HOW SPONSOR BANKS CAN REDUCE THEIR LIABILITY FOR MONEY LAUNDERING AT THEIR FINTECH PARTNERS

When a friend sought to retain the services of an effective divorce lawyer, whilst contemplating the filing of a petition for dissolution of marriage here in Florida, I directed her to one of Miami's premier attorneys who specialize in that type of litigation, because that lawyer's initial consultation with clients always included the client taking away form that meeting a summary of both rights and responsibilities in contested divorce cases. The object of that briefing package, which the client was required to sign at the subsequent consultation, was to insure that he or she fully understood what was expected of them.

As regulators regularly assign liability for fintech deficiencies in anti-money laundering compliance to the sponsor bank partner, It is humbly suggested that this technique be applied for AML/CFT risk reduction in this manner: that newly onboarded fintechs must execute an extensive briefing package, which includes the minimum compliance requirements for operating with the sponsor bank partner. Furthermore, not only is the fintech required to employ banking best practices in its compliance program, but that the typical methods and
techniques that money launderers employ at fintechs be specifically listed, and that fintech management, as well as compliance, agrees that it understands them and will make a major effort to find and interdict them. If Sponsor banks are unaware of what methods should be included in the briefing, this old reformed money launderer will be happy to assist them.

Since regulators love to point the finger at sponsor banks, for the compliance mistakes of their fintechs, look that the signed briefing book as an appropriate response to them, demonstrating that the sponsor bank has defined that obligations of fintech compliance, and that this responsibility has been acknowledged and assumed.

DOES MALTA'S CURRENT PRIME MINISTER HAVE TOO MANY SKELETONS IN HIS OWN CLOSET TO SEIZE HIS CORRUPT PREDECESSOR'S MILLIONS, SITTING IN FOREIGN BANK ACCOUNTS

                                

Robert Abela, by COSIMO

Our recent article, WILL MALTA'S MOST CORRUPT PRIME MINISTER NOW BE UNABLE TO GET HIS MILLIONS IN BRIBES & KICKBACKS OUT OF DUBAI? https://lnkd.in/d-QJRY4 exposed allegations that JOSEPH MUSCAT, the former Prime Minister of the Republic of Malta (2013-2020), has reportedly cached many millions of Euros and Dollars in a prominent UAE financial institution. These funds, alleged to be bribes and kickbacks paid to Muscat, by American businessmen and others, should be properly seized and forfeited to the people of Malta.

Joseph Muscat and Robert Abela

Unfortunately, Joseph Muscat's successor, ROBERT ABELA (2020-present), has refrained from seeking justice for his constituents. In truth and in fact, before replacing the disgraced Muscat, Abela was his most trusted advisor when in private legal practice. In addition, although he presented himself as an employment attorney, he represented a number of Maltese allegedly known to be connected to organized crime, individuals who appear to have repeatedly evaded accountability in the country's arcane criminal justice system, which allows cases to be delayed indefinitely, where prominent lawyers are involved.

In truth and in fact, PM Abela appears to have a Conflict of Interest in taking Muscat's alleged criminal profits away from him, as well as sufficient skeletons in his own closet that to preclude any move against Muscat, who could expose his successor's dark background if charged with corruption. Will Muscat escape justice due to Abela's sins?

ARGENTINA ATTRACTS CBI GIANTS, AS CARIBBEAN PROGRAMS FACE INTERNATIONAL PRESSURE

The global citizenship-by-investment (CBI) industry appears to be entering a period of profound transformation. For decades, the Caribbean dominated this lucrative market, But mounting scrutiny from the United States, the United Kingdom, and the European Union—combined with tightening visa policies—may now be accelerating a strategic shift away from the region.The latest signal came from London; The United Kingdom recently cancelled visa-free access for Saint Lucia, citing concerns about the integrity and oversight of Caribbean citizenship-by-investment programs. The decision sent shockwaves through the investment migration industry and reinforced warnings already issued by both Washington and Brussels regarding security risks associated with poorly vetted economic citizenship schemes. At the same time, a significant development is unfolding thousands of miles away in South America. Argentina is positioning itself as a new frontier for the global investment migration market.

Argentina’s Strategic Move; According to a recent report published by IMI Daily, the Argentine government has recommended awarding the master agent contract for its new citizenship-by-investment program to a consortium composed of Apex Capital Partners, AIM Global, Passport Legacy, and Arton Capital—four firms with deep experience in the global investment migration industry. These companies are not minor players. They have been central pillars of the Caribbean CBI ecosystem for years, marketing and distributing citizenship programs from jurisdictions such as Saint Kitts and Nevis, Dominica, Antigua and Barbuda, Grenada, and Saint Lucia.

Argentina’s evaluation process placed this consortium ahead of other bidders, including the well-known migration advisory firm Henley & Partners. The selected consortium will now help design, launch, promote, and operate Argentina’s new citizenship-by-investment framework, potentially processing up to 5,000 citizenship approvals under a multi-year contract. In essence, Argentina is preparing to enter a market long dominated by small Caribbean island states.

There has been a Shift in the Investment Migration Industry; The timing of this move is particularly striking. Caribbean CBI programs—once marketed as the gold standard of economic citizenship—have come under increasing pressure in recent years. The industry is seeking new jurisdictions, and with good reason, for the Eastern Caribbean programs have become infected with money laundering, fraud and corruption. Look for this focus away from the Caribbean, replacing it as the region of choice for economic passports, with clean programs, free of crime and corruption. 

WILL MALTA'S MOST CORRUPT PRIME MINISTER NOW BE UNABLE TO GET HIS MILLIONS IN BRIBES & KICKBACKS OUT OF DUBAI?

Mugshot by COSIMO

If you are following the fast-moving developments in wartime UAE, you know that the government, shocked at being on the receiving end of Iranian missiles, is in the process of considering how to block the expected massive capital flight out of Dubai, as high net worth individuals take assets from what they thought was a safe haven elsewhere. It will not just be Iranian capital that is blocked from exiting Dubai financial institutions, according to our sources in the Emirates.

Enter the former Prime Minister of the Republic of Malta , JOSEPH MUSCAT, once named as the European Union's most corrupt leader. Muscat alegedly has many millions of US Dollars and Euros, all received in bribes & kickbacks as well as stolen public funds , from his tenure as Maltese PM, in a major UAE bank, with Emirati royal connections. He is now said to be unable to withdraw any of them at this time.

As we understand that he only has a very small portion of his alleged criminal proceeds in Swiss bank accounts, he now has a major problem; will the UAE notify the government of Malta about his frozen illicit assets, and facilitate their seizure and forfeiture to the Maltese Treasury? We cannot say, but we will be watching.

WHAT IS IT ABOUT CBI AS "INHERENTLY HIGH RISK" THAT NOBODY WANTS TO ADMIT IN SAINT LUCIA?

After the United Kingdom changed its Immigration Rules this year (HC 1691, 5 March, 2026) to require Saint Lucia passport holders to obtain a visa to enter the UK, terminating the existing visa-free entry policy, it squarely placed the blame for this action upon the country's Citizenship by Investment (CIP) economic passport program, identifying it as "INHERENTLY HIGH RISK." That term is an existential threat to CBI all over the Eastern Caribbean.

As the plain meaning of that term is not open to honest debate, the Labour government of Saint Lucia is desperately attempting to spin the news into some sort of ficticious new cooperation, between it and the UK, hinting that its amazing diplomatic skills will, sooner or later, result in a reversal. If one looks at the two years since the UK slammed the visa-free door on the Commonwealth of Dominica, you know that, due to the corrupt CBI program, Saint Lucia will not see relief on visas so long as ERNEST HILAIRE, the most corrupt minister in PHILIP J PEIRRE's Cabinet, and in bed with China's CARIBBEAN GALAXY, remains in command of the CIU.

Minister for Investment Ernest Hilaire

Therefore, Saint Lucians, who gleefully reelected Labour recently, have made their bed, and now they must reap the consequences; no entry into the USA, *(a $15,000 bond if you can even get a visa),tight controls on entry into the UK, and the visa-free roof is about to fall in over in the staunchly anti-CBI European Union.

Add this to the Saint Lucia government's political alignment with the Peoples' Republic of China, autocratic Cuba, and what's left of Venezuela, all of which is strongly disapproved by the present United States administration, and Saint Lucians are facing a dark future, where their Citizenship by Investment piggy bank could be forced to close shop.

I understand that the presence of American warships off Saint Lucia's beaches, as well as a US attack on some of its "fishermen" allegedly smuggling cocaine, is making Saint Lucians nervous, as they should be, as storm clouds look to be on the horizon, and the US still has a number of nasty cards to play in its deck of surprises. Philip J Pierre has chosen Ernest Hilaire and Caribbean Galaxy over Saint Lucia.

WILL SENIOR SAINT LUCIA GOVERNMENT OFFICIALS, INCLUDING ITS PRIME MINISTER, BE NAMED AS FACILITATORS OF VENEZUELA'S MASSIVE COCAINE TRAFFICKING OPERATIONS, IN THE MADURO CASE?

                                            

There is speculation, in Caribbean media, that SAINT LUCIA, as well as its sitting Prime Minister, PHILIP PIERRE, will be ultimately identified in the cocaine trafficking case of former Venezuelan President NICOLAS MADURO MOROS, and others, after a specific allegation surfaced in the Superseding Indictment, regarding payments made for what was described as the "Caribbean Route."

The basis for the assertion is language that appears on page 9 of UNITED STATES vs. NICOLAS MADURO MOROS et al, Case No.: 11-CR-205 (SDNY), which has been attached to this article. Caribbean media has accused both the current and the former prime minister of Saint Lucia of allowing cocaine-laden aircraft, bound for the United States, to land at night at the country's international airport.

It is noteworthy to remember that the former premier of the British Virgin Islands, ANDREW FAHIE, now serving an eleven year sentence in the United States for facilitating drug trafficking and engaging in money laundering, is known to be cooperating with American law enforcement. Fahie has previously admitted that he has first-hand knowledge of criminal activities in support of cocaine trafficking, committed by other senior Caribbean government leaders. How many individuals has he implicated for receiving payments to assist the "Caribbean Route"?

Given the restrictions upon Discovery disclosure in Federal Court, we may not learn of the identities of the Caribbean officials until the trial. On the other hand, if another superseding indictment is handed down, naming Pierre and others, the truth will come out earlier.

I AM DEFINITELY OVERQUALIFIED FOR THIS POSITION

For over twenty five years, I have acted as the conscience of the Caribbean Citizenship by Investment (CBI) economic passport community, exposing the corruption, fraud and systemic money laundering, all caused by greed and avarice. If anyone is overqualified to be the gatekeeper for this industry, it is yours truly, but the position will most likely go to some former Caribbean banker with a dodgy background, but superb political connections.

The question is: how can you ask someone to be the lead regulator in an industry under existential threat in the region? It's like being on the last helicopter out of Saigon in 1975, as the North Vietnamese Army closes in fast.

WHICH ISLE OF MAN COMPANIES FACILITATED THE MOVEMENT OF THE AYATOLLAH'S BILLIONS? HERE ARE SOME OF THE POSSIBLE CANDIDATES

Consider this AI-generated list* from Google of IOM shell companies linked to Iran to be our starting point. You can add to it a certain British solicitor known to represent some of the players.

Meanwhile, down in Basseterre, the capital of SAINT KITTS & NEVIS, where the other shell companies used to facilitate the movement of Iran's billions abroad were formed, there's no comment from the ruling Labour Party, as the country's Prime Minister, TERRANCE DREW, jets around Africa, looking to establish new relationships with government officials there, to replace the now severely diminished CBI funding from dodgy sources with new capital, from jurisdictions with a high degree of corruption.

No, we have not as yet identified which Saint Kitts companies were employed by the Ayatollah's laundryman son, who is now the new Supreme Leader of Iran, but we are looking in it; stay tuned.

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* Trust, but verify, anything created by Artificial Intelligence.

HILAIRE, YOU WERE WARNED ! THE UNITED KINGDOM CANCELS VISA-FREE ENTRY FOR CITIZENS OF SAINT LUCIA, DUE TO NATIONAL SECURITY THREATS CAUSED BY ITS CITIZENSHIP BY INVESTMENT (CIP) PASSPORT PROGRAM

UK HOME SECRETARY MAHMOOD

The people of SAINT LUCIA woke up this week, to reap the whirlwind created when their Minister of Investment, ERNEST HILAIRE, disregarded advice and proceeded to bring Chinese-owned and controlled CARIBBEAN GALAXY GROUP on as the principal vendor of Citizenship by Investment (CIP) passports, resulting in then issuance of tens of thousands of passports to Chinese career criminals, intelligence agents involved in Industrial espionage, fraud and money laundering, as the UK has now terminated Saint Lucia's visa-free admission privileges. Visitors visas are now required, and Minister Hilaire is completely to blame for this sad state of affairs. Home Secretary SHABANA MAHMOOD delivered the announcement at a press conference

While the official grounds for the end of visa-free admission for Saint Lucians is said to be that their citizens, once in the UK, seek asylum in large numbers, in truth and in fact, the national security threats to the UK, caused by the corrupt CIP program, which is operating without any effective due diligence, has caused serious concerns in London. Those concerns are well taken.

Although the Saint Lucia Government, in a press statement responding to this news, attempted to minimise the problem, stating that it would be working with the UK "to better understand the decision and to explore pathways for maintaining strong mobility arrangements between both countries," this decision, like a similar one put in place two years ago, with respect to the dangers posed by Dominica's corrupt CBI program, is not being modified or withdrawn anytime soon.

Saint Lucians have only Hilaire to thank for this new UK action, which will usher in expensive and time-consuming arrangements to make application for visas, which were recently completely blocked to the US by the Department of State. International travel has just now become much more difficult and complicated for Saint Lucians, due to their inability to rein in their rogue passport sales program.After the United States action, placing Saint Lucia on the list of 75 countries paused for immigration, this is another serious blow for Prime Minister Philip J. Pierre, and Hilaire, and St. Lucians have Les Khan and Caribbean Galaxy to thank, along with Hilaire and PJP.

MY ARTICLE ON FINCEN IN LINKEDIN

HELLO FINCEN; THE SON OF IRAN'S SUPREME RULER, AYATOLLAH KHAMENEI, MOVED BILLIONS OF DOLLARS INTO TAX HAVEN BANKS, USING SAINT KITTS AND NEVIS SHELL CORPORATIONS

UK Media is on fire with the news that MOJTABA KHAMENEI, one of the sons of Iran's Supreme Ruler, AYATOLLAH KHAMENEI, laundered billions of dollars into tax haven banks in Switzerland, the United Arab Emirates (UAE) and Liechtenstein, using anonymous shell companies formed in SAINT KITTS AND NEVIS. This breaking news, coming on the heels of this week's disclosure that the American AML/CFT agency FINCEN just removed its 2014 Advisory and warning on Saint Kitts & Nevis, should be a wake up call for that agency. 

The fact that such a high profile Politically Exposed Person (PEP) as Mojtaba Khanenei would be allowed to obtain corporations in Saint Kitts affirms that both the country's Registry of Companies, and its financial service firms, will sell companies to the most dangerous individuals under global sanctions, confirming that the elevated risk of any financial transactions with Saint Kitts and Nevis companies, financial institutions, government agencies, lawyers or businesses must be avoided, lest exposure to terrorist financing, money laundering and international sanctions violations be charged to anyone who makes the fatal error of dealing with any entity or individual linked to that high-risk offshore jurisdiction.

Saint Kitts should now expect the full force of United States law enforcement agencies to come down hard on all these Kittitian entities, after this despicable information has come to light. American bankers who want to avoid being indicted with them had best pay heed to the probable consequences of doing business with St. Kitts banks.

We trust that the Director of FinCEN is paying attention.

SAINT KITTS REMAINS A CLEAR AND PRESENT DANGER TO U.S. FINANCIAL INSTITUTIONS, AND FINCEN'S DIRECTOR SHOULD RESIGN FOR REVOKING THE AGENCY'S ADVISORY ON SKN CITIZENSHIP BY INVESTMENT PASSPORTS

                                   

FinCEN Director Andrea Gacki

Who is in command at the Financial Crimes Enforcement Network ? Obviously, they are not paying attention to what goes out the door, because FinCEN recently cancelled its critical, eleven year old Advisory on Saint Kitts & Nevis Citizenship by Investment (CBI) passports. The fact that all the old SKN passports that were in force in 2014 are no longer valid is NOT a good reason to retreat from one of the most valuable moves the agency ever published, and which made Enhanced Due Diligence the order of the day for Saint Kitts transactions. And now you have removed that warning? If anything, St. Kitts CBI passports, now held by many thousand Chinese white collar criminals, spies and fraudsters, are more dangerous today than they were in 2014.

If ANDREA GACKI, the agency's director since 2013, cannot see the fundamental error of this action, then perhaps it is time for new leadership at FinCEN, someone who is understands the unintended consequences of the removal of Advisories. She used to be the Director of OFAC, and most certainly is aware of the rampant fraud, money laundering and corruption that have fatally infected Saint Kitts & Nevis.

If I was a compliance director at a major American financial institution, I would advise my frontline staff to treat Saint Kitts & Nevis transactions as if the Advisory was still in force. FinCEN, if you are not part of the AML/CFT solution, you are part of the problem.

IS THE UNITED STATES NOW CONTEMPLATING THE EXTRADITION OF ALEX SAAB MORAN ONE MORE TIME?

I have noticed some major interest* in ALEX NAIN SAAB MORAN of late, on the part of law enforcement, meaning that my 2022 article, READ THE NAMES OF THE OTHER ALEX SAAB MORAN FAMILY MEMBERS INDICTED IN ITALY FOR MONEY LAUNDERING https://lnkd.in/eWUKqWYG has been the subject of intense interest, from ISPs known to be favorites of law enforcement and our intelligence services, are suddenly being read, four years later.

Remember, the dismissal of Saab's Federal indictment, when he was exchanged in a prisoner swap with Venezuela, was WITHOUT PREJUDICE, meaning that it can be filed again, so long as the Statute of Limitations has not run. Is he truly in custody in Caracas, as has been rumored, and will be be turned over the United States, as part of some murky DOJ deal**? We cannot say, but we will be watching.

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* THIS PARAGRAPH IN PARTICULAR?

For those readers who wanted the names of the Italian family members of Colombian money launderer ALEX NAIN SAAB MORAN (accused of laundering €350m by US) who were indicted in Rome, on multiple money laundering counts, along with Saab, and his wife, CAMILLA FABRI, they are:

(1) LORENZO ANTONELLI, the husband of Camilla's sister, BEATRICE ANTONELLI.

(2) ARIANNA FIORE, Camilla's aunt.

(3) PATRIZIA FIORE, another of Camilla's aunts.

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** READ THE FINE PRINT"