A WARNING REGARDING THE USE OF AI BY COMPLIANCE OFFICERS CONDUCTING ENHANCED DUE DILIGENCE FOR ONBOARDING

We have written a number of articles, covering the hard position that the American judiciary has taken, in disciplining attorneys who filed briefs that contain bogus or fabricated citations to legal authorities, meaning case law, and secondary legal references. Lawyers have drawn as much as $10,000 fines for their carelessness, irrespective of the reason they allow AI research to creep into their court filings.

Compliance officers, as we have seen, have been supplementing their due diligence and enhanced due diligence queries with AI searches, and using the results tom decide on whether to approve (onboard) new bank clients, and some are not taking the additional, and necessary, step of actually verifying what the AI program has told them about their new customer.

Here's why this is risky, from a professional ( malpractice/negligence) viewpoint. Unlike lawyers, whose legal citation are often reviewed for accuracy by opposing counsel, and the presiding judge, A-vetted compliance decisions simply go into a file, and generally are never seen by anyone else. They do, however, surface when the customer is later found to be laundering money through his accounts, or is indicted, and a subpoena finds its way into the bank. of course it is far too late at that point to fix the error. If you don't check your AI-generated results in compliance, they may come back to haunt you.

One final and important point as to why you should be concerned; some open AI is continually learning from the data fed into it, and if a prior user input, or generated, bogus data on your target, you may very well receive that false information in your subsequent query. Are you sure you are using a Closed AI program? And what about security flaws possibly present in Open AI? you may have unwittingly further increased your chance of picking up erroneous results.

Bottom line, check everything that AI gives you back, Mr. or Ms. compliance officer.

WE GO INSIDE ANTIGUA'S MASSIVE ALFA NERO/WEST INDIES OIL COMPANY SCANDAL IN DETAIL; WHERE DID ALL THE MISSING MILLIONS GO?

Due to the massive international reader interest in the ALFA NERO scandal, its relationship to the WEST INDIES OIL COMPANY, and the alleged criminal participation of a rogues gallery of senior Antiguan government officials, and their immediate family members, we have deemed that portion of the letter to the United States Attorney  General so important for the people of Antigua that it deserves to be reprinted here in full, in advance of the upcoming national election.

 Only if the voters are fully informed, regarding the full extent of the systemic corruption, and the fact that many millions are missing, and believed to have ended up in the personal pockets of Prime Minister GASTON BROWNE, and his family, can educated voters make an informed choice st election time. The truth about the funneling of millions int0 the hands of senior members of the Antigua and Barbuda Labour Party we believe completely disqualifies it for reelection. Read it, and decide for yourself. We have taken the relevant portions verbatim from the document; they appear below:

AMERICAN NGO IN WASHINGTON ASKS U.S. ATTORNEY GENERAL TO OPEN A CRIMINAL INVESTIGATION INTO SYSTEMIC CORRUPTION, FRAUD AND MONEY LAUNDERING OF ANTIGUA'S LEADERS, FOCUSING ON CIP

The CARIBBEAN ANTICORRUPTION ASSOCIATION, a U.S-based NGO, has sent a twelve page white paper to TODD BLANCHE, the American Attorney General, detailing what it calls systemic corruption, fraud and money laundering, on the part of the elected leaders of ANTIGUA AND BARBUDA, and their allies in the Labour Party, and in the private sector, demanding an immediate investigation into Federal crimes that the targets have committed against the United States, especially regarding the country's CITIZENSHIP BY INVESTMENT (CIP) Passport sales program, as well as several other financial scandals.

Compliance officers at financial institutions with international clients should note well the attached list of targets implicated by the NGO for criminal activity, and immediately determine whether any are currently, or have been in the past, bank customers, counterparties, or recipients of wire transfers, and take the appropriate action, if any are found. American banks, who are charged with operating a RISK-BASED AML COMPLIANCE PROGRAM, should note that the white paper has concluded that the individuals named constitute a NATIONAL SECURITY RISK and are HOSTILE TO THE UNITED STATES, which preclude any financial transactions.

Any reader who wishes to review the complete text of the letter ,please email me at miamicompliance@gmail.com

HENGSHENG CBI SCANDAL IN GRENADA THREATENS THE PROGRAMS OF ALL FIVE CITIZENSHIP BY INVESTMENT CARIBBEAN STATES

Reports this week of efforts to arrest a senior executive at the Chinese-owned CBI passport consultancy HENGSHENG SINGAPORE PTE. have resulted in his flight to China, the arrest within China of a second senior HS officer on money laundering charges, and related news that indicates the company, which sustained a $400,000 judgement against it in the UAE, forcing it to operate under another name, will soon be shuttered, with its staff scattering to avoid arrest on a variety of charges. HS is the principal CBI vendor of Grenada economic passports. 

 What this scandal will do to an already beleaguered Caribbean economic citizenship industry cannot be underestimated. The CIP program in Antigua and Barbuda, which has an upcoming national election on April 30, and which resulted in the enactment of extremely onerous U.S. visa conditions on Antiguan citizens, could now result in even more restrictions, which could threaten the local economy. Antigua is closely linked to the Peoples' Republic of China, like Grenada, and both could suffer additional American actions, which are seen in the Caribbean as punitive in nature, but which all relate back to CIP corruption, and the China connection. 

 We cannot say what the extent of additional American restrictions will be, as the direct result of the HS scandal, Antigua, St. Kitts and St. Lucia, all of whom have a major China factor in their CIP programs, could shortly become the subject of additional restrictions as an additional manifestation of America's 2026 foreign policy towards China in the Caribbean.

ANTIGUA'S ATTORNEY GENERAL BLOCKED VICTIMS OF MALPRACTICE FROM BRINGING CLAIMS AGAINST DOCTOR CONNECTED TO LABOUR PARTY

Antigua "medical tourism" physician, Doctor JOSEPH "JOEY" JOHN, whom we have recently revealed is part of a dodgy Antigua and Barbuda Labour Party scheme to install him as the country's Governor-General, a position which some legal experts note confers immunity from criminal prosecution under British law, is also being illegally protected from his many victims by the Antiguan Attorney General, STEADROY BENJAMIN. John''s partner, SANJA ILLIC, recently pled guilty in the United States, to concealing death at John's Antigua clinic.

The AG has blocked civil suits for medical malpractice, for a doctor that also allegedly conducted experimental cancer treatments. Benjamin's action is not based on any proper legal grounds, but because the doctor is associated with sitting Antigua Prime Minister GASTON BROWNE's Labour Party, of which Steadroy is also a longtime member. We find Steadroy also involved in a number of other questionable matters, the totality of which many Antiguans feel render him unfit to continue to serve in the country's Parliament: (1) He has a criminal conviction for passport fraud. (2) He totally ignored efforts by the trust that owns the luxury yacht ALFA NERO to settle the matter, while assisting in what is allefged to be an illegal sale of the vessel by the Government of Antigua. (3) As the Deputy Prime Minister, in the absence of GASTON BROWNE, he ordered police to fire rubber bullets at children and elderly citizens engaged in peaceful protests. (4) He is allegedly involved in corruption efforts surrounding the proposed new prison project.

With a snap election, called by PM Browne, coming up on April 30, Antiguans are anticipating his probable indictment in the United States, should he lose his Parliamentary seat.

WHICH CARIBBEAN LEADERS LOST THEIR AMERICAN DIPLOMATIC VISA PRIVILEGES THIS WEEK?

 

Saint Lucia Minister for Investment ERNEST HILAIRE

Legal experts who cover the Caribbean have been digesting this week's news that twenty six Caribbean government leaders have has their diplomatic visas to enter the United States terminated with prejudice, and they are seeking to determine which individuals are included in that American decision. Multiple media outlets, including those from outside the United States, has broken that story, giving the information a presumption of accuracy and correctness.

Antigua Prime Minister GASTON BROWNE

We know that, as a matter of policy the U.S. Department of State does not release the names of those who they choose to cancel their diplomatic visa privileges, but considering that it is known the reasons believed to be behind this U.S. action include their participation in corrupt Citizenship by Investment (CBI/CIP) economic passport sales programs, especially those which involve Chinese corporate entities or influence, which impacts American national security.

St. Kitts & Nevis Prime Minister TERRANCE DRE

Therefore, based upon our 40+ years of experience in the coverage of the economic citizenship industry, as well as personal involvement with the first CBI program, in Saint Kitts & Nevis in 1983, we have made an educated guess, regarding who are the most likely candidates for American visa termination, based upon their known connection to CBI corruption, fraud and money laundering.We admit that while this is only an estimate, it was taken from the allegations of criminal activity implicating those leaders during the past decade or more. 

Dominica Prime Minister ROOSEVELT SKERRIT

We shall be monitoring the travel schedules of the individuals who appear here, to determine whether their visits to the United States have now come to a halt, to confirm our conclusions. Stay tuned.

Grenada PM DICKON MITCHEL

LABOUR GOVERNMENT OF ANTIGUA PLANS TO IMMUNIZE ONE OF ITS OWN, WHO FACES EXTENSIVE LITIGATION IN THE UNITED STATES FOR NEGLIGENCE IN MEDICAL TOURISM

Doctor Joseph "Joey" John

A scheme, by the sitting Labour Party of ANTIGUA AND BARBUDA, to place one of its own, local physician DOCTOR JOSEPH JOHN, in office after the upcoming national elections, as GOVERNOR-GENERAL, has become public knowledge. Johns, who is engaged in dodgy Medical Tourism in Antigua, is reportedly the subject of extensive civil litigation in courts in the United States, alleging professional negligence. His experimental cancer treatment program has come under attack by the medical establishment, and resulted in claims by his patients in American courts.

The obvious aim of the Labour plan is to immunize Doctor John, who as Governor-General will become immune under Antiguan law for any criminal charges, which are believed to be pending and threatened against him at this time. Should the Labour Party, which has been under attack for corruption and money laundering, Doctor John would most likely face criminal prosecution; he is a known Antigua and Barbuda Labour Party member. His controversial Antiguan knighthood, in the face of fraud allegations, has also drawn critics.

Doctor John was appointed AMBASSADOR AT LARGE and Advisor to Antigua Prime Minister GASTON BROWNE a decade ago, as part of Browne's policy of doling out diplomatic passports to members of the Labour Party who do not discharge actual responsibilities as working diplomats, but who then can engage in international travel without have their baggage and documents examined by customs officers. Exactly what governmental advisor benefits a private physician can deliver to the Government of Antigua has always been a question, as have a large number of diplomatic passports given to private businessmen in Antigua, and the facilitation of corruption has long been suspected as the true reason for this widespread practice.

REPORTS CLAIM U.S. DEPARTMENT OF STATE HAS ANNOUNCED PLANS TO RESCIND THE DIPLOMATIC VISAS, AND ALL TRAVEL PRIVILEGES, FOR 26 SENIOR CARIBBEAN GOVERNMENT LEADERS.

Antigua PM GASTON BROWNE

This information, which came after details appeared recently claiming that Antigua and Barbuda's Prime Minister GASTON BROWNE has had all his visa privileges to enter the United States revoked, was seen multiple times on social media. The grounds were said to be that the individuals named threatened the security and prosperity of the United States. Reuters has confirmed this story.

In what must be considered an extension of the current American visa restriction policy, a denial of the ability of those named to "own or control critical assets" was mentioned. Whether this means that sanctions will be imposed by the Office of Foreign Assets Control (OFAC), or some other American regulatory or law enforcement action, we cannot say.

The report included specific information regarding individuals who hold office in Antigua; it stated that a half dozen Antiguan officials, as well as a senior local businessman are included on the list of names of those whose visas will be terminated. We shall make every effort to verify the names, but wish to point out that the United States, as a matter of policy does not confirm single cases where it has revoked visa privileges of foreign leaders.

NEW CONTROVERSY IN MALTA OVER A BAN ON FOREIGN LETTERS IN NAMES REMINDS US OF THE TRICKS MONEY LAUNDERERS USE TO HIDE IN PLAIN SIGHT

Media in the Republic of Malta has recently been covering the issue surrounding the government's intention to ban the public registration of foreign characters in names. BAN ON FOREIGN LETTERS IN NAMES TRIGGERS LEGAL THREAT https://lnkd.in/eSvmcst5 We are reminded of our prior coverage of the problem, in connection with Citizenship by Investment (CIP/CBI) passports: MOST INDIVIDUALS OBTAINING CBI PASSPORTS COME FROM COUNTRIES USING NON-LATIN ALPHABETS REQUIRING FACIAL RECOGNITION SOFTWARE IDENTITY CONFIRMATION. https://lnkd.in/eiqJF23s

We note for compliance officers at international banks that money launderers often choose to substitute a single non-latin letter, accent, or other departure from their original legal name, to confuse and confound database searches, resulting in a negative result for a high-risk individual . They also make such small alterations in corporate names, to confuse compliance officers into thinking that they are dealing with a well-known, legitimate entity, when the opposite is true.

Always pay attention to details when examining an individual or corporate name; does it include diacritical marks not normal to Western European script or typeface? are there one or more letters that are different than the standard Latin alphabet? Laundryman have been known to substitute a single Cyrillic ( Russian) letter, to foil name searching.

Read both of the above articles for important information, please.

CARIBBEAN CITIZENSHIP BY INVESTMENT (CIP/CBI) PROGRAMS MUST HAVE REMOTE ADMINISTRATION TO ESCAPE THEIR LEGACY OF CORRUPTION, FRAUD AND MONEY LAUNDERING

The severe visa restrictions that the United States has placed upon ANTIGUA and BARBUDA and the COMMONWEALTH OF DOMINICA, created due to the unacceptable situation surrounding those states' extensive Economic Citizenship/Citizenship by Investment programs, will not be rescinded so long as the rampant corruption, fraud and money laundering that has infected them since they were organized continues to plague their operation. Just today, we learned that government agencies are being offered bribes by prospective clients, to disregard the information in due diligence reports, and issue the passports to unqualified and high-risk applicants.

Antiguans who are asking when, or even if, the American visa restrictions will be lifted need to understand, as do all the other Eastern Caribbean CBI states, SAINT KITTS AND NEVIS, SAINT LUCIA, DOMINICA and GRENADA, that the US, UK and the EU aren't going to allow the current programs, which they deem unacceptable, for a wide variety of valid reasons, which we have painfully documented, to continue to enjoy their previous privileges for much longer. New European screening programs ( ESTA, ETA, etc.) will serve to block CBI passport holders, whether visa-free travel legally exists or not.

The solution is top-to-bottom reform, and to have the programs administered remotely, with oversight, rather than allow them to continue to wallow in their current unsupervised corruption, which has spawned global financial crime by bad actors with CBI passports. It is the only way to truly conduct effective, and corruption-free due diligence, screening and AML/CFT at the banking best practices level. And we mean administration in a Western country, far from the culture of corruption that has been a feature of life in the English-speaking Caribbean since independence, not moving the programs to an unregulated venue like Dubai, where high-risk applicants can still worm their way into being accepted, as we have seen of late with SAO TOME's remotely-administered program; US or UK-based locations, where strict supervision by regulators can actually occur. Sao Tome''s remote administration is accepting Russian and Iranian applicants, two high-risk, sanctioned jurisdictions; That should not be happening. Remote must be in a controlled environment.

Therefore, without an effective, properly administered CBI program, remotely operated and completely controlled from abroad, and not susceptible to local pressures and opportunities for bribes and kickbacks by greedy governbment officials and staff members, Caribbean CBI faces an existential moment, and the current United States government, no stranger to abrupt and lethal action, will steamroller over the jurisdictions that don't reform through professional. remote operation. Let's see whose Caribbean programs are still acquiring clients in 2028, if they fail to make this move to remote.

ANTIGUA MUST REFORM ITS CORRUPT CITIZENSHIP BY INVESTMENT (CIP) PROGRAM THIS YEAR BEFORE THE UNITED STATES WILL REMOVE THE CURRENT VISA RESTRICTIONS PLACED UPON ITS CITIZENS

Although the current government of ANTIGUA and BARBUDA has gone to great lengths to assure its people that the major restrictions imposed by the United States on visa entry are only temporary, in truth and in fact they are the direct result of the country's mismanaged and corrupt Citizenship by Investment (CIP) program, and those restrictions will not be lifted until and unless a major reform is instituted. The United States, )and for that matter, the European Union) has zero confidence in the current Labour government in place in Antigua to ever clean up CIP; only with a new government in place is there any reasonable expectation of a successful negotiation, resulting in a lifting of the current status, will occur. The money laundering and fraud which has been characteristic of the present program must become a thing of the past.

Furthermore, given the level of corruption in the agency operating the CIP, mismanagement, lack of control over agents abroad, and utter failure of due diligence, there will need to be administration of at least part of the tasks involved by external, independent operators, to insure that the bribes and kickbacks which have fatally infected Antigua's CIP no longer plague the program.

If Antiguans sincerely want to regain the ability to freely travel to the United States, free from the financial burdens of obtaining an expensive bond, and without the severe conditions that America has now imposed, then it is up to them to use the power of their votes to usher in a new government, not tainted by corruption as is the current one, so that they can move forward to favorably resolve their present visa situation.