BMPE+TBML=MONEY LAUNDERING THROUGH FAST FASHION

If you were wondering why US law enforcement pulled off a major raid of Los Angeles-area clothing wholesalers last year, here's why. FAST FASHION, the sale of cheap copies of the latest fashion trends, manufactured quickly in Mexico, and sold to hungry young American consumers, is a cash cow for retailers. The fact that its manufacture is also an environmental nightmare appears to be irrelevant to all the participants involved, but compliance officers in Los Angeles know that it is a clear and present danger to their banks.

The fast-moving pace of transactions between American fashion houses and Mexican clothing manufacturers, acting to capitalize on short-term fashion trends, masks the illicit movement of narco-profits earned in the US to Mexico, where it is eventually delivered to the cartels converted to Peso form, thereby evading Mexican restrictions on the conversion of US Dollars into local currency. Some experts refer to it as a variation on the Black Market Peso Exchange well all know, but with a twist; there's no retailer at the southern end needing greenbacks to buy US goods. the transactions appear to simply be American company payments to Mexican factories for fast fashion. Piggy-backing additional Dollars to wire transfers, and then diverting the difference to Cartel financiers smack of Trade Based Money Laundering, so I must call it an amalgam of both BMPE and TBMl to be accurate.

If you are a compliance officer at ANY American financial institution whose clients purchase goods from Mexico, you will want to check to see whether the funds headed south, through your bank, are in excess of the purchase price of the goods being bought. You should expect that it's not only fashion companies that are pulling this trick. Watch for it.

DEBRA GEISTER GOT IT RIGHT; MONEY LAUNDERING IS INDEED A TESSERACT

Deb's recent statement, that money laundering techniques have indeed expanded beyond the traditional three-step diagram, is spot on. Indeed, the only way one can now describe it is to liken it to a TESSERACT, a representation of a four-dimensional cube, to approach what is a complex operation with many facets, some of which are designed to confuse and mislead, and others set to allow the user to arrive at his or her destination successfully, without being caught by either vigilant compliance officers, or law enforcement. A conundrum without a solution.

Speaking Truth to Power.

Perhaps we need to take a whole new approach to AML/CFT, as what we are doing now is akin to people living and working in a two dimensional system, while the laundrymen are operating in three- and four dimensions. There are multiple AML perspectives pushing back against mysteries that are often on a much higher plane. Almost forty years after the passage of the Money Laundering Control Act, compliance officers are still playing catch-up with their opponents. When will next generation technology finally level the playing field, as we cannot outthink the money launderers, who are constantly adapting and improvising in real-time, while compliance plods along, fighting last year's war this year. Compliance is playing checkers, on the laundrymen's chessboard. Who will invent the perfect AML platform, and when?

THE UK MUST NOW TAKE OFF THE GLOVES AND IMPOSE AN ORDER IN COUNCIL UPON THE THE ROGUE BVI, FOR ITS REPEATED REFUSAL TO DISCLOSE BENEFICIAL OWNERSHIP

If you are like me, when you see a British Virgin Islands-registered company, you immediately, and correctly, assume the worst: money laundering, tax evasion at home, fraud, or even possible terrorist financing. That's because of the damn stubborn insistence of BVI authorities to open their corporation database to public inquiry. All the possible scenarios, ostensibly compromises, that the BVI has offered the UK on BOI allow bad actors to escape identification, move their illicit assets, or otherwise evade justice and accountability. This must stop, forthwith.

I personally regard the place as a Den of Legal Vipers, having flown into Road Town many times in my misspent youth to pick up multiple SHELF COMPANIES on the fly, for my narco-clients. It must now be the subject of an ORDER IN COUNCIL, which for the non-lawyers is an effective Royal statutory instrument, rarely used against British Overseas Territories, but sorely needed here, to clean up this legal obscenity which has facilitated financial crime for far too long.

There's a reason Mossack & Fonseca preferred BVI companies to their own Panamanian: total and absolute opacity. This needs to end, right now. The question is whether the British Government has the intestinal fortitude to issue one. I have my doubts, ladies & gentlemen; prove me wrong.

BELGIUM-BASED HIND RAJAB FOUNDATION SUPPORTS HAMAS AND HEZBOLLAH

Here is the latest special report on the organization,  dated January 2025:

https://www.gov.il/en/pages/special_report_hrf_foundation_2025-01

NEW DOJ POLICY ON THE FOREIGN AGENTS REGISTRATION ACT WILL RESULT IN FEW PROSECUTIONS

If you read the fine print in yesterday's GENERAL POLICY REGARDING CHARGING, PLEA NEGOTIATIONS AND SENTENCING, you now know that FARA prosecutions will only occur when there's an actual element of espionage involved. the vast majority of Foreign Agents Registration Act cases during the past decade definitely do NOT involve the gathering of intelligence, espionage or anything close to spying.

What the new AG memorandum will accomplish we cannot say, but you can forget about seeing new FARA indictments, in my humble opinion. Of course, the political aspect of declining to charge American businessmen with FARA violations, when they neglect to file, one cannot ignore, Take a close look at who has been charged in recent years, if you miss my meaning.

IN LIGHT OF RECENT DEVELOPMENTS AT DOJ, YOU MAY WANT TO READ THIS ARTICLE FROM 2020, AS MANY HAVE CHOSEN TO ACCESS IT THIS WEEK

I was asking a lot of questions about the outcome of UNITED STATES vs. ALI SADR HASHEMINEJAD back then; it bothered me at that time, and remains a mystery today to most legal observers.

https://rijock.blogspot.com/2020/06/the-us-attorney-working-behind-scenes.html

SOUTH AFRICAN BANKS FACE UNIQUE TERRORIST FINANCING THREATS

If you happen to be a compliance professional in South Africa, responsible for AML/CFT, you should be aware that your country's banks, as well as nonbank financial institutions (NBFI) face terrorist financing threats on a level higher than those that exist elsewhere. The fact is, a number of specially designated global terrorist entities, as well as entities that feed funding to those internationally-sanctioned organizations, are not sanctioned or prohibited there. In truth and in fact, some are tolerated or even welcomed for political or social reasons.

Given that financial institutions function on a global scale, when they even unwittingly conduct transactions which facilitate terrorist organizations, even indirectly, they risk consequences from those Western countries that maintain sanctions against them. These include taking action against local branches or subsidiaries located abroad, regulatory action imposing civil fines and penalties upon such entities abroad, up to and including the complete blocking of access to critical financial centers or currencies in the most serious cases. This could occur, even though there are no existing legal obstacles to processing such financial transactions within South Africa.

It is incumbent upon compliance officers working in South Africa to be aware of the specific entities which could damage their bank or their clients, in the event that regulatory agencies abroad determine that terrorist financing impacting their national interest, occurred or originated within the South African financial community. As this information is obviously of a sensitive nature, and not generally suitable for publication, it will be detailed at the upcoming TITC seminar "UNMASKING AFRICA'S FINANCIAL UNDERWORLD," on February 19 and 20. You are urged to attend this important event, as an important component of your responsibilities to counter the financing of terrorism, and to reduce your level of risk.

For further information:

https://titc.io/kenneth-rijock-webinar-africa-special

PLANNING ON MOVING TO YOUR NEW ECONOMIC PASSPORT COUNTRY IN THE FUTURE? YOU HAD BETTER HIRE ARMED SECURITY TO PREVENT YOUR POSSIBLE MURDER IN THE STREET WHILE SHOPPING

One of the primary reasons offered up by the "Investment Migration" or economic passport consultancies is the availability of your new country as a potential place for you to reside, especially if increased taxes, political instability, war, or even natural disasters, occur in your home country. Consider this a blunt warning, if you are considering moving your family to any of the five East Caribbean states that offer CBI/CIP programs, because in many cases, it's just plain dangerous to live there, due to increased crime, especially homicides, taking place there.

The current homicide rate in the United States, per 100,000 people is 6.3; in the UK it is 9.7. If you choose to relocate to SAINT KITTS, or to SAINT LUCIA, the two most popular CBI choices pushed lately by the largest passport vendors in Dubai, the rate is ten times those figures. Additionally, homicide rates in those two island nations has spiked even more in the last year and a half. If you thought Haiti was dangerous, look at the statistics for the East Caribbean states. Read the local newspapers of St. Kitts & St. Lucia online if you don't believe me.

You and your family might be in the local market, when a pair of the local chronically unemployed youth involved in drug trafficking choose to resolve their territorial disputes in the street, and you become collateral damage. In other countries, you might have survived due to prompt and effective medical attention, but here in the East Caribbean there's no ambulance speeding to your rescue, and you die on the scene. What will your family do now? They are far from home, without your guidance and support.

Please, ignore that drivel coming from the passport sales consultancies,a and DO NOT consider relocating to that sunny Caribbean isle. There is an undercurrent of danger there which your passport salesman will not tell you about, and I can tell you from personal experience that wearing a bulletproof vest in the tropics is not something you want to do by choice.

CAREER CHINESE MONEY LAUNDERER CONVICTED IN BILLION DOLLAR SINGAPORE SCANDAL ARRESTED ON NEW CHARGES UPON ARRIVAL IN EUROPE

WANG SHUIMING, one of the major Chinese organized crime players in Singapore's largest money laundering scandal, and who served a thirteen month sentence and was thereafter deported in Japan, has been arrested in Montenegro, when he arrived there on a private plane. Details have not been released, but it is known that he had passports from three different countries other than China in his possession. It was reported that he was coming from the Maldives, and that he was arrested due to an INTERPOL Red Notice; What jurisdiction issued the arrest warrant is not known.

I find it interesting that he chose to enter Europe outside the EU; it looks just another career money launderer, plying his dark trade in another part of the world, caught in the act. He is the Poster Child for all that is wrong with Singapore's extremely lenient money laundering sentencing policies. Sentencing is supposed to represent not only a deterrent for others, but to incapacitate the offender for a sufficient period of time, out of circulation. Singapore sinly want to deport these offenders forthwith, but in doing so they unleash them on the rest of the financial system.

BTW Wang's alias is VANG SHUIMING; his CBI passports were from TURKEY, VANUATU and CAMBODIA, when arrested in Singapore. He still had the Vanuatu passport when taken into custody in Montenegro.

CREATING A GOVERNMENT AGENCY TO REVIEW ALL ACCOUNT CLOSURES BY SOUTH AFRICA'S BANKS COULD INTERFERE WITH COMPLIANCE OFFICERS' AML/CFT EFFECTIVENESS; CAN IT BE DONE?

The ongoing discussion over whether the closing of customer accounts by financial institutions in South Africa, including the concept of legislation in Parliament creating a government agency to pass on such decisions, would take away an important compliance function: the ability to immediately shut down accounts when Transaction Monitoring determines suspicious or illegal activity. While we understand that there may be political reasons why politicians are speaking out about in support of such an action, prudence demands that a hard look at the potential adverse effect having such an entity will have on the suppression of money laundering and the financing of terrorism.

Such an entity might unnecessarily delay the closure of accounts, meaning that criminal activity could continue unabated, while a tedious review is conducted. It would have to (1) be staffed with individuals experienced in the compliance function, and (2) Be swift in making its decisions on whether account closures were appropriate, and South African government agencies are not known for their speed. Someone will, of course, now being up some sort of administrative appeal process, which could also delay action that is judged by ban to be of immediate resolution.

We call upon the Banking Association of South Africa (BASA) to assist Parliament in reaching a fair and equitable, and above all, effective, solution. Please don't tie the hands of compliance officers in the exercise of their duties. if there must be a government agency passing on their decisions, make sure it works quickly and correctly.

_______________________________________

For more information on South Africa Financial Crime:

https://titc.io/kenneth-rijock-webinar-africa-special

HERE ARE THE TOP FINANCIERS OF HAMAS - UP TO TEN MILLION DOLLAR REWARD FOR INFORMATION FROM U.S. DEPARTMENT OF STATE DIPLOMATIC SECURITY SERVICE Activate to view larger image,

 

BUYING MORE THAN ONE ECONOMIC CITIZENSHIP? LET THE BUYER BEWARE; YOU MAY NOT LIKE THE CONSEQUENCES

We noticed recently an opinion, rendered by a Citizenship by Investment (CBI or CIP) consultancy, advising prospective purchasers of a second passport that circumstances within the country whose passport you spend a large amount of money on may change in the future, perhaps decreasing its attractiveness, or the number of visa-free jurisdictions it allows you to enter. It then tacitly suggested that, to hedge your bets, you secure more than one citizenship, complete with passport, to reduce the risk that untoward events in the near future may lessen the worth and value of the sole passport you acquired.

The article cautioned buyers to be aware that a number of the countries that are advertised as your best choice, because of the large number of visa-free or visa-upon-arrival jurisdictions you may access, may not be such a great deal, because a substantial number that allow trouble-free visits do NOT allow permanent residency and /or the right to work or be employed, or to make certain investments. Therefore, some may not be such a great deal after all.

My own personal reservations regarding the possession of multiple second citizenships is that many of the world's most notorious transnational white collar criminals, and spies, are often arrested with several of these valuable identity documents on their person, generally with different names, date & places of birth cleverly inscribed by corrupt CIU officials. Do you really want to be targeted by some foreign law enforcement agency as a potential career criminal or worse?

Additionally, the more second citizenships you acquire, the greater the chances that one or more of those countries is a former (or current) offshore tax haven, where dirty money is accepted, making you even more of a possible target.

Therefore, kindly resist the consulting firm's advise that you load up on a couple Caribbean, European or Pacific passports, to minimize risk, for you may end up buying a problam from which you cannot easily or quickly escape or evade in your global travels.