This is how THE ILLICIT EDGE, where I recently was interviewed about my career, interpreted my life story. You can watch the video version of my podcast here:
https://www.youtube.com/watch?v=TiXmVhZzjvk&t=2021s
Money Laundering, Terrorist Financing and Financial Crime
This is how THE ILLICIT EDGE, where I recently was interviewed about my career, interpreted my life story. You can watch the video version of my podcast here:
https://www.youtube.com/watch?v=TiXmVhZzjvk&t=2021s
Once again, the United States trades a major convicted criminal for some hapless American dumb enough to be caught inside Russia with anything that passes for contraband. Why our government, which says it has a policy of never negotiating with terrorists, allows itself to get roped into giving up career criminals for someone arrested abroad by a dictatorship for the express purpose of swapping him for someone they want back, I'll never know.
The next time someone considers travel to Iran, Russia, Venezuela or China, perhaps they might consider that they might very well become a hostage to a tyrant's whims or needs. Let's stop losing our convicted and imprisoned bad actors, going free because of a mistake of one of our own, who travels to a high-risk jurisdiction, and thinks it's O.K. to do so.
Now, however, had he lived to see his beloved country in 2025, he would he distressed to see that a Chinese company, CARIBBEAN GALAXY, with the aid and assistance of corrupt officials more interested in feathering their own nests, rather than helping the people who elected them, has literally stolen billions of their patrimony, through his beloved CBI. Billy is most likely looking on from his cement grave, with strong disapproval and even disgust, as the current SKN Labour leadership, cowing to Chinese demands and undue influence, has facilitated the theft of not only billions of US Dollars, but the country as well, to the PRC. They have ignored "Country Above Self" in favor of selling out for bribes & kickbacks.
The much-cited BASEL AML INDEX has South Africa at 52 out of 100, in its calculation of money laundering risk levels, which are based upon a number of basic issues, such as weak regulatory frameworks, political instability, and cash-driven economies have made the continent a hotspot for illicit financial activities. However, although much has been made of the country's strengthened AML legislation, its failure to zealously pursue money laundering networks, rampant money laundering due to corruption, and a number of other factors, which we shall discuss at the upcoming Africa Financial Crime seminar, which place it squarely in the category of highest risk for money laundering on the Continent
https://www.youtube.com/watch?v=TiXmVhZzjvk&t=2021s
AML/CFT is not a job; it must be a calling for compliance officers assigned to Account Opening and Transaction Monitoring. It is not for people who scurry out of the office at the official close of business, with that urgent, time-sensitive matter left on their desks; it is definitely not for those who pass a borderline suspicious transaction, just to move on to the large pile which some non-compliance officer is urging that they complete before five o'clock rolls around, because a certain account executive wants to open those new accounts pronto.
Anti-money laundering is never a chore; it should be considered a daily challenge to be fought, something close to being fun, while understanding that it is a serious task, but performed with a zeal that only one devoted to that profession can muster up. Every day, joust against the laundrymen, by exposing them; take their actions out in the sunlight,and either shut them down, or make your bank a place where they fear to tread, lest they be caught in the act.
I realize, as a former career money launderer, I regard AML as nothing short of an adventure in intellectual stimulation; others may find it mundane or stressful, but I relish those challenges. Make sure that those individuals who lead your compliance department also see it as a duty. Be the resolute gatekeeper, pushing back against the money laundering darkness, ladies & gentlemen.
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.
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?
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.
Here is the latest special report on the organization, dated January 2025:
https://www.gov.il/en/pages/special_report_hrf_foundation_2025-01
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