US STATE DEPARTMENT POSTS $7 MILLION REWARD FOR RUSSIAN SANCTIONS EVADER WANTED FOR MONEY LAUNDERING

WANTED: ARTEM ALEKSANDROVICH USS
REWARD OF UP TO $7,000,000 

NAME: Artem Aleksandrovich Uss
ALIASES:   Artyom Uss
DOB: April 22, 1982
POB: Russia
NATIONALITY: Russia
CITIZENSHIP: Russia
HEIGHT: 5’10”
WEIGHT: 180 lbs
HAIR COLOR: Brown
EYE COLOR: Blue/Green

Artem Uss is the son of a Russian politician who served as the governor of Russia’s Krasnoyarsk Krai region.  Uss had ownership interests in several Russian companies in Krasnoyarsk Krai and elsewhere, including a coal mining company in Krasnoyarsk.  Uss also held a senior position with a subsidiary of a Russian state-controlled oil conglomerate.  The FBI determined Uss was a close associate of Russian oligarch Oleg Deripaska.

Uss orchestrated a transnational fraud, smuggling, and money laundering operation under the umbrella of Nord-Deutsche Industrieanlagenbau GmbH (NDA GmbH), a privately held industrial equipment and commodity trading company located in Hamburg, Germany.  As owner of NDA GmbH with another co-conspirator, Uss engaged in a variety of activities in violation of U.S. criminal laws and U.S. and other sanctions, including:  1) the unlawful export of millions of U.S. dollars in military and sensitive dual-use technologies from the United States to Russia; and 2) the use of the U.S. financial system to smuggle millions of barrels of oil from Venezuela.  

On September 26, 2022, a federal grand jury in the Eastern District of New York returned a 12-count sealed indictment against Uss and six other co-defendants.  Uss was charged with four counts: 1) conspiracy to defraud a department or agency of the United States; 2) conspiracy to violate the International Emergency Economic Powers Act (IEEPA); 3) conspiracy to commit bank fraud, and 4) conspiracy to commit money laundering for the oil smuggling and IEEPA scheme.  

The U.S. Department of State is offering a REWARD OF UP TO $7,000,000 for information leading to the arrest and/or conviction of Artem Aleksandrovich Uss.

COMPLIANCE OFFICERS; TRAVELING INSIDE EUROPE ? DON'T LEAVE HOME WITHOUT IT, AS EU MEMBERS REIMPOSE BORDER CONTROLS

If you are a compliance officer working in a country within the European Union, and you find you must travel to another bank branch, or to visit a customer, be advised that many EU Member states have temporarily reimposed border controls. We are not talking about just at the external frontiers of the Schengen Zone, but also, in a number of what are referred to as Internal Borders within it, meaning the old national borders.

This is said to be only a temporary measure, instituted in large part due to increased illegal migration flows within Europe, but the destabilizing issue of cross-border Palestinian protest activities may also be a contributing factor.

You are reminded to revert to maintaining possession of your passport, and to not rely upon any minor identification card to establish your name and nationality. For further details on specific frontier crossing points that are now subject to documents checks, go to the EC website Migration and Border Control here:

https://home-affairs.ec.europa.eu/policies/schengen-borders-and-visa/schengen-area/temporary-reintroduction-border-control_en

(legal authority for this measure)

Temporary Reintroduction of Border Control

The Schengen Borders Code (SBC) provides Member States with the capability of temporarily reintroducing border control at the internal borders in the event of a serious threat to public policy or internal security.

The reintroduction of border control at the internal borders must be applied as a last resort measure, in exceptional situations, and must respect the principle of proportionality.

The duration of such a temporary reintroduction of border control at the internal borders is limited in time, depending on the legal basis invoked by the Member State introducing such border control.

The scope and duration of reintroduced border control should be restricted to the bare minimum needed to respond to the threat in question. Reintroducing border control at the internal border should only be used as a measure of last resort.

The reintroduction of border control is a prerogative of the Member States. The Commission may issue an opinion regarding the necessity of the measure and its proportionality but cannot veto a Member State’s decision to reintroduce border control.

Notifications of the Temporary Reintroduction of Border Control

Current Temporarily Reintroduced Border Controls

ASSASSINATION OF HAMAS SENIOR LEADERS ABROAD COULD EXPOSE THEIR WESTERN BANK ACCOUNTS AND BANKERS

 

You can expect that senior leaders of the designated terrorist organization HAMAS who reside abroad, will shortly be personally targeted for assassination, due to their accountability for the attacks  and kidnappings perpetrated upon civilians on October 7, 2023. A public statement made recently by RONEN BAR, the head of SHIN BET, Israel's internal security agency, left little to the imagination:

"The cabinet has set us a goal, in street talk, to eliminate Hamas. This is our Munich. We will do this everywhere, in Gaza, in the West Bank, in Lebanon, in Turkey, in Qatar. It will take a few years but we will be there to do it."

The mention of 'Munich' was a reference to Israel's targeted assassination of Palestinian terrorists who were involved in the PLO kidnapping, and subsequent murder, of Israeli athletes at the Munich Summer Olympic Games in 1972. Known as Operation Wrath of God, tracking down and eliminating those terrorists known to be responsible was reportedly conducted by the Mossad, Israel's national intelligence agency. These were extrajudicial killings, but I leave it to the reader to judge whether they were morally justified under the circumstances, especially since terrorist organizations, by definition, do not adhere to neither the Laws  of War, nor the Geneva Convention. 

How is this of interest to compliance officers? The violent demise of known terrorists is always newsworthy, and the local banking relationships of terrorists are of major interest to journalists. Add that to the fact that some banks close their eyes to terrorist financing in transit elsewhere, especially in places where the governments have no diplomatic relationship with Israel.The last piece of the puzzle is the attraction to local branches of UK and EU banks abroad by terrorists, who may later attempt to move their funds into European nations.

 Therefore, if a terrorist dies, will the news of the inevitable police investigation, or an Israeli leak, expose a Western bank as the location where Hamas millions, diverted from Qatar or EU aid money, reside, under the control of a senior officer who lives the jet-setting high life, and who was allowed to maintain a hefty bank account which should never have been allowed to open ?  Did he gift his personal banker with a Rolex and trips on holiday to Malta, where he drew out cash of his client ? 

FRANCE IMPOSES SANCTIONS, ASSET FREEZES ON HAMAS POLITICAL LEADER AND HIS MILITARY DEPUTIES

The Government of France this week imposed sanctions, including asset freezes, on YAHYA SINWAR, the leader of HAMAS. Reports from France confirmed that a decree appeared in an official government journal. Previously ( November 13), sanctions were imposed upon the terrorist entity's military commander, MOHAMMED DEIF, and the deputy commander, MARWAN ISSA. 

There is also an indication that Hamas' financing network will come under sanctions in the European Union. Compliance officers at major EU financial institutions should be looking carefully at their client lists for front companies and frontmen with Jordanian,Turkish or Lebanese passports, and consider closing any accounts that appear to have suspicious connections, including and charitable organizations linked to Hamas, rather than get caught flat-footed by sanctions, and possible negative media coverage of terrorists as bank customers. 

European banks whose business development departments have targeted an affluent Middle East clientele, and whose customer service officers might be tempted to look the other way in onboarding new clients, due to large bonuses awarded by management for bringing in lucrative new business, are especially vulnerable. There must be a reason France has now abruptly instituted sanctions, so many weeks after the October 7 attacks by Hamas upon Israeli civilians. Are there accounts of Hamas leaders at French, Austrian or Swiss banks? Several Hamas senior leaders, who reside in Qatar, are believed to be billionaires, due to their diversion of aid money to their personal use. 

IS PROFITING FROM TRADING WITH ADVANCE NOTICE OF THE HAMAS ATTACK ON ISRAEL INSIDER TRADING OR PROVIDING FINANCIAL SUPPORT TO A TERRORIST ORGANIZATION?

 

A paper published this week has made and documented allegations of a surge in short selling immediately prior to the October 7 terrorist attack on Israel by Hamas. What is the liability, if proven by the evidence, of both traders and their client, for not only Insider Trading, but Providing financial Support for a terrorist organization? Dp we really have such amoral stockbrokers on Wall Street or elsewhere that would engage in such conduct? If so, terrorist financing and money laundering charges would seem appropriate, with enhanced penalties for convictions at sentencing. 

These issues require immediate investigation by the Securities & Exchange Commision, as well as America's Federal law enforcement agencies and its intelligence community. Read the extract below for more details.

"Recent scholarship shows that informed traders increasingly disguise trades in economically linked securities such as exchange-traded funds (ETFs). Linking that work to longstanding literature on financial markets’ reactions to military conflict, we document a significant spike in short selling in the principal Israeli-company ETF days before the October 7 Hamas attack. The short selling that day far exceeded the short selling that occurred during numerous other periods of crisis, including the recession following the financial crisis, the 2014 Israel-Gaza war, and the COVID-19 pandemic. Similarly, we identify increases in short selling before the attack in dozens of Israeli companies traded in Tel Aviv. For one Israeli company alone, 4.43 million new shares sold short over the September 14 to October 5 period yielded profits (or avoided losses) of 3.2 billion NIS on that additional short selling. Although we see no aggregate increase in shorting of Israeli companies on U.S. exchanges, we do identify a sharp and unusual increase, just before the attacks, in trading in risky short-dated options on these companies expiring just after the attacks. We identify similar patterns in the Israeli ETF at times when it was reported that Hamas was planning to execute a similar attack as in October. Our findings suggest that traders informed about the coming attacks profited from these tragic events, and consistent with prior literature we show that trading of this kind occurs in gaps in U.S. and international enforcement of legal prohibitions on informed trading. We contribute to the growing literature on trading related to geopolitical events and offer suggestions for policymakers concerned about profitable trading on the basis of information about coming military conflict."

Keywords: law,finance,trading,terrorism,securities,financing

JEL Classification: G14,K22

Suggested Citation:

Jackson, Jr., Robert J. and Mitts, Joshua, Trading on Terror? (December 3, 2023). Available at SSRN: https://ssrn.com/abstract=4652027

ATTORNEY WHO NEVER MADE PAYMENT OF SETTLEMENT FUNDS TO FARMERS IN SHELL OIL SPILL THAT HE RECEIVED AS LOCAL COUNSEL

If you follow oil spill cases, you know that there were a number of civil actions filed against SHELL OIL COMPANY, by farmers in Barbados after 200 acres of their properties were permanently rendered unfit for cultivation by leaks in the company's seven-mile pipeline.Crops were wrecked, water supplies were contaminated, and the fertility of the soil reduced so as to be not economic or productive for agriculture. Local attorney ALRICK SCOTT negotiated the settlement on behalf of the oil company, and reportedly received substantial funds, running into the many millions of dollars, to be held in escrow and paid out to the victims.

Our investigation has revealed that only a small portion of the farmers have received their settlement money, and those who have not been properly paid accuse attorney Scott of misconduct in retaining it for his personal use and benefit, in violation of both the law and his oath as attorney. Some of the farmers have died of old age whilst waiting to be compensated, as time has passed, and their estates are now seeking payment for survivors. Scott continues to delay, and the victims fear that he has spent or otherwise dissipated their settlement money, in violation of the terms of settlement. He has been dealing in bad faith with the victims, confident that he is above the law, as he lives in a jurisdiction where corruption trumps the Rule of Law.

Letter refusing to deal with estate of an unpaid victim

Unfortunately, lawyers in Barbados have a long and sordid history of stealing client funds while being in a fiduciary capacity, owing a duty to the victims to render compensation for their injuries. Neither the courts nor the Barbados Bar Association can be relied upon to render justice for the many victims, due to the pervasive corruption among attorneys in the country, who do not fear the law nor professional discipline.   

We wonder whether Shell oil company is aware that their legal representative has defaulted upon the terms of the settlement of the oil spill dispute, which means that the litigation can be reopened, and the terms of settlement modified by the courts, in favor of the victims who were cheated out of their just compensation by Shells' designated attorney. We also wonder whether the London law firm for Shell,  HAUSFELD LLP has any liability to the victims, or to the Court, for failure to adequately supervise Scott's disbursement of the settlement proceeds in a timely and businesslike manner, and for professional negligence to Shell due to Scott's alleged misconduct.

FINCEN'S NEW 2024 BENEFICIAL OWNERSHIP REGULATION WON'T STOP THE MONEY LAUNDERERS I KNOW

The new rule of the Financial Crimes Enforcement Network [31CFR Part 1010] which becomes effective on January 1, and is further strengthened on January 1, 2025, will not work to eliminate the information gap on Beneficial Ownership that allows money launderers and financial criminals to take full advantage of the Black Hole that is zero information on Ultimate Beneficial Ownership of corps.

USE IT, ABUSE IT & LOSE IT; That's the laundryman's Standard Operating Practice. I would have one of the corporate service providers in Delaware form a company, and then (1) fly to Philadelphia (2) take a taxi across the state line/border, (3) register a vessel at an obscure bait and tackle shop, using aliases whose signature were authenticated by a cooperating Notary Public  and (4) Fly back the same day and deliver the corporate records AND the vessel registration & Delaware hull number to clients.*

This long (and in 2025 shorter) lag time in requiring registration of beneficial ownership is too little, and far too late. Enterprising laundrymen have already used the corp for the illicit purposes therein intended. They will let the company expire for lack of filing Annual Report with the Secretary of State, but the damage has already been done.

Money launderers do not work at the pace of normal business; they are on overdrive 24/7. Do not expect them to (a) comply with this slow filing requirement and (2) even have that corporation active and operating at the time of the filing deadline. They will have already moved money, drugs, or something else in support of illicit activity, long before ANY deadline. Only if compliance with beneficial ownership was to be at corporate formation, with actual punishment teeth to enforce it, would it ever be effective. Nice try, FinCEN, but you have unfortunately not thought through the problem sufficiently to solve it.

_________________________________________________

* Alternatively, I would form a bearer share corporation in a Caribbean tax haven jurisdiction, fly in a maritime surveyor from the Cayman Islands to create the necessary inspection, and register the vessel remotely in the United Kingdom from Anguilla. By the time the files got to Cardiff, where vessel documentation was kept, the boat had already gone on a narcotics trafficking journey, and was due to be re-registered in Delaware all over again, and so it goes. Aircraft used for smuggling drugs or bulk cash is a story for another day.

HEZBOLLAH TERRORIST LEADING ATTACKS ON NORTHERN ISRAEL ATTACKED US EMBASSY IN BEIRUT IN 1983

The United States has an old score to settle with this Lebanese terrorist; IBRAHIM AQIL  a/k/a TAHSIN was a key player in the 1983 bombing of the US Embassy, which killed a number of members of our intelligence community. According to media reports, he now leads Hezbollah's RADWAN UNIT, which is responsible for the attacks on Northern Israel, both before and since October 7. He is known to be a member of Hezbollah's JIHAD COUNCIL, and was also involved in the bombing of the US Marine Barracks, which killed 241 soldiers. 

Apparently, Israeli aerial attacks into Lebanon on response have inflicted a large number of casualties upon the Radwan Unit, but Aqil has not been named as one of them.

PREMIER'S CALLS FOR INDEPENDENCE OF THE BRITISH VIRGIN ISLANDS COULD KILL THE GOLDEN GOOSE FOR THIS CENTER OF DODGY SHELL COMPANY FORMATION

A very assertive public statement by the sitting leader (Premier) of the British Virgin Islands NATALIO WHEATLEY, regarding self-rule in the BVI, has local media there openly discussing a move towards independence, after what it regards as unnecessary interference by the UK in BVI internal affairs. Allegations of systemic corruption, cronyism, "don't ask don't tell" about the facilitation of drug trafficking through the territory, and other major problems voiced by Britain aside, talk of throwing off what is regarded as the British yoke of colonialism is more dominant since a critical report on the BVI, with the threat of Direct Rule, was issued around the time that disgraced former Premier ANDREW FAHIE was arrested in Florida, and charged with both money laundering and conspiracy to engage in drug trafficking.

What if the BVI becomes independent? From a compliance standpoint, the cache' and implied stability of a British Overseas Territory goes right out the window, when it comes to the anonymous BVI corporation. One might expect most corporate service providers abroad, especially in Hong Kong, to cease recommending the BVI company as the entity du jour immediately, and move on to another jurisdiction. Such a radical loss of revenue in the BVI, both in government fee cash flow, and in the local provider firms, to hit the Road Town economy hard. How will all those cushy "do-nothing" government job salaries be funded? Who will employ the clerks and lawyers who are involved in company formation? Expect a recession forthwith, if not an outright depression, as the direct result.

Of course, as a compliance officer, I would welcome the downfall of the BVI company structure; those corporations are the bane of due diligence inquiries, and continue to bedevil those of use who need to positively establish beneficial ownership at account opening, for transaction monitoring, and to properly discharge our AML/CFT responsibilities each day. Will the BVI dive off the deep end into independence? We cannot say, but we will be watching.

EVIDENCE OF WARTIME COMPLICITY BETWEEN HAMAS AND UNRWA STAFF MAY SERVE TO DISQUALIFY THE AGENCY FROM ANY POSTWAR ROLE IN GAZA

The United Nations Relief and Works Agency for Palestinian Refugees in the Middle East, or UNRWA, created in 1948 to assist refugees from the recently-concluded war between Israel and the Arab countries, may not survive the present hostilities in Gaza, which presents unusual problems for compliance officers charged with countering the financing of terrorism by HAMAS and its allied and affiliated organizations in Gaza. Evidence emerging of the actions of UNRWA staff in facilitating and assisting Hamas, both before and during the present war, may disqualify it from any future role in assisting Palestinians. It is expected that Israel, post-war, may choose to abandon its recognition of UNRWA as a provider of humanitarian assistance in the not too distant future. 

Victims who were hostages taken to in Gaza assert that they were actually held captive by UNRWA staff; fuel and other United Nations assets were turned over to Hamas; UNRWA school leaders openly cheered on Hamas' terrorist activities within southern Israel; The UN allowed the construction of Hamas facilities literally underneath UNRWA schools in Gaza; Hamas was allowed to store weapons, and fire rockets and missiles from school courtyards; and a number of additional ways in which UNRWA showed it was not only sympathetic to Hamas terrorist activities, it openly provides logistical support that translated to facilitating its military activities.

Created to assist in the plight of displaced Palestinians, who were instructed by the Arab states to leave areas of the terminated British Mandate of Palestine during their invasion of the new State of Israel, UNRWA had a mandate support and create jobs. Unfortunately, it has perpetuated the indefinite refugee status of the Palestinians, by arbitrarily deciding to consider the descendents of Palestinian refugees as legitimate refugees, entitled to relief, and status that the UN has never conferred anywhere else. Subsequent generations of refugees are not treated as refugees under international law; the influence of the Arab countries, then staunchly anti-Israel, is believe to have been the cause of the unique treatment of Palestinians, whom neighboring nations in the region did not want emigrating into their jurisdictions.

Obviously, the State of Israel will not be accepting UNRWA in a future Palestinian state in Gaza; compliance officers at international banks, who are now aware that UNRWA senior staff knew or should have known that UN assets were being diverted to Hamas, now will have the difficult task of insuring that those United Nations Relief and Works Agency now working with Hamas, do not use their privileged international aid status to fund Hamas, directly or indirectly, as UN employees. Given that a number of UNRWA school leaders and staff are known to be Hamas members, and United Nations official engaged with UNRWA matters must be conclusively ruled out as a financial facilitator to a designated terrorist organization. Compliance officers tasked with CTF responsibilities should be made aware of this threat, and adjust their inquiries accordingly.

IDF discovers Gaza rockets, missiles hidden under UNRWA equipment

IDF destroys Gaza mosque used by Islamic Jihad as operational HQ • IDF strikes over 50 terror targets in Khan Yunis from air, land, and sea

Released hostage says he was held by UNRWA teacher in Gaza - report

Boker's report also cites another hostage saying that he was held by a Gazan doctor as he was treating children patients.

By JERUSALEM POST STAFF

 30/11/2023

WE NAME THE MINOR GAZA TERRORIST ORGANIZATIONS BELIEVED TO BE HOLDING ISRAELI HOSTAGES

This is in response to readers who asked us to name the minor Palestinian terrorists organizations in Gaza that Israeli intelligence services which we referred to in our recent article Compliance Officers facing Zero Tolerance for Permitting Terrorist Financing into the Middle East need to Know who are their Additional Adversaries . If you are periodically checking social media entries of your high-risk bank clients, and happen to see any of these organizational symbols or flags, which could indicate that your customer is affiliated with any of these entities, or is delivering financial support to them abroad,  immediately upgrading your inquiry to enhanced due diligence, and forthwith report your findings to your director of compliance and/or outside bank counsel. 

We remain puzzled why there is essentially little publicly-available information about these terrorist organizations, other than the PFLP. Familiarize yourself with their names, and keep the images handy for future reference. This is not intended to be anything other than the disclosure of the entity names and their symbols; conduct detailed research on any group that you believe might be involved with your banks clients, even indirectly. America's intelligence community most certainly know the names of all the leaders of these organizations, but chooses to classify them and not to share them with the financial sector, so we have no way of knowing who they are. No wonder the war on money laundering is not going well.

1. THE POPULAR FRONT FOR THE LIBERATION OF PALESTINE.

                                                                                   

2. THE DEMOCRATIC FRONT FOR LIBERATION OF PALESTINE.

                                                                        

3. AL-AQSA MARTYR'S BRIGADE

                                                                           

4. PALESTINE MUJAHIDEEN MOVEMENT

                                                                        

4A. MUJAHIDEEN BRIGADES -Armed Wing of PMM: 

FLAGS OF VARIOUS GAZA TERRORIST GROUPS:

                                                            

                   
 

                                                                                   

COMPLIANCE OFFICERS FACING ZERO TOLERANCE FOR PERMITTING TERRORIST FINANCING INTO THE MIDDLE EAST NEED TO KNOW WHO THEIR ADDITIONAL ADVERSARIES ARE

Given what appears to be a renewed zero tolerance policies for terrorist financing into the Middle East, given American law enforcement agencies' increased focus on Palestinian terrorist organizations, compliance officers at banks in states where there have been remittances to and trade or charitable relationships with, the countries of the Middle East, are at a severe information disadvantage about who their targets should be, regarding the more obscure entities that exist, especially in Gaza and the West Bank. Why is there a dearth of publicly-available data about these smaller players, and their leaders?

As the press has repeatedly advised, not only are their other know terrorist organizations operating within Gaza, besides HAMAS and PALESTINIAN ISLAMIC JIHAD, but there are at least two other, more minor entities, and these entities are certainly targets, as they are said to be each holding Israeli and foreign hostages captured on October 7. Israeli media has accused Hamas of actually selling and trading hostages with these additional terrorist groups in Gaza. This means that American compliance officers must consider them to be already targeted and be under investigation by our law enforcement and intelligence agencies.

So why is there no public disclosure of the identities of these terrorist organizations, and of the names of their leaders? This puts compliance departments at a major disadvantage, as they do not know what or who to look for, when it comes to terrorist financiers. I understand the hesitation of US law enforcement agencies to disclose what it regards as sensitive information, and to not give them any publicity, but classifying or withholding this critical information will allow these smaller terrorist groups to obtain funding from their supporters abroad, especially from the United States. 

Therefore, we call for the release of not only the various names that these terrorist organizations operate under,and their fronts, but the identities of their leaders, and any other details that might allow compliance officers to spot terrorist financiers in the act of remitting funds. Make this information available please, so that compliance officers can protect their banks, and reduce the risk that they are unwittingly approving the funding of terrorist entities in Gaza. If necessary, declassify a sufficient amount of data so that we have the tools to do our job.  

EXTRAORDINARY DELAYS IN JUDICIARY HANDING DOWN DECISIONS? BLAME CORRUPTION, NOT WORKLOAD

The news, appearing this week in Barbados' government-controlled media, that the country's Supreme Court may be taking action against judges who wait months, if not years, to hand down rulings in cases that have already gone to trial or final hearing, is intended to confuse Bajans about the true cause of judicial delay. The fact that thousands of pending cases are in a Twilight Zone, where no written rulings have been entered by sitting trial or appellate judges, notwithstanding that the trial or oral argument in an appeal have long ago occurred, is NOT a reflection on major workload of cases; it's all about corruption, dear reader. There is no overload of cases assigned; it's just disinformation, intended to confuse laymen who are not familiar with true activities within the court system.

In truth and in fact, the corrupt power structure in one-party Barbados uses the intentionally dilatory court docket to punish Opposition party members and vocal supporters, individuals who have expressed dissatisfaction with the present government's insensitivity to the needs of its poorer citizens, those who have pointed out widespread attorney fraud and misconduct, and others who are perceived as threats to the continued reelection of certain senior government officials. Delaying a court decision, indefinitely, is a tool of corrupt leaders who wish to tamp down dissent, in any form, which is a Human Rights violation by definition, according to agencies of the United Nations.

It's not limited to Barbados, unfortunately; look at the MEHUL CHOKSI extradition case in neighboring Antigua, where a billion-dollar fraudster fugitive from India has been able, with government collusion, to evade justice at home for years. Also, one needs only look at the courts in the Republic of Malta, where an antiquated Production of Evidence court procedure is employed by the corrupt Labour Party leaders to delay justice ad infinitum, as it suits those in public office anxious to protect their own from justice. Look for such judicial misconduct in any autocratic state pretending to be a democracy; That's how they rein in their opponents.

This means individuals will often serve out their entire sentence of incarceration, before the appeals court hands down a possible decision of reversal in their case; civil plaintiffs with a valid cause of action often, after a successful trial of their claim, wait years for a written ruling, whilst the defendant, favored by the government in power, cheats justice, free to transfer his assets, and evade justice. Some may call these politically-sensitive cases, but I call them what they really are, indicia of corruption, on a grand scale. No wonder many foreign investors steer clear of Barbados, and countries like it; in the event of a dispute with locals, they know that there will be no justice for them in the courts.  

HAVE YOU READ ALL TWENTY OF THE MONEY LAUNDERING TRADECRAFT ARTICLES?

 

I understand that some readers may have missed some of the articles on money laundering techniques and strategies. In the event that you are not as regular reader of my blog, here is a list of all of the Tradecraft 101 articles published this year to date; there are more in preparation. The may all be found at https://rijock.blogspot.com

I can provide real-life examples of these techniques, from my own experience, to enhance the understanding of these methods. Contact me if you are interested in a virtual or live seminar. miamicompliance@gmail.com

 1. MONEY LAUNDERING THROUGH INTERNATIONAL PRODUCT DIVERSION.

2. MONEY LAUNDERING THROUGH LIFE SETTLEMENTS.

3. ADVANCED TRADE-BASED MONEY LAUNDERING.

4. THE LAUNDRYMAN'S VERSION OF HAWALA.

5.  MONEY LAUNDERING THROUGH FINE ARTS AND ANTIQUES.

6. MONEY LAUNDERING THROUGH CASH-INTENSIVE BUSINESSES.

7. MONEY LAUNDERING THROUGH THE MOTION PICTURE INDUSTRY.

8. INVESTING OFFSHORE ILLICIT WEALTH ONSHORE.

9. MONEY LAUNDERING THROUGH REAL ESTATE INVESTMENTS.

10. MONEY LAUNDERING AND SANCTIONS EVASION THROUGH THE USE OF CITIZENSHIP BY INVESTMENT (CBI) PASSPORTS.

11. MONEY LAUNDERING USING SHELL AND SHELF COMPANIES.

12. MONEY LAUNDERING THROUGH CORRESPONDENT BANKING.

13. HOW MONEY LAUNDERERS EMPLOY ADVANCED TECHNOLOGY TO OUTWIT COMPLIANCE OFFICERS.

14.MONEY LAUNDERING THROUGH LOTTERIES AND OTHER CASH PRIZE EVENTS.

15. MONEY LAUNDERING THROUGH THE HOARDING AND SALE OF PRECIOUS METALS AND VALUABLE STAMPS AND COINS.

16. MONEY LAUNDERING THROUGH THE USE OF DIPLOMATIC PASSPORTS BY NON-DIPLOMATS.

17.WHAT GOES UP AND DOESN'T NECESSARILY COME DOWN IN MONEY LAUNDERING OPERATIONS.

18. THE USE OF PSYOPS IN MONEY LAUNDERING TO CONFUSE COMPLIANCE OFFICERS INVOLVED IN TRANSACTION MONITORING.

19. HOW MONEY LAUNDERERS DEAL WITH IDENTITY VERIFICATION ISSUES.

20. WHEN MONEY LAUNDERERS GIVE YOU UNINTENTIONAL EASTER EGGS FOR YOUR ENHANCED DUE DILIGENCE INVESTIGATION.

COMPLIANCE IN 2024; WHERE EXPERIENCE IS EXTRAORDINARILY IMPORTANT AS A TRAINING TOOL

Compliance officers at international banks are presently working during a period marked by increased risks posed by the double-barreled threat of Russia sanctions due to Ukraine, and a new terrorist financing focus due to the Israel/Hamas war, and this is not the time for newly-minted frontline staff to get on-the-job experience. Banks need seasoned compliance directors to guide their staff during this high-risk period, individuals who will deliver practical training programs, to equip their people to deal with these emerging threats, while still exposing them to the money laundering tradecraft that they need to know to identify advanced and unusual techniques employed by laundrymen.

Since you can't give your staff twenty years of hands-on compliance experience, adequate training, supervised by people who have been there since 9/11, and can pass on their decades of actual tactical exposure, has become mandatory. Neither academics nor former regulatory officers can give your staff the benefit of the perspective of experienced compliance officers, who should be conducting your training sessions, using not only the needed content, but illustrating the information with their own actual examples from cases they handled.

Any compliance directors whose 2024 training budgets are not sufficient to bring in outside talent should draft their most experienced frontline staff to conduct that training. I humbly suggest that they may wish to employ the twenty Money Laundering Tradecraft articles that I have published on my blog this year, to give their people a broad-based background in the techniques that they are most likely to encounter in their daily workload, If you are not aware of those articles, email me at miamicompliance@gmail.com  and I will supply you with a detailed list of the topics I have covered. Use your best people to teach your new ones the tricks of our trade, ladies and gentlemen. These are difficult times for any compliance department; you need to meet these challenges head on; use your most experienced people to do that.