WILL PROPOSED BVI RESIDENCY BY INVESTMENT BECOME THE NEW BACKDOOR METHOD FOR WHITE-COLLAR CRIMINALS TO ENTER THE UK?

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.

MORE DETAILS EMERGE REGARDING PERSONAL MISCONDUCT OF ITS OWNER IN CENTRAL BANK TAKEOVER OF SAINT LUCIA NBFI FINANCIAL INVESTMENT AND CONSULTANCY SERVICES

Lorne Theophilus 

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.

RAMPANT REAL ESTATE FRAUD CONTINUES IN SAINT LUCIA, AND THE COUNTRY'S PRIME MINISTER, FINANCIALLY BENEFITING FROM THE ILLEGAL SCHEME, BLOCKS NECESSARY REFORM

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.

COMPLIANCE OFFICERS: IGNORE MISLEADING AND INACCURATE INFORMATION ON CBI DUE DILIGENCE APPEARING ON INVESTMENT MIGRATION MEDIA WEBSITES

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:
(1) Articles about arrests and convictions of passport holders.
(2) Information regarding what entity is actually processing due diligence and its track record.
(3) Litigation and news about claims by applicants, information regarding CIU misconduct or negligence, and news about correspondent accounts being restricted or closed, due to concerns that applicants are not being properly investigated.

The last place you should be looking for accurate and complete information is CBI industry media, which is rife with Conflict of Interest, and disinformation which is intended to lull investors into a false sense of security regarding supposedly effective and professional due diligence programs, professed to weed out unsuitable and dangerous applicants. CBI jurisdictions intentionally pass bad actors; their due diligence is a sick joke being played on investors. Ignore those glossy articles, please, when conducting your own inquiries.

For Further Reading:

CONFLICT OF INTEREST IN CBI INDUSTRY ONLINE PUBLICATIONS RESULTS IN THEIR FAILURE TO DISCLOSE THE INHERENT RISKS TO INVESTORS OF SECOND PASSPORT PURCHASES

CHRISTIAN NESHEIM, PRESIDENT OF LEADING CBI INDUSTRY PUBLICATION, DISMISSES GALAXY'S ILLEGALLY-DISCOUNTED PASSPORT SALES, STATES EVERYBODY BENEFITTED FROM THE 'SCAM"

BILLION DOLLAR 1MDB LAWSUIT CHARGES BARBADOS BANK WITH USING OPAQUE BVI SHELL COMPANIES TO COMMIT MASSIVE FRAUD

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.

CONFLICT OF INTEREST IN CBI INDUSTRY ONLINE PUBLICATIONS RESULTS IN THEIR FAILURE TO DISCLOSE THE INHERENT RISKS TO INVESTORS OF SECOND PASSPORT PURCHASES

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:

ANGRY COMMENTS FROM PROFESSIONALS TO THE DISCLOSURES WE REPORTED REGARDING THE CHRISTIAN NESHEIM STATEMENTS ON THE ILLEGALLY-DISCOUNTED CBI SCHEME OF CARIBBEAN GALAXY AND SOLD BY LATITUDE/RIF TRUST

CHRISTIAN NESHEIM, PRESIDENT OF LEADING CBI INDUSTRY PUBLICATION, DISMISSES GALAXY'S ILLEGALLY-DISCOUNTED PASSPORT SALES, STATES EVERYBODY BENEFITTED FROM THE 'SCAM"

BANK HIT WITH TWENTY MILLION DOLLAR PENALTY FOR MASSIVE, APPARENTLY INTENTIONAL AML FAILURES, SUES THE FDIC

CBW BANK, a state chartered bank in Kansas, which the FDIC asserts ran an "illusory AML/CFT program," resulting in a civil money penalty of $20,448,000m has filed an action against the Federal Deposit Insurance Corporation, seeking a jury trial, on Constitutional grounds, and seeking a Preliminary Injunction The bank allegedly took millions in suspicious cash from Mexican banks, which it then wired back to them, and moved $27bn overseas, to such high-risk jurisdictions such as Lebanon and Cyprus. Frankly, I am wondering why its bank executives, as well as compliance officers, have not been charged with money laundering yet.

In my humble opinion, the case has not legal merit; FDIC counsel artfully noted in their Motion to Dismiss, which is pending:
(1) The FDIC action is a administrative proceeding, and there is no statutory right to trial by jury. In fact, there is no subject matter jurisdiction, and the Complaint fails to state a claim upon which relief may be granted.
(2) There was insufficient showing to justify a preliminary injunction, and the bank would have post a $20m bond
(3) The case law does not favor such an action.

This looks like a Hail Mary, perhaps filed to seek to negotiate a modification of what must appear to be a fatal blow to a $90m bank, but it is hard to see how the civil suit will survive the motion to dismiss The real question is how bank staff, which clearly ran an operation designed to launder the cash proceeds of criminal activity, have not been indicted.

EASTERN CARIBBEAN CENTRAL BANK POSTS ADMINISTRATOR TO RUN SAINT LUCIA FICS; FINANCIAL MISCONDUCT OR LINKS TO CIP?

In a recent public announcement, the Eastern Caribbean Central Bank (ECCB), the financial regulator for the region, has named NIGUEL STREETE, a career financial professional, as Official Administrator of FINANCIAL INVESTMENT AND CONSULTANCY SERVICES, of Saint Lucia. FICS is a family-owned non-bank financial institution (NBFI) that serves the Saint Lucia public, and has been under the control of the Theophilus family since its formation in 1992.

While the ECCB, unlike American regulators, has been accused of being non-transparent and opaque in it operation, this action on its part would not have been authorized by its leadership unless there was a serious reason, or financial misconduct, and risk to its depositors is the primary reason the ECCB would take such radical action. The current ownership of the FICS is believed to be held by LORNE THEOPHILUS, a lawyer who has served as the head of the country's Citizenship by investment Board (CIU), and who has come under fire for the CIP's close relationship with passport vendor CARIBBEAN GALAXY GROUP, amid allegations of fraud, money laundering and corruption. 

Although his current status at the CIU remains a mystery, his supervision of the agency, alleged role in corruption, and potential exposure to criminal charges, may be the reason the ECCB has inserted an outside administrator at FICS. We plan on initiating a further investigation into FICS finances, and will report back to our readers forthwith.

CONFESSIONS OF A SAINT KITTS MONEY LAUNDERER

Interest in the period when money laundering thrived in the Caribbean has increased of late, and I have received a number of inquiries seeking information about events in Saint Kitts & Nevis during that period. While government leaders there apparently have gone to great pains to suppress the local publication of articles about the long money laundering career of the country's late Ambassador Plenipoteniary William (Billy) Herbert, Jr., and his partners in financial crime during that period, the story needs to be told, so that this type of financial misconduct doesn't ever happen again in Basseterre.

Beginning on January 20, I am presenting a three part, three hour virtual lecture on Advanced Money Laundering Techniques, during which I illustrate methods used through actual case histories, many of which involve Caribbean offshore financial centers, including Saint Kitts & Nevis. Readers who want to learn the unvarnished truth about the conduct of money laundering in Saint Kitts & Nevis, and elsewhere in the Caribbean, during the wide-open nineteen eighties, and who was involved, are cordially invited to attend this hard-hitting, no holds barred seminar.

For details; KENNETH RIJOCK-The Laundry Man

https://titc.io/kenneth-rijock-the-laundry-man

IRANIAN SANCTIONS EVADERS AND PEPS USING CARIBBEAN CBI PROGRAMS TO OBTAIN MORE VALUABLE EUROPEAN CBI PASSPORTS

There's a report out that asserts prominent Iranian oil traders, who also happen to be PEPs, are employing a two-step tango to deceive European oil buyers; they first obtain a CBI passport in the Commonwealth of Dominica, and use that piece of identification to acquire a IIM (CBI) passport from Malta, and use that ID to trade sanctioned Iranian oil disguised as originating in non-sanctioned jurisdictions.

While some of our readers protest too much that one cannot get a new name and new country of birth placed upon your new Dominica CBI passport, I remind them that, for the right price, Roosevelt's Skerrit's Labour government will issue you anything you desire, provided your request is supported by USD$100 notes. Case in point: Chinese money launderer who obtained a Dominica CBI passport, then engaged in billion dollar money laundering operation in Singapore. ultimately deported to Cambodia, for Dominica wasn't about to accept her.

EVOLVING MARKETPLACE CONDITIONS INCREASE THE RISK THAT COMPLIANCE OFFICERS PERFORMING TRANSACTION MONITORING WILL SEE MORE MONEY LAUNDERING THROUGH LIFE SETTLEMENTS

As complex market forces force smaller and independent firms selling Life Settlements to investors out of business, the giants in the industry gobble up the inventories of their former competitors. Inasmuch as there are no regulations requiring that Life Settlement companies maintain an effective AML/CFT program, the odds that enterprising money launderers were in the past able to embed their criminal clients into a significant number of investments at the now-defunct little companies, is significant.

When those investments are sold by failing Life Settlement firms to the bigger players in the industry, there is no compliance done on the existing investors, and when the investments mature ( the insured on those large policies pass away), and the insurance carrier which issued the policies pay off what can be millions of dollars, the Proceeds of Crime are artfully cleaned and laundered.

I bring this up, as most compliance officers accept eight-figure payments from the world's largest life insurance companies without any further inquiry, believing, in error, that sufficient due diligence was previously completed, when in truth and in fact, only the original beneficiary was vetted, not the successor, which was precisely where the money launderer was able to work his magic, in the secondary market for life insurance that is the Life Settlement industry.

If you do not have a thorough understanding of Money Laundering through Life Settlements, you might want to seriously consider attending my upcoming January 20th virtual seminar on advanced, esoteric and obscure money laundering techniques. You can obtain details here:

https://titc.io/kenneth-rijock-the-laundry-man