Sunday, March 31, 2013


If you follow Iranian domestic events, you know that Egypt, as part of the renewal of diplomatic and cultural relations between the two countries, has started tourist flights, by Iranians, to Egypt's premiere sites. Thus far this week, fifty Iranian tourists hve flown to Luxor, Aswan and Sharn El-Sheikh. Is there a hidden agenda for these trips ?

I note that two Iranian diplomats accompanied the first flight of eight tourists. Egypt's southern cities also feature Egyptian, Middle Eastern and European financial institutions, whose primary role is to serve the tourists. Will they also be facilitating sanctions evasion to these "tourists ? " Sharm El- Sheikh alone has 34 bank branch offices.

If I was an Iranian money launderer charged with assisting Iranian officials purchase dual-use products, and in general evade UN, US, Canadian and EU sanctions, I would love the anonymity of a busy, but obscure, Egyptian bank branch, in a tourist town, or a branch of an EU bank there. You may want to examine any unusual funds transfers originating in Egypt,  from 25 March on, where the goods purchased are being shipped to a destination known for transshipping to Iran in the past.


Readers who wish to review the complete text of the Federal Reserve Consent Order against Citigroup Inc. , can find it here*.

* In the Matter of Citigroup, Inc. 

Friday, March 29, 2013


If you are watching the strong response that the United States took to the latest North Korean provocations, sending B-2 bombers over Korea on a training bomb run, you know that the DPRK is now a priority issue with the American Government. Prudent compliance officers always adjust their policies and procedures to unfolding events.

Since both the US and the UN have imposed new sanctions upon North Korea, you will want to take a hard look at any transactions your clients have with that country. I understand that charitable clients, NGOs and clients with OFAC licenses are generally low risk, but proper procedure requires that you ensure that there is no chance your bank is involved in any transactions that Treasury will look upon as technical violations.

Frankly, I see no reason why you should be comfortable, given the North Korean posturing, and threats against the US, with any exposure there, as there is little to be gained, and a lot at risk. This also means watching potential transfers to North Korea through third parties; watch yourself on indirect transactions.

Thursday, March 28, 2013


The Chinese PLA Navy sent an amphibious task force to remote James Shoal, a reef in the far eastern edge of the South China Sea, just 80m from Malaysia, which claims James Shoal is its coastal territory.   This action represents the most provocative advance of China's maritime might to date, and could raise regional risk in the South China Sea. James Shoal is 1800 km from the Chinese Mainland; the Peoples' Republic does not appear to have a valid claim.

China's fleet, which consisted of one of its most advanced landing ships, which carries marines and hovercraft, supported by three escort ships, reportedly renamed the atoll "Zengmu Reef," and dropped a subsurface marker to buttress its claim. The Chinese action came uncomfortably close to Brunei for the first time, which is another complication in the calculation of risk in the South China Sea.

Uninhabited James Reef

The employment of an amphibious task force far south of the Spratley Islands is disturbing; China is clearly pushing its colourable claims to the extreme, most likely testing both the small countries in the area, as well as looking for a United States response, or lack thereof. It also demonstrates China's expanding maritime offensive capabilities, which I am sure is not lost on the Republic of China (Taiwan), which China covets. Curiously, Taiwan still has a historic claim on the reef, but there does not appear to be any factual basis for its claim, either.

Invasion fleets do not belong in the South China Sea; they do not promote peace, and of this is what China has in mind, look for the United States Navy to move into these waters sooner rather than later.

Wednesday, March 27, 2013


Many Venezuelans this week are extremely angry at their government, after it became public knowledge that a number of Hezbollah Venezuela agents, including its OFAC-sanctioned leader, have Venezuelan diplomatic passports. Reports linking Hezbollah to the country's acting president, Nicolas Maduro, validate claims that the Specially Designated Global Terrorist (SDGT) organisation has carte blanche to traffic in narcotics,  then laundering its illicit profits through Panama, and into Lebanon, thus providing substantial financial support to the organisation.

How many Hezbollah Latin America operatives are roaming the globe as "diplomats," their bags and baggage immune from customs searches ? Remember, that is how North Korea distributed the Super Note, the counterfeit US $100 note that was extremely difficult to identify as bogus. Hezbollah agents could transport cocaine in international commerce, without fear of arrest. They also can carry bulk cash, or financial instruments into offshore financial centres, this moving Hezbollah drug profits along on their journey to controlled entities inside Lebanon.

One wonders whether how many Hezbollah agents are running around Europe with Lebanese diplomatic passports, moving cash or cashier's cheques through EU banks, in support of the organisation's terrorist goals. Apparently, the Bulgarian bus bombing was not enough incentive to
compel the EU to designate Hezbollah, but rest assured, the financial crimes they are engaging in are far more dangerous. A shame nobody in Europe is paying attention.


Recent reports state that US Government agencies have asked officials in the Principality of Liechtenstein to disclose information on American citizens who own foundations domiciled there. Readers not in the legal or financial world may not be aware that a foundation, which has no shareholders or beneficial owners, is a favourite tool of individuals with "flight capital" that they are looking to hide from the taxman or law enforcement.

Now that the US is obviously beginning to move against Liechtenstein, one must assume that at least some capital flight will occur, ahead of any formal US actions. If you are a compliance officer at an international bank, you might want to alert your new accounts staff to forward to you any and all new clients, who speak English with American accents, but whose vehicles are corporations or foundations from offshore financial centres, especially brand-new companies.  If they are presenting official cheques
drawn on Liechtenstein banks, the reason for their move becomes obvious.

Tuesday, March 26, 2013


As we continue to cover the never-ending series of Ponzi schemer cases that have been traveling  though the Federal Court system lately, one thing has become crystal clear: Once arrested, the major Ponzi schemers tend, by and large, to allege that their bankers facilitated the fraud. This is a huge problem, because the banks involved are already looking at civil litigation from the Ponzi victims, and potential regulatory fines & penalties. The frightening thing is, not all the damaging statements from the Ponzi schemer may have a factual basis.

Let me tell you how it works: Federal criminal defendants, who have already been convicted, have an opportunity to receive a shorter sentence than the Federal Sentencing Guidelines* computation indicates. It is called Substantial Assistance (USSG 5k1.1), and it happens when the defendant's cooperation results in either additional indictments, or a financial recovery for the US Government.

Testimony to the effect that certain senior officers at your bank aided and abetted in the Ponzi scheme will often get the Ponziman his lower sentence, and some defendants, who have a problem with truth in any case, have been known to exaggerate, to embellish, to achieve that short sentence. That is the first problem.

The second situation takes place within one year of sentencing; the imprisoned Ponzi schemer can achieve that much-desired sentence reduction, again by testimony incriminating your bankers, assuming that the US Attorney agrees, and files a motion under Federal Criminal Rule 35(b). There is always the temptation to portray his bankers as facilitators, even when that was not the case.

What I am getting at here is that the tendency to boast about the number of bankers in his back pocket appears to serve the Ponzi schemer well at sentencing, deflects some of the blame, and provides law enforcement with new, fixed, and asset-rich targets. Compliance officers must, duly and regularly, examine successful bank client lists, and their accounts, to rule out possible Ponzi scheme activity at your bank, and avoid a long nightmare, built on lies and half-truths.  
* No longer mandatory. but still advisory.


Mr. & Mrs. Rothstein and V.P. candidate Pallin

A South Florida bank where convicted attorney/Ponzi schemer Scot Rothstein was allowed to have huge overdrafts on his accounts, and where he admittedly was able to transfer funds between his trust accounts and personal accounts at will, is reportedly up for sale. The bank sustained multi-million dollar losses two years in a row, due to massive settlements with Ponzi victims, and overdrafts left hanging when the Ponzi scheme collapsed in a heap.

The bank, which also had money laundering deficiency problems with regulators, suffered severe reputation damage as the result of its association with the Rothstein case. The Ponzi schemer, who was actually a shareholder in the bank, is currently serving a 50 year sentence for his crimes.
With the Governor of Florida
The owners, who reportedly paid $93m to purchase the bank several years ago, could take a loss on their investment in any future sale, as the direct result of the bank's diminished reputation. If there was ever a reason for bankers to scrutunise all bank clients whose success seems too good to be true, the possibility that a client is operating a Ponzi scheme is it.

Monday, March 25, 2013


With all the controversy emerging from Congressional hearings regarding compliance failures at major banks, with American leaders asking why no senior staff have been, or will be, charged with money laundering, or sanctions evasion, we will certainly see more personal AML/CFT accountability in the future. Meanwhile, since it does not appear that anyone working at any of the major US banks cited for money laundering or sanctions violations will be indicted, you may want to ensure that your bank does not have a problem from a bad actor recently moved in next door to you; your new co-worker.

It is humbly suggested that any new compliance hire in your office, who came on board during the past two years, be vetted to minimise the risk that he did not participate in any programme, in his past employment, that might indicate intentional disregard of compliance best practises. Bluntly stated, was he ever working in a bank where there was widespread, institutionalised sanctions evasion, or willful blindness of money laundering activity ? We call this risk management.

Here's how to do it:

(1) Take his resume, and extract the names of the banks where he was previously employed, and the years that he was there.

(2) Run those particular banks on the relevant regulatory lists, to determine whether any of them had fines & penalties levied against them, during the period that the individual worked there.

(3) Carefully read the Cease & Desist orders, and determine what departments and divisions would have had a major role in the violations.

Was your co-worker involved, and to what degree ? Was he instrumental in intentional compliance malpractice ?

 This may sound like a witch hunt, but it is better that you know in advance, rather than when a law enforcement agency interviews you two or three years later, long after he has left, about certain things he did at your bank. They may want to know why he failed to report suspicious activity, and whether you were somehow involved.

There are only a very small amount of dirty compliance officers out there, thank goodness, but you do not want to work beside any of them, lest you also get dragged into the mud.   

Sunday, March 24, 2013


As a money launderer, I learnt early on that one of the most effective items in my toolbox was the use of a well-crafted deceptively similar entity. This means that I formed corporations with names that were very close to those of well-established companies, often with only one word or letter different than the real thing. the purpose of this ploy was to deceive legitimate businesses (e.g. bankers) into thinking that they were dealing with a subsidiary or affiliate of a major legitimate corporation, or even the company itself.

Once, when I had formed a new subsidiary of a client's legitimate company, I traveled to Washington to meet with the representatives of a major law firm, to obtain their assistance in a new matter. The firm erroneously assumed that my client's new company was a subsidiary on a giant US company, merely because I had chosen to begin the new subsidiary's name with the word "Continental." Nothing could be further than the truth; the new company had absolutely no assets.

This fiction is accepted more often than not, because what we used to call in the military, attention to detail, is generally not a strong point, even in the world of finance, due to the speed with which transactions are processed. Money launderers also give them a little bit of help:

(1) If using a name that could be interpreted as a subsidiary of a well-known global company, you form it in an obscure offshore jurisdiction where you can later artfully omit "Ltd." or "Limited" from the name, or put in small print that goes unnoticed.

(2) Sometimes, you use the same colour scheme as the real company on your stationary, cheques, and even webpage; Some money launderers have been known to even place a counterfeit logo there, to further assure the victim company or bank of its authenticity.

(3) Some laundrymen form a company with the exact same name as a legitimate one, but they do it in a jurisdiction where the real thing neither has a subsidiary, nor is doing business. You might be surprised how quickly a banker, smelling large deposits, will assist you, when he thinks that you are the vanguard of a new regional operation, by your global transnational corporation.

Is a deceptively similar name a Red Flag ? In most cases, the answer is yes. Always perform a corporate information search on such names. Some Enhanced Due Diligence investigations involve actually calling up the supposed parent company, to see whether there really is a relationship.  I recommend this, as well as looking at the online company documents, and checking out the incorporators, and initial officers and directors. Are they the same as the parent that you know ? If not, watch out.



Everyone inside Venezuela needs US Dollars, whether for international trade, to work the currency exchange operations, to hedge against the next imminent devaluation of the Bolivar, or for their upcoming move to Miami. Such a demand spawns bulk cash smuggling into, not out of, Venezuela.

Whilst we are not US Customs and Border Protection (CBP) agents, as bankers:

(1)  We know when an existing client's request for dollars is inconsistent with his trade of business.

(2) We know when a client's cash receipts, that ordinarily are deposited the same day each week, are no longer being presented, and when cheques from a new payor have taken their place.

(3) We know when clients whose business takes them to Caracas once of twice a month on average, are now visiting Venezuela twice a week.

(4) We can tell when a client has unexpected and repeated cash withdrawals, when all his previous traffic was in cheques and wire transfers.

Any client with a high volume of business transactions, whose business activity fits one or more of the above red flags, should immediately be the subject of an enhanced due diligence investigation, lest he later names the bank as a facilitator when he is arrested for bulk cash smuggling. Watch for these indicia of unusual activity.

Saturday, March 23, 2013


The United States Attorney's Office has filed a Motion in Limine* in the first of two pending money laundering cases pending against prominent El Paso attorney Marco Antonio Delgado.  In that case, it is alleged that Delgado was involved in laundering $600m for a Mexican Cartel. Whilst such motions are generally filed by defence counsel, to exclude prejudicial or inflammatory material, which could influence jury to rule against a defendant, in this case, here, it is the Government's motion. It must have grounds to believe that the defence intends to introduce such arguments.

The defendant, Marco Antonio Delgado, is reportedly an influential attorney; he was a trustee and financial benefactor at Carnegie Mellon University, of which he is a graduate, and he was involved in community matters in El Paso. The Government must have concerns that potential jurors could be sympathetic to the defendant, influenced by defence counsel, or even be moved to exhibit unfair prejudice against the Government, through artful, but improper, arguments or statements made by defence counsel during the trial.

The motion seeks to exclude:

(1) Any comments regarding a possible sentence, or other consequences faced by the defendant if convicted.
(2) Commenting to the jury that the defendant could receive a specific sentence, or jail time; that his freedom will be taken away; that the jury will be sending him to jail; that they will be taking him away from his family.
(3) Information that a government investigation against the defendant was opened, then later closed, and now reopened.
(4) Any mention of governmental misconduct, because such action must be so truly outrageous as to deny Due process, and prevent conviction on the defendant.
(5) Any inference of Selective Prosecution, whereby others were not arrested, or were given immunity from prosecution, for cooperating with the US Attorney in prosecution of others.

We will detail the response of Mr. Delgado's counsel, and the Court's subsequent ruling, as soon as they are filed. The defendant remains in pretrial confinement.

*A Motion in Limine, rarely made, is always made in advance of trial, to exclude the use. for any purpose, of certain testimony at trial; it is generally made to avoid unfair prejudice to the defendant, should certain information be admitted into evidence. 

Friday, March 22, 2013


For reasons unknown, those countries that have sanctioned Hezbollah have chosen to pointedly ignore the 92 known Hezbollah agents, who are operating in Venezuela as Hezbollah Venezuela, and Hezbollah Latin America. Their drug trafficking profits are being funneled, unimpeded, back to the Middle East  through cooperating organised crime groups in the Republic of Panama, who prefer profit to obeying global sanctions, and who know that Panamanian authorities will neither arrest them for providing material support to terrorism, nor turn them over to American law enforcement agents for extradition.

These individuals are carrying valid Venezuelan passports and Cedulas (national identification cards), using aliases that change their Lebanese family names to those Spanish surnames common in the region, making them extremely difficult for legitimate bankers to identify as terrorist organisation members. These aliases, which need to be declassified and made public by the US or Israel, together with their photographs, are critical to any effective suppression of terrorist financing. Why keep the bankers, who are the one group that could identify those transactions on a real-time basis, in the dark ?

Hezbollah's front companies operate freely in Venezuela. Their cash couriers, whose identities are known, and who are moving US Dollars into and through Caribbean offshore financial centres, do so without fear of arrest and detention. Why aren't East Caribbean law enforcement agencies made aware of these bulk cash smugglers ? These are golden opportunities to seize bulk cash shipments.

What will it take before there is some effective direct action taken, in the Western Hemisphere, against Hezbollah ? They must be laughing at the US, for sitting idly by, whilst their Venezuelan agents continue to send millions of dollars to Lebanon, and plot attacks on the United States. Has everyone forgotten the key: follow the money.


Please note that officials from the Libyan Government have arrived in Egypt, seeking the arrest and extradition of 88 Libyan PEPs, all former officials in the regime of the late Moammar Gadhafi. Many are wanted for crimes against the Libyan people for participating in military action against the Libyan Opposition in the recent civil war.

I am sure that a number of these individuals, who reportedly fled with large sums of money, have already left Egypt; they may be seeking to open accounts at your bank, claiming to be refugees from the Gadhafi regime, when in truth and in fact, they supported it to the bitter end, when they fled for their lives. The current Government of Libya's efforts to detain them cold bring them to your door, seeking to open accounts. Check out any Libyan national who appears to have a high net-worth, for wealth in Gadhafi's Libya meant collaborating with the dictator.

Apply enhanced due diligence to any and all new arrivals who have Libyan Arab accents, or offer Libyan passports for identification. Was the passport issued during the last six months of the Gadhafi regime ? Check the individual out thoroughly;  You do not want to be banking a war criminal wanted in his own country.

Thursday, March 21, 2013


The Rothstein firm bankruptcy case* continues to show us how utterly important it is for a bank to identify a possible Ponzi scheme early on, lest the subsequent damage claims by victims, and reputation damage, explode to the point where it is a danger to the bank.

The creditors of Rothstein, Rosenfeldt, Adler PA, the law firm that convicted Ponzi schemer and senior partner Scott Rothstein, employed to defraud his many victims, have taken another major step, to prevent Rothstein's principal bank, TD Bank, from entering into a global settlement which would bar any future litigation against the bank. They have moved** to convert the pending Chapter 11 Reorganisation into a Chapter 7 Liquidation, claiming that such action is in the best interests of creditors, and the estate.

The more than 55 corporate entities and individuals in the movant creditor group, who reportedly are owed more than $400m, out of filed claims totaling $470m, object to TD Bank entering into a settlement with the Trustee, whereby the bank's total exposure would be in the $55m-$72m range. The moving creditors allege that the bank's net worth is $49bn. They also note that the proposed settlement would curiously allow the bank to maintain its $132m claim, and would bar additional claims, thus discharging its liability to the fraud victims, including potential punitive damage awards.

A conversion to Chapter 7 Liquidation would end the Trustee's authority, and thereby kill the deal with TD Bank, potentially exposing it to extensive additional litigation, where, if previous court actions against the bank in this case are any indication, it would be extremely costly. One more time, the close examination of the fallout from a major bank client involved in a Ponzi scheme, that was not shown the door early on in the relationship, teaches us how dangerous it is to fail to detect fraud. Punitive damage awards can be extremely high, and the litigation could cause clients to lose faith in their bank, and close their accounts en masse.

When the Court rules on the Chapter 7 conversion motion, we shall update our readers.
*In Re: Rothstein, Rosenfeldt, Adler PA, Case No.: 09-34792-RBR (Bankr. SD FL).
**Creditors' Motion for Entry of an Order Converting the Debtor's Case to a case under Chapter 7 of the Bankruptcy Code.


The much-discussed comment this week, by the Chairman of Standard Chartered, betrays an obvious culture of "business as usual," when it comes to sanctions violations. Though retracted later by the bank's spin masters (PR staff), his quote,  that the large number of Iranian sanctions violations were all "clerical errors," insults our intelligence. That's the best he can do ? His compliance staff failed to catch all of them ? Come on, Mr. Chairman.

Individuals in command who know that their bank can handle a huge financial penalty for AML/CFT or sanctions  violations, due to their large profit picture, are laughing at regulators, as they rake in ever-increasing profits. Until those in charge are held personally liable for the repeated sins and transgressions committed by regularly and repeatedly by major international banks, the violations will continue ad infinitum.  

Wednesday, March 20, 2013


Two individuals who ran what purported to be a legitimate bulk cash courier service into the United States from Mexico, but which was an illegal operation designed to cash cheques for illegal alien workers who had no access to the banking system, have been arrested, and charged with Conspiracy to Commit Money Laundering.

Martin Gerrardo Diaz-Lopez and Enrique José Guerra Cruz, who have been ordered held under Pretrial Detention, operated a Mexican transport company, Enfoque Potosino, which purported to be lawfully shipping bulk cash, US Dollars, from casas de cambio into the United States. A Federal Public Defender has now been appointed for defendant Diaz-Lopez, but his temporary attorney was Samuel Rabin, Jr., the prominent Miami criminal defence attorney whom regular readers of this Blog will recall represented Rama Kirshna Vyasulu, the principal player in the Rosemont Financial case.

In truth and in fact, it is alleged that the notes were probably narcotics profits, exchanged for Pesos in Mexico, and moved into the Continental United States by the defendants. Ever since Mexico strengthened its laws, narcotics traffickers have been unable to bank their narcodollars in Mexican banks and money service businesses; They must find a cooperating business outside the country.

Two companies controlled by the defendants, Relma Corporation, and FinTrade Corp., both located in El Paso, Texas, operated as unlicensed money transmitters. The funds went from Mexico to Texas, and were then shipped to Miami, where they were used to cash payroll cheques of illegal alien workers, who could not themselves cash them at local banks, due to their lack of legal immigration status. Local supermarkets were employed, as agents. The funds from the cheques, less fees, were then wired to the defendants' El Paso companies.  Diaz' son, Marco Diaz, was reportedly the actual courier.

The arrests were made by the HSI Money Laundering Task Force. Note that the indictment is being prosecuted by AUSA Richard Gregorie,  a senior attorney who has a history of being involved in only the most important cases filed in the Southern District of Florida, indicating that this is considered a major case.

There is a forfeiture court in the Indictment for approximately $1.5m, which has reportedly been seized, which was in the possession of TransValue, Inc., of Miami, an armoured car company, and Presto Cash, of Aventura, Florida. The indictment alleges that the defendants shipments totalled $23.3m between 2011 and 2012.
* United States vs. Enrique Guerra Cruz et al, Case No.: 13-cr-20169-KMW (SD FL).

Tuesday, March 19, 2013


Allen Stanford is having major problems with the appeal of his Federal criminal conviction. His court-appointed counsel apparently failed to regularly communicate with him; he found out through his family that his appellate brief was due shortly, and that his appointed lawyer claimed that she was too busy with her caseload to complete it timely. She is a sole practitioner, with no other counsel in her office to assist her, probably not the appropriate person to undertake such a complex case, requiring the exclusive attention of counsel. Should not the Court have taken that into account ? I realise that Stanford ruined a lot of people financially, but he is entitled to effective assistance of counsel, no matter what we may think of him.

It gets worse; Stanford has been held in the Special Housing Unit, or SHU, reputedly because he was told he was under Bureau of Prisons investigation. A person in the SHU is completely locked down, and isolated from not only the general prison population, but from the outside world as well. I spent several weeks confined in one once, and an inmate is in that cell 23 hours a day. Remember that Stanford was attacked, and badly beaten, in another prison, and this may be the way the BOP insures that it does not happen again. Assisting in the preparation of your appeal would be difficult from such confined conditions.

So, from the SHU, on 13 March Stanford files a handwritten motion, unopposed by the US Attorney, to extend the time he has to file his brief, which is granted by the Court. He states that his appeal is very complex, and that his appellate rights were being violated. The Fifth Circuit has granted the motion, extending the time until September.

I know that when you plead poverty, and ask the Court to appoint counsel on appeal, you cannot expect perfection, but he needs a good attorney. Will he get one ? Stay tuned.


The high-profile case, involving prominent El Paso attorney Marco Antonio Delgado, who has been charged with laundering drug profits for Mexico's Milenio Cartel, has been set for trial on 20 May, 2013. Delgado, also known as Marco Delgado Licon, was subsequently indicted in a different case, both of which have been extensively covered on this Blog.

The United States Attorney's Office in El Paso has filed a notice of its intent to introduce into evidence business records, which include bank and telephone records, at trial. Questions have been raised as to how Delgado, who was a Confidential Informant, managed to run a money laundering operation, when he was supposedly being supervised by US law enforcement. We shall continue to follow all developments in this case, as they unfold.  


(This is another book)
David Eduardo Helmut Murcia Guzman, the twice-convicted Colombian billion dollar Ponzi schemer, is reportedly writing his autobiography, whilst he serves a long term of imprisonment in America. Though the manuscript, which he reportedly has smuggled out of the prison in installments, is not available, one of our reliable sources has indicated some of the important topics he is covering.

For obvious reasons, we have redacted the names of the criminals involved, leaving those disclosures for Sr. Murcia to make in his upcoming book. We call them the Monkey Mafia, the Pirates of Panama, and other unflattering names. I do not wish to disturb the sleep of Panama's criminal elite, but experienced Panama observers will certainly know who will shortly be losing a lot of sleep, worrying over whether they will be the subject of American indictments, for you can bet that all this information has already been given to US law enforcement, with whom Murcia is actively cooperating.

Here are his claims, all of which implicate the players for money laundering charges:

(1) A yacht sales company in Panama & Colombia received millions of dollars, in cash, from Murcia, and, according to Murcia, stole the money.

(2) Banks in Panama & Belize received millions of dollars for investment from Murcia, and did not give him documentary proof ; they later simply stole his money after his arrest and extradition to Colombia.

(3) A supermarket magnate in Panama received millions of dollars for investment; the money was later stolen.

(4) A Russian real estate group from Canada was given millions of dollars for laundering and subsequent investment; they purchased apartments and office buildings from a number of local builders, but kept the realty for themselves, spawning a number of "instant" Russian millionaires living in Panama.

(5) A real estate group in Panama, operated by an Brazilian with a penchant for fine clothing, laundered some of his millions through security firms and banks in Panama, and then absconded with his money.

(6) Murcia Guzman purchased a number of high-end luxury cars and motorcycles, but never received the titles for those vehicles.

(7) A security firm in Panama that allegedly was in partnership with one of the country's presidents, laundered the money through the purchase of office condominium units in Panama. The owner allegedly later attempted to launder $4m through an undercover law enforcement operative.

(8) Murcia invested millions in Contadora Island (Isla Contadora), for a large hotel, to be built through an Eastern European national who resided on the island. The European was reportedly a fugitive from justice on a murder warrant. Murcia lost his entire investment to the fraudster. Murcia also purchased villas and expensive lots on Contadora, but all the properties where stolen by Panamanian organised crime members.

Remember that Murcia was not just investing his own Ponzi scheme proceeds; he also invested a substantial amount of money for the Revolutionary Armed Forces of Colombia, the FARC, a designated global terrorist organisation, which raises issues of terrorist financing, as well as money laundering, amongst the recipients of Murcia's billions.

 There are many others who Murcia is including in his book, who stole his money. We will be covering these fraudsters, who are located in Panama, Colombia, New York, the State of Washington, and other jurisdictions, in additional articles to be published here; watch for them. The book will be available for sale in March 2014, just two months before the national elections in Panama.