Tuesday, October 7, 2014


You may recall that, in 2008, the Armed Forces of Colombia, in a cross-border raid upon a FARC camp inside Ecuador, killed Raúl Reyes, the FARC second in command, and seized several laptop computers, containing operational details of the FARC. The Colombian Government, with a few exceptions, has failed to declassify the intelligence contained on those computers, which includes detailed information regarding the FARC's global financial operations. Colombian courts have ruled that the information is no admissible in criminal cases, due to then inability to authenticate it, and the fact that it was seized outside Colombia, and it remains, for the most part, classified, and unavailable to the financial community.

What little information has been released is alarming:

(1) The FARC financially supported the election campaign of Ecuador's president, Rafael Correa.
(2) Senior Ecuadorian military officers have worked directly with the FARC.
(3) Senior Venezuelan ministers were in contact with FARC leadership, providing material support to terrorism.

The parties at risk, due to Colombia's continued restrictions on releasing the information contained on the FARC laptops, are financial institutions in the United States. Ecuadorian and Venezuelan PEPs, who appear in that intelligence, as assisting the FARC, may have bank accounts in the United States, and may be using those accounts to facilitate their work with the FARC. Should any of this surface, in an investigation conducted by American law enforcement agencies, these banks stand to be hit with major civil fines and penalties, with the attendant reputation risk, as well as potential criminal charges.

 It does not make sense, that six years later, we still do not know whose names are contained in those FARC laptops. Colombian cannot use that intel against its own citizens, and sufficient time has certainly elapsed for the development of investigations, based upon that data. American banks should know the names of all the Latin American PEPs who work with the FARC, and Colombia's stubborn and unjustified retention of that information, hurts any banks who are unaware that their customers are linked to a designated global terrorist organization.

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