent their TBML adversaries are, so that they govern themselves accordingly. Otherwise, the deck is, frankly, stacked against them.

First of all, many laundrymen who engage in trade-based money laundering have prior relevant industry experience, which affords them distinct advantages over bank compliance officers tasked with the identification of TBML. I remember attending an emergency Saturday hearing in Federal Court as a young bank lawyer, where it quickly became apparent that my opposing counsel had an extensive shipping background. Lawyers and accountants who have worked for freight forwarders, shipping lines, or law firms that handle maritime matters exclusively possess a familiarity with the industry that young compliance officers are sorely lacking, as they are dealing with a wide variety of client businesses.

Second, these TBML laundrymen generally have the ability to create legitimate-appearing documentation that, unless compliance takes valuable time to confirm, will pass muster every time, especially in the hurried environment of an international bank's compliance department, with deadlines on pushing out files, and ambitious junior compliance staff on the way up, conscious of their need to complete assignments not just on time, but actually ahead of schedule. That nasty end-of-day deadline on file reviews will result in TBML sneaking through every time, unless the compliance officer knows the tricks of the TBML "profession."

Finally, artful laundrymen in the TBML sphere apply money laundering tradecraft, used to penetrate other business sectors, which is usually missed by compliance officers intent on looking for industry-specific techniques. You are looking for apples, when your opponent is throwing oranges at you, and beating you.

Space doesn't permit further detailing of the winning TBML tradecraft; I have explained some of the tricks in prior articles, and if you require a tutorial on what to watch for, I can present a virtual seminar on those TBML methods for your compliance staff. Find me here: miamicompliance@gmail.com

SPONSOR BANKS: INCREASE AML EFFICIENCY OF YOUR FINTECH PARTNERS THROUGH TRAINING ON TECHNIQUES LAUNDRYMEN ARE KNOWN TO EMPLOY WITH IMPUNITY

Given the current position of America's regulators, that sponsor banks are ultimately responsible for the anti-money laundering shortcomings of their fintech partners, it is humbly suggested that they focus on imparting relevant knowledge to fintech compliance officers, regarding the money laundering techniques and methods that are known to be successfully employed to that specific sector of the financial services industry. Laundrymen often use shell and shelf companies, after artfully concealing beneficial ownership, to deceive busy fintech startups which are focused on expanding their customer base to reach profitable status. They bank on the eagerness of fintechs to attract new business, hoping that management will trump normal compliance concerns, when expanding that important client base. Money launderers also look for fintechs desperate to enlist strategic partners, for mutually beneficial business arrangements; under those circumstances, they are betting that fintech ownership may not look too closely at the background of partner ownership. Our concern is that proceeds of crime will be moved though the unsuspecting fintech, piggybacked with legitimate transactions. Who really owns that affiliated company? Often, fintech compliance officers are simply unaware of how advanced money laundering techniques, funneled through sponsor bank partners, appear at the their inbound end. It has become their responsibility to impart that tradecraft to them, even if it means regular training sessions at the fintech location, and not conducted virtually, so that message gets through of its importance. it may seem like an uphill battle, but unless a sponsor bank wants that unwelcome visit from regulators, exposing the fact that one fintech dropped the ball in a major matter, you must teach those generally inexperienced compliance officers how to spot specific money laundering methods in real-time.

THE CASE OF THE CONVICTED CHINESE MONEY LAUNDERER WITH THE ST. KITTS CBI PASSPORT AND THE FUGITIVE DISENTITLEMENT DOCTRINE

Remember DAREN LI a/k/a LI DAREN, the Chinese crypto scam fugitive, who pled guilty to Money Laundering Conspiracy, and then cut off his ankle bracelet, before fleeing the United States? An angry United States District Judge in Los Angeles, sentenced Li to the maximum - 20 years' imprisonment, for his crimes. We note however that Li, when interviewed at an undisclosed location abroad
(Cambodia, perhaps?) stated that his conviction, which he pled guilty to, was "unjust," that he had been "deceived and induced" to enter a guilty plea, and that his attorney was appealing his conviction. 

Perhaps someone should enlighten Li, regarding the FUGITIVE DISENTITLEMENT DOCTRINE, well established in American Federal jurisprudence, which states that:

"In Ortega-Rodriguez v. U.S., 507 U.S. 234 (1993), the Supreme Court observed that '[i]t has been settled for well over a century that an appellate court may dismiss the appeal of a defendant who is a fugitive from justice during the pendency of his appeal,' id. at 239, citing Smith v. United States, 94 U.S. 97 (1876), as its earliest invocation of the doctrine."

Li will have to surrender himself, and return to custody, if he want to prosecute an appeal, and even then, there's case law affirming that an appellate court may not commit error if it dismisses his appeal anyway. Perhaps he should have taken the time to consult with his attorney, before cutting off that ankle bracelet, if he was truly serious about his claim of being railroaded into a guilty plea.

PAUL BILZERIAN: TIME MAY BE RUNNING OUT IN THE CARIBBEAN

Paul Bilzarian

Let me be very clear to my friends in the compliance community: Paul Bilzerian is a wanted man in the United States. There is a current federal indictment; There are active criminal charges; And there is an arrest warrant. Yet, for years, he has continued to reside in Saint Kitts and Nevis, operating in a jurisdiction that many of you already know well — not from tourism brochures, but from SAR filings and enhanced due diligence reports.

THIS CASE NEVER CLOSED — IT EVOLVED

Some of you may remember Bilzerian from his original conviction back in the 1980s. Securities fraud. Aggressive takeover schemes. A textbook case.But the real story — the one compliance officers should care about — is what came after.
- Massive disgorgement orders from the U.S. Securities and Exchange Commission 
- A refusal to pay 
- Decades of litigation and a judgment
- And the systematic movement of assets offshore 

Fast forward to 2024, and the U.S. government has had enough. New charges include wire fraud, securities fraud, and conspiracy.This is no longer a historical case. It is active.

THE ST. KITTS FACTOR — AND THE CBI QUESTION

Bilzerian relocated to a jurisdiction that offers financial opacity, flexible corporate structures, and a long-standing Citizenship-by-Investment (CBI) program. CBI is not illegal. But from a compliance standpoint, it introduces identity layering, jurisdictional complexity, and obstacles to enforcement.

THE STRUCTURE: CONTROL WITHOUT OWNERSHIP

According to U.S. prosecutors, Bilzerian’s financial strategy follows a familiar offshore pattern:
- Assets placed in offshore entities 
- Nominee ownership 
- Indirect control mechanisms 
He doesn’t “own” the assets — but he controls them.

DETENTION REPORTS — A POSSIBLE SHIFT

Local outlet St. Kitts Times reported that Bilzerian was detained on the island. At the time of writing, this has not been confirmed by U.S. authorities or the government of St. Kitts and Nevis. If confirmed, it could signal a shift.

THE PRESSURE ON SMALL JURISDICTIONS

The United States has intensified enforcement across the Western Hemisphere. Jurisdictions like St. Kitts and Nevis face a choice: protect offshore clients or maintain access to the U.S. financial system.

EXTRADITION: FROM THEORY TO POSSIBILITY

If U.S. pressure increases, extradition becomes a credible scenario.

LOCAL RELATIONSHIPS — AND PERCEPTION RISK

There are persistent perceptions that offshore actors develop proximity to local elites. There is no publicly confirmed evidence of specific relationships between Bilzerian and senior officials. But perception risk alone can drive action.

FINAL ANALYSIS

Paul Bilzerian is wanted by the United States government; He has operated from a CBI jurisdiction for years. The question is no longer whether he can remain offshore — but whether the jurisdiction can afford to keep him.

THE RIJOCK RULE

Offshore protection works — until the cost of providing it exceeds the benefit.

____________________________________________________

FOR FURTHER READING:

ST KITTS ECONOMIC CITIZENSHIP REP IS CAREER FRAUDSTER

https://rijock.blogspot.com/2016/07/st-kitts-economic-citizenship-rep-is_5.html

AS ANTIGUA'S ALFA NERO SCANDAL REMAINS UNRESOLVED, PRIME MINISTER BROWNE CALLS A SNAP ELECTION; FEAR AND LOATHING?

PM Gaston Browne

Antigua's beleaguered Prime Minister, GASTON BROWNE, whose sitting Labour Party (ABLP) remains under a cloud created by the suspicious, and patently illegal, sale of the Russian luxury Yacht ALFA NERO, with missing millions in proceeds and a stolen fine art collection known to be on board reportedly worth more than the vessel itself, has called a snap General Election, to be held within the next 90 days. Although Antiguan law specifies that the next election is not due until January 2028, Browne reportedly sees a political advantage, due to recent events, in moving forward at this time.

Insiders in Antigua say that Browne is focused on remaining in office, as he believes that, so long as he remains as PM, the US Department of Justice will not choose to indict him, on a number of of corruption and money laundering charges, going back decades, that he would most likely face as a private citizen. The most damaging one, the Alfa Nero luxury yacht case, reportedly resulted in the DOJ receiving incriminating evidence that personally implicated him in a bogus sale, with missing sale proceeds, and a quick resale listing by the purchaser, all of which appears to implicate Browne, his family, and close business and political associates.

Given the widespread vote buying and rampant voter fraud that has been a feature of Antiguan elections in the past, it is fully expected that The ABLP will again emerge the victor, notwithstanding significant opposition among voters and Opposition parties. It is not expected to be a free and fair election process. Additionally, the stagnant state of the Antiguan economy, with good private sector jobs generally absent, and the resulting bloated government employment, leaving many voters subject to ABLP intimidation, any outcome where Labour does not prevail is extremely unlikely.

Therefore, we do not expect that the systemic corruption, and accompanying money laundering that plagues Antigua, will be reduced anytime soon. Corruption officers at banks in North America and Europe should continue to regard the jurisdiction as having elevated risk levels for financial crime.

GOVERNMENT OFFICIAL RECEIVES 72 YEAR SENTENCE FOR MONEY LAUNDERING; WILL IT DETER OTHERS WHO ARE TEMPTED IN NIGERIA?

Chukwunyere Anamekwe Nwabuoku, formerly acting Accountant-General in the Federal Government of Nigeria, was sentenced to a jaw-dropping seventy two years in prison, on multiple money laundering charges, an extraordinary sentence in a country known for massive official corruption raging out of control, which may explain the sentence. Nwabuoku diverted N868,465,000, the equivalent of USD$630,000, by transferring the funds to shell companies that he controlled.

In the United States, the maximum sentence for violations of the Money Laundering Control Act of 1986 is twenty years in Federal Prison, but that sentence is rarely, if ever, imposed by District Judges. Perhaps they might want to take judicial notice of this case, for short sentences for money laundering do not appear to have served as adequate deterrence, given that the United States Sentencing Commission lists over 25,500 Federal convictions since 2001.

FEDERAL JUDGE STRIKES DOWN THE NEW FINCEN RULE REQUIRING REPORTING ON CASH SALES TO TRUSTS AND OTHER ENTITIES

A United States District Judge in Texas (EDTX) has ruled that the FinCEN regulations, which became effective 1 March, 2026, and which required reporting on all cash sales of residential real estate to trusts and corporations, was an unlawful extension of the Bank Secrecy Act. Obviously, there will be an appeal to the Fifth Circuit, and most likely to the US Supreme Court, but this decision throws compliance with the regulations into a quandry. There have been three other District Court decisions approving the regulations, which sets up the probability of Conflict Certiorari to the High Court eventually, when those cases hit the Courts of Appeal.

Read the complete text of the 32-page decision here.

https://storage.courtlistener.com/recap/gov.uscourts.txed.237265/gov.uscourts.txed.237265.34.0.pdf

THE IDENTIFICATION OF CITIZENSHIP BY INVESTMENT (CBI) PASSPORTS BY COMPLIANCE OFFICERS FOR AML/CFT PURPOSES

                                 

While the investment migration industry sells most of its economic citizenships to legitimate purchasers, most of whom are affluent or high net worth individuals, a number of financial criminals do end up with passports that afford them visa-free entry into Europe or other areas, where they often seek to engage in white collar crime. Therefore, compliance officers at financial institutions and NBFIs must develop the skills necessary to readily identify CBI passports when they are presented as account opening, at real estate closings, and in connection with other business transactions.

It is humbly suggested that you follow these guidelines:
(1) Be aware of which jurisdictions currently, or previously, sell or sold economic citizenships; it is also helpful to keep a watchful eye on the CBI industry, so that you learn, in advance, of any new nation that is opening a program which could result in the appearance of new CBI passports in circulation, before you are aware that they are being sold.
(2) Assume that the listed name on a CBI passport is either a modification of the holder's legal name, an alias, or a possible translation/transliteration from another language, alphabet or script. This will interfere with your ability to use commercially available off the shelf databases to rule him or her out for sanctions or identification as high risk or with a criminal background abroad. Have you attempted to employ facial recognition software?
(3) Unless an individual has actually lived in the jurisdiction where his passport was issued, he generally will not have both the relevant language fluency, and the slang and terms peculiar to residents of that country. Do you have someone on your staff from that loication, who could tell in a moment if he was a native speaker, with local phrases, grammar usage and accent? Have him engage the client in conversation about what city he is from there.
(4) If you have not yet established that you have a CBI passport in your hands, check the Place or Birth closely. While originally, CBI jurisdictions like Saint Kitts and Dominica inserted bogus birthplace information, in recent years, legal requirements or local practice have dictated that the holder's real birthplace be listed; this can be an additional confirmation of CBI status.
(5) the passport of most world travelers have several pages of entry and exit stamps, visas, work authorizations, and other notations. Is the passport you have in hand new, and with few such stamp? That is one of the indicia of possible CBI passport status.

With experience, compliance officers are usually able to spot a CBI passport early on, and then must decide, as gatekeeper, whether enhanced due diligence is the next step, or should they decline the business outright, report it up the chain of command, or file a SAR. It's your decision; Choose wisely.

SPECULATION ABOUNDS HERE REGARDING ALEX SAAB MORAN'S NEW SEALED INDICTMENT, AND WHEN HE WILL BE EXTRADITED A SECOND TIME TO THE UNITED STATES

The mystery surrounding ALEX NAIN SAAB MORAN, the Colombian money launderer closely associated with former Venezuelan President NICOLAS MADURO's criminal enterprises, continues to roil legal observers here in Miami; when will he be extradited, and who else is a named defendant in the sealed Federal indictment reportedly filed against him in January, in the U.S. District Court for the Southern District of Florida. Other than it involves corruption charges, there is no other information available from any source, regarding details of the new charges against Saab, who was previously granted a pardon in connection with a prisoner (essentially hostage) exchange for Americans held by Venezuela.

Readers who wish further information on Saab's original Federal case can find a number of articles detailing his initial arrest in Cabo Verde, subsequent extradition to the United States, and proceedings in the prior SDNY case, on my blog here. Use the White search box at the top of the page.

We do know that there is conflicting information regarding whether Saab is being detained, and under what conditions, though it is known that Venezuela's current president, DELCY RODRIGUEZ, has removed him from his position as Minister of Industry and National Production; his wife was also said to have lost her government post. There has been no information released to the media on the status of negotiations for his extradition, or that of any other targets.

I WARNED GRENADA ABOUT ITS HANG SHENG CHINA SCAM; U.S. IMPOSES A $15,000 VISA BOND

If you were wondering when the U.S. Department of State was going to respond to Grenada's continued massive sale of CBI passports to Chinese nationals, giving them the ability to take advantage of Grenada's unique to the Caribbean E-2 visa privileges, it happened today, when Secretary MARCO RUBIO announced that the Eastern Caribbean state is one of twelve new high risk jurisdictions whose nationals must now post an expensive bond, when applying for a visa. Don't native-born Grenadians understand that this is the American response to their government's actions, and that the continued existence of that valued E-2 visa eligibility that they currently enjoy is at risk?

Industry apologists have been downplaying Grenada's Prime Minister's intense political alliance with the Peoples' Republic of China, and ignoring the country's continued business relationship with the Chinese-controlled HANG SHENG GROUP. A number of Chinese nationals, all holding CBI passports from the Caribbean, have been arrested in the United States on a variety of criminal charges, including white collar crime and industrial espionage conduced on behalf of China, and this new $15,000 visa bond, as what was previously imposed on citizens of Antigua & Dominica, also CBI-issuing states, is the real reason for this new American action.

I have repeatedly warned Grenada about the probable consequences of operating a rogue CBI program. Wake up, Grenada, before you see an even stronger American response to your sale of CBI passports to criminals and high risk individuals targeting the United States for China. Reform your CBI program; if you cannot , then terminate it.

HOW DID BVI PREMIER ANDREW FAHIE'S CO-DEFENDANT, OLEANVINE PICKERING MAYNARD SERVE ONLY ONE YEAR OF A NINE YEAR SENTENCE ON COCAINE CHARGES?

If you know how Rule 35 Sentencing Reduction works in Federal Court, cooperating defendants often receive up to a 50% cut in their sentences. Rarely do we see more; the huge (65%) sentence reduction handed out in Miami to the Swiss banker/money launderer MATTHIAS KRULL was obviously payment for his testimony against a major Venezuelan money laundering operation, but that is the rare exception.

OLEANVINE PICKERING MAYNARD, the BVI port manager who received a nine year sentence in the ANDREW FAHIE drug & money laundering sting, served only a single year of her sentence, before being released. A 90% reduction in her sentence is quite extraordinary, and it most certainly was not as the result of her trial testimony against Fahie. We must assume that she gave evidence implicating other senior Caribbean government officials, and they either not been indicted yet, or more likely, their are sealed indictments being held until the targets are physically within the jurisdiction of the United States, such as a quick trip over to the US Virgin Islands, which is sovereign American territory.

We will be watching for the case that Oleanvine, and her son KADEEM MAYNARD, who also drew a major sentence reduction, spawned. I imagine there are some nervous government officials in the BVI with sleepless nights these days.