Sunday, May 31, 2015


"For the good of the game."

If you have not yet read the complete text of the 166-page indictment in United States vs. Jeffrey Webb, et al* the FIFA case, in which many senior FIFA officials, and others, are charges in a massive indictment, with multiple counts of RICO, money laundering and wire fraud involving $150m, you do not know that only one bank, of the more than twenty specifically identified in the charges, refused to complete wire transfers of large sums for the defendants. There are others, located in Switzerland, New York, and Paraguay, to list a few, but all of these banks failed to inquire into the circumstances of the transactions, negligent acts that I call  compliance malpractice.

Senior officials of any NGO, non-profit, or similar entity, are considered to be Politically Exposed persons, or PEPs, as are individuals closely connected to them, but it appears that bank customers who were FIFA officials, or officers in other related sports entities, were given a free pass to move huge amounts of money, without question.

The banks listed in the indictment, from my review of the document, are:

Capital Bank (Panama)
Citi Private Bank
Delta National Bank & Trust Co. (Miami)
Banco do Brasil
First Citizens Bank (Trinidad & Tobago)
Barclays Bank (Cayman Islands)
Bank Ita├║ (New York City)
Bank of America
Republic Bank (Trinidad & Tobago)
First Caribbean International Bank (Bahamas)
Delta Bank (Qatar)
Intercommercial Bank (Trinidad & Tobago)
HSBC Bank (Hong Kong)
Standard Chartered Bank (New York City)
Fidelity Bank (Cayman Islands)
SunTrust Bank (Georgia)
JP Morgan Chase Bank (NYC and Miami)
Espirito Santo Bank (Miami)
Wells Fargo Bank (NYC)
Bank Hapoalim (Zurich)
Bank Julius Baer (Zurich)

None of the above banks have been charged with any crime, or regulatory violation, but one must assume that they are under the microscope somewhere, due to their role in the FIFA case. One wonders: didn't their compliance departments wonder what all these large wire transfers were for ?

Readers who wish to review the complete text of the indictment can access it here. The document is searchable, through a feature appearing on the webpage.

* Case No.: 15-CR-0252-RSD-RML (EDNY).


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