Monday, November 30, 2015


By now,  you have read and absorbed the news about the £72m fine levied against Barclays PLC, for compliance violations that occurred when the bank allowed wealthy Politically Exposed Persons (PEPs) to participate in a secretive billion Pound investment. The case is especially egregious, due to the fact that Barclays reportedly went to extraordinary lengths to conceal the names of the investors, keeping that information in a secret safe that staff members did not know existed, and that it applied a lower level of Due Diligence upon those individuals, than it required for PEPs.

The real tragedy here is that the United Kingdom Financial Conduct Authority (FCA) has failed to name & shame the senior officers at the bank who ran this obscene operation, and has declined to take any action against them. How are we to know whether a new hire at the bank, next year, was one of the guilty ones, who kept the PEP client names totally out of the computer databases of customers, to hide them from even other Barclays bankers ? These individuals need to be permanently banned from the global financial services industry, and to do any less shows the financial sector that they can, indeed, get away with such conduct. 

Friday, November 27, 2015


Margarita Island, Venezuela
A number of additional Canadian & American investors, who have reported that their financial advisers, known as the Cayman Gang of Four,  absconded with their money, have contacted this blogger, either in person or through counsel, and related their stories of loss, due to fraud, and breach of a fiduciary relationship. They have uniformly stated that the most egregious frauds executed by the Gang of Four were committed by Sharon Lexa Lamb, and Ryan Bateman, and that they consider the misconduct of these two fraudsters, who diverted client assets into a covert trading scheme, to be criminal acts, for which they plan to seek justice through indictment. Most observers believe that the money will never be recovered, as it has reportedly been effectively laundered in several countries.

Other victims have asserted that they were defrauded by one or more of the members of the Gang of Four, in a case unrelated to the $450m trading scam.

Some of the victims, who are planning to bring civil suits in the Cayman Islands, have requested details on the present whereabouts of Gang members Lamb, Bateman, and former Dundee Bank President Derek Buntain, all of whom are reported to be in hiding. Only Gang member Fernando Mota Mendes can be found in Grand Cayman, for service of process.

A reputable media source in the region has stated that the ultimate destination of the Gang's ringleader, Sharon Lexa Lamb, is Margarita Island (Isla Margarita), a Caribbean territory of Venezuela. Considering that international relations between the United States, and the Bolivarian Republic are extremely strained, the chances of her possible extradition in the future, to face charges in the United States, are slim to none.

Miss Lamb

Exactly why Miss Lamb would choose to relocate to Margarita is not known. Margarita is the center of radical Arab terrorist activity in Venezuela, and elements of Hezbollah, Al-Qaeda, Hamas, the FARC, and the ELN, all reside, and operate from, that location. Whether any of the other Gang of Four missing crew members are presently hiding out there, to avoid service, is not known.

Thursday, November 26, 2015


Miami Federal Detention Center
We have been getting inquires from readers, requesting an update into the status of the appeal of Richard Chichakli, the Syrian-American CPA who worked with the Russian arms trafficker, Viktor Bout. The case has generated great public interest, not only because of the defendant's ties to Bout, but due to his allegations of governmental misconduct, against both himself & Bout.

 Chichakli is still being housed at the Federal Detention Center (FDC) in downtown Miami, which is primarily a pre-trial holding facility, and not designed for permanent placement of inmates serving their sentences, unless there are special circumstances. He will not be released until June, 2017, and I can find no reason to relocate him to Miami.

 Given that Chichakli had numerous objections, regarding his inability to adequately prepare for trial, while being confined in an FDC in New York, there is clearly a question as to the propriety of his swift post-conviction transfer to Florida, which is far from the venue of his appeal, the Second Circuit, and whether it was done for punitive reasons by the BOP.

The United States has filed its brief in the appeal, and here are the pertinent point covered in the 75-page, well-documented and with profuse citations, filing. Readers who wish more detail should access the document on PACER, or at terminals available to the public at the Court.

(1)  The District Court properly admitted the Bout laptop and exhibits.
(2)  The Court properly admitted the summary exhibits, and the testimony describing them.
(3)  The Government did not suborn perjury.
(4)  The Indictment was valid.
(5)  There was no violation of the Rule of Specialty.
(6)  The appellant has no cognizable claim for ineffective assistance of counsel.
(7)  There was no instructional error.
(8)  There was nothing improper regarding the Government's references to Bout.
(9)  There was no "secret" evidence admitted against Chichakli.
(10) There were no Discovery violations.
(11) Chichakli's placement in the Special Housing Unit (SHU) was not part of the Government's trial strategy.
(12)  The District Court's Guidelines calculations were correct.
(13)  The Forfeiture order should not be disturbed.
(14)  There was no evidence of juror misconduct.

The US Attorney's Office has requested Oral Argument, which is unusual, as it generally desires to have the cases decided solely upon the briefs filed, but then again, it is a case of great public interest, with multiple issues raised by the appellant.

There is a possibility that, should the Court delay somewhat in its decision, or there be significant extensions of time granted, that the defendant could complete his sentence, and actually be released before a ruling is handed down. Can this be considered a case with political implications ? We cannot say at this time, but we will continue to follow the progress of the appeal on this blog.


Wednesday, November 25, 2015


Barracuda Networks, inc.,  a US seller of "web filtering products, including products that could be used to block or censor Internet activity, " and whose UK subsidiary sold Internet security products, and related software subscriptions, to individuals and entities in Iran, Sudan & Syria, some of whom were SDNs, was fined $38,930 by OFAC.

Although designated a non-egregious case, I disagree. These products have no benign applications, other than to keep minor children from accessing mature Internet sites.  The software damaged any democracy advocates in those countries, and prevented individuals from seeing the truth, unclouded by evil national interests that are in conflict with Western values. The officers richly deserve some Federal Prison time, and allowing this to remain a strictly civil case is a miscarriage of justice, in my humble opinion.

Add to this the fact that Barracuda Networks, Inc. had no OFAC compliance program in place, and we end up with a mere slap in the wrist, for reckless violations. You may read the complete text of the Enforcement Information for November 24, 2015, here*.

Tuesday, November 24, 2015


Ayyan Ali, regarded by many to be Pakistan's top supermodel, and who was stopped, in March, 2015, when she attempted to board a flight to Dubai, carrying an undeclared $508,000, has been charged with money laundering. While the long delay in bringing her case has often been attributed to her threats to name names, regarding her clients, she has been indicted by the Customs Court, and a hearing has been set for December.

Ali's many previous trips to the UAE, as she is now thought to have been a regular bulk cash smuggler for prominent Pakistani businessmen, has highlighted the potential role of celebrities in financial crime. Most celebrities are rarely stopped, let alone searched, when they jet around the globe, and customs agents, who are often in awe of them, are usually prone to avoid properly discharging their law enforcement duties, when confronted by a famous film or television star.

A number of international celebrities have been found to be carrying large amounts of cash, under circumstances that suggest criminal activity, including tax evasion, either for themselves, or others. Compliance officers should take that into account when bank staff has been receiving unusual requests for large amounts of cash, or the purchase of significant amounts of foreign currency; Don't let their stardom dazzle you. 

Saturday, November 21, 2015


The Brief of Appellee in the Second Circuit appeal, by the Venezuelan Ponzi schemer, Francisco Illarramendi, states that the trial judge did not commit error in its calculation of loss. The appellant, who has gone through no less than five lawyers in this case, delayed sentencing for three years with his arguments regarding the losses suffered by the victims.

The various estimates of the total loss were $382m, $300m, $380m, and $275m. The defendant's gain was estimated as $20m, but it may have been as high as $22m.

The US Attorney's office in Connecticut made these points:

(1) The District Court did not commit procedural error in calculating the loss amount under the Sentencing Guidelines.
(2) The District Court properly determined that Illarramendi's fraudulent conduct caused a very substantial loss.
(3) The District Court cautiously determined that the loss amount could not be determined with sufficient precision.
(4) The District Court acted well within its discretion, in declining to conduct an evidentiary hearing, regarding the loss amount, and the gain attribution.
(5) The District Court properly used Illarramendi's gain as an alternative measure of loss.
(6) If there was Procedural Error, it constituted Harmless Error.

The Appellant's Reply Brief is due in late December; He is currently serving a 13-year sentence.

Friday, November 20, 2015


Most compliance officers are familiar with the cases involving billions of dollars of Medicare payments fraudulently obtained by criminal organizations in Florida. Generally, the front man relocates to Cuba, where he has enjoyed immunity from extradition to US District Court in Miami. There are, however, other classes of criminals who take full advantage of the "Sugar Cane Curtain" that allows them to flee to Cuba, and enjoy the fruits of their American criminal pursuits.

The Wanted poster above illustrates a different type of criminal conspiracy; the offenders fake automobile accidents, and then, using corrupt physicians to assist them, file multiple claims against the insurance companies that cover the motor vehicles. One such criminal organization existed in South Florida; the law enforcement operation that targeted the fraudsters is called Operation Sledgehammer.

As you can see, all the principal bad actors have fled to Cuba, thereby avoiding criminal prosecution. One wonders what the position of the Government of Cuba will be, when diplomatic relations are finally normalized between the two countries ? There are a large number of fugitives from justice living in Cuba at this time. Will Cuba give them up, when sanctions are completely removed ?

Thursday, November 19, 2015


Insiders in the Cayman Islands advise that the financial pirates known as the Gang of Four, through their reputed ringleader, Sharon Lexa Lamb, purchased a yacht for the Cuban national, José Fernandez Santana, at a cost of USD$3.5m. Lamb married Santana earlier this year, in what appears to be strictly a business arrangement, resulting in Ms. Lamb receiving not only residency in the Republic of Cuba, but the right to purchase real property there.

Lamb & Santana
Exactly what services Señor Santana provides for the Gang of Four has never been verified, but he frequently sails his yacht between Cuba and Grand Cayman, and his other ports of call include a number of offshore financial centers, including the Turks & Caicos Islands. If you follow financial crime stories in the Cayman Islands, you will recall that Joshua VanDyk, who was convicted in the United States of money laundering, worked at Ryan Bateman's B & C Capital Ltd., during the time he was involved in offering tax evasion & money laundering services to American clients, moving money through TC and into the Cayman Islands. Was Santana providing illicit maritime courier services for the players in this scheme ?

Sr. Santana is known to be a Person of Interest to certain US law enforcement agencies; his intimate relationship with Ms. Lamb raises the question: what was the extent of his involvement in the $450m trading scam, allegedly perpetrated by the Four ?

For the benefits of readers who are not familiar with this scandal, the Gang of Four comprise Ms. Lamb, Derek Buntain, Ryan Bateman, and Fernando Moto Mendes. Buntain & Bateman are Canadians; Mendes has Portuguese citizenship, and Ms. Lamb is originally from the Isle of Man. All but Mendes abruptly left the Cayman Islands, and their present whereabouts are unknown, scattered to the four winds.

Wednesday, November 18, 2015


According to a reliable source close to the operation, the Trump Organization was one of the 150 targets of former Panamanian President Ricardo Martinelli's illegal audio and video surveillance system. The ex-president is facing criminal charges for his secret spying operation, which utilized sophisticated equipment, and his National Security team. Many prominent Panamanians, and their spouses, were targeted, and the affairs his staff recorded later used by Martinelli for his own ends, some of which involved blackmailing individuals into having sexual relations.

This particular subject of Martinelli's cameras and microphones, the Panama staff of the Trump Organization, was spied upon for purely commercial reasons. The conversations were delivered to longtime Martinelli associate, Gary Lundgren, a/k/a Gary James Lundgren. Mr. Lundgren reportedly used that confidential information to great advantage, in his dealings with both the Trump Organization, and Newland International Properties Corp., the developer of Trump Ocean Club.

The current location of those tapes, which were recorded in violation of Panamanian law, is not known, as well as whether multiple copies exist, but the Martinelli agents who recorded the private meetings of Trump executives may have been the primary source of this information, and leaked it, or it may have come from one of the offices of an Anti-Corruption Prosecutor, who has some of those records.

Did Gary Lundgren make certain purchases of Newland bonds*, armed with inside information ? Did he illegally acquire condominium units, through his in-house lawyer, Alcides Bartolo Peña Araya, and become a director, and later Chairman, and lead unit owner, due to confidential information ? We cannot say, but rumors continue to circulate, to the effect that Gary Lundgren covets the casino at the Trump Ocean Club. Will he get it?

Gary Lundgren

More importantly, will Trump now bring suit against Gary Lundgren ?
* Gary Lundgren purchased 15% of the total amount of Newland bonds; the source of his funds was never disclosed, but Panamanian sources assert that it was all drug cash brought in by the convicted Colombian Pyramid schemer, David Murcia Guzmán, and later stolen by Lundgren, after Murcia was deported.               


Lamb has been seen in Cuba recently
The Cayman Gang of Four, reportedly fearfully facing the legal consequences of their fraudulent actions, have sunk to a new low, even for them; they have sought to poison the victims' relationship with the major banks, and libeled them to law enforcement agencies, and government officials. The did this by sending electronic mail, which though it was disguised to appear that it came from a third party, has been traced back to their specific computers, by experts in the field of computer crime. Their letter painted an ugly picture of the victim as an unethical, career criminal, when in truth and in fact he is a retired Canadian attorney with a stellar reputation. This was done with the deliberate intent to damage his professional reputation in several countries.

Their worst offense was the illegal disclosure of one of the victim's brand-new account relationship with a Cayman Islands bank, including the account numbers, to all the recipients of the hateful email, which characterized the victim as a slumlord, tax evader, and sundry other criminal acts, none of which was true, nor has it ever been true. Obviously, the Gang of Four failed to investigate to determine whether any of these allegations were true, before publishing them, which constitutes defamation and libel. It was done to poison the financial, legal, and government sector against the victim, and to damage his reputation beyond repair.

The accounts were so new new, that only the Gang's ringleader, Sharon Lexa Lamb, had the account numbers, which she had received to purportedly refund the victim's investments. Given this open and notorious breach of Cayman bank secrecy laws, she should forever be barred from performing any financial services in the Cayman Islands, by the Cayman islands Monetary Authority, and charged with a crime.

You can now add defamation and libel to the long list of crimes the Gang of Four, and specifically Sharon Lexa Lamb, have been accused of by their many victims. 

Tuesday, November 17, 2015


Two of the victims of the Cayman Gang of Four have publicly offered to pay a $100,000 reward for any information that will lead to the arrest and conviction of the ringleader, Cayman Islands resident Sharon Lexa Lamb. Ms. Lamb reportedly left Grand Cayman, when a massive civil suit was filed against her, and Dundee Merchant Bank a/k/a Dundee Bank, and has absconded.

Should any reader wish to contact the individuals who are offering that reward, kindly email me at, and your email address and letter will be promptly forwarded to them.

Please do not disclose that information in your inquiry, only your email. Your identity will be kept strictly confidential.

Sharon Lexa Lamb is believed by most to be the leader of the Cayman Gang of Four, a group of fraudsters who reportedly stole over $450m from Canadian & American retirees and pensioners. The other members of the Gang of Four, all of who participated in the trading scam & fraud are:

(1) Ryan Bateman, the principal of B & C Capital Ltd., and Bateman Capital, Ltd., who is a fugitive from justice in the Cayman Islands.
(2) Derek Buntain, the former president of Dundee Merchant Bank. He is missing, and believe to be in hiding in Canada.
(3) Fernando Moto Mendes, the surviving director of B &  Capital Ltd. he resides in Grand Cayman.



The Deputy Foreign Minister of Russia, Mikhail Bogdanov, has publicly stated that his country does not consider Hezbollah to be a terrorist organization. This disclosure was made in connection with Russia's efforts to negotiate a political solution to the civil war in Syria, where groups not considered terrorists will be reportedly involved in the negotiations. Russia has developed a relationship of sorts with Hezbollah, and is seeking to include it as a player, together with Iran, in deciding Syria's future.

Russia justifies its position based upon these grounds:
(1) Hezbollah has never committed any terrorist acts on Russian territory. This appears to be true.
(2) Hezbollah was elected by popular vote to the Lebanese Parliament.
(3) The Lebanese Government includes cabinet members, and ministers who are Hezbollah.
(4) Hezbollah is a "legitimate socio-political force" in Lebanon. Does this mean that its social programs excuse its terrorist actions ?

Given that both the United States and the EU long ago designated Hezbollah as a terrorist organization, the Russian position. Do not expect  the Western nations, especially the US and France, both of who lost soldiers and diplomats to terrorist acts linked to Hezbollah, in Lebanon, to change their positions.

Compliance officers should be vigilant, to insure that international trade transactions with their clients are not Russian fronts for Hezbollah purchases, through Russian banks. Any shipments of goods to Russian-controlled area of Syria (Latakia) could simply be transshipped to Hezbollah, within Syria. Given the take-no-prisoners attitude demonstrated by American regulators, towards any sanctions violations involving Hezbollah, you want to be careful with payments to your bank clients, originating in Russia, but for goods and services destined for the Middle East.

Sunday, November 15, 2015


The Mexican-American fugitive, David Miguel Nanes Schnitzer, former president of Stanford Group Mexico SA de CV, which targeted wealthy Latin American investors in Alan Stanford's billion dollar Ponzi scheme, has been detained in Belize, where he was caught using a forged driver's license. The offense carries a maximum sentence of three years.  He was ordered held without bond at the Belize City Magistrate's Court; it has been reported that the US Marshals Service and INTERPOL were responsible for locating him.

Nanes was also the president of Stanford Fondos SA de CV, and a director at Stanford Bank Panama, and SIH Panama. He is wanted in Mexico, where he has been charged with breach of fiduciary duty.

Though not known to be under indictment in the United States, the Court-appointed Stanford receiver, Ralph Janvey, has a civil suit pending against him*, alleging that he, and his wife, have control over as much as $16m in Stanford Group assets. Nanes defrauded wealthy investors, primarily in Mexico, Panama & Venezuela. He operated a corporation known as Wealth Management Services, Ltd., against which the Receiver has a $12m judgment, obtained on October 1, 2014, in US District Court in Texas.

There is no information available regarding the whereabouts of Nanes' spouse, Hasibe Elizabeth Ancona-Mizrahi.
* Ralph Janvey, in his capacity as Court-Appointed Receiver of Stanford Group etc. vs. David Nanes, Case No.: 15-cv-03171-N-BG (ND TX). 


The San Francisco branch of the Federal Reserve Bank, and East West Bank, of Paradena, California, have entered into a Written Agreement regarding certain AML compliance deficiencies. The bank maintains a subsidiary in Shanghai, and representative offices, and a branch, in Hong Kong.

Readers who wish to review the complete text can access it here*.

The document provides no details regarding the AML defects that the Fed seeks to correct. There was no monetary penalty levied, nor were any officers or staff asked to leave the bank, which is usually a favorable indication. The bank has stated, through a spokesman, that it is working to remedy all the outstanding AML issues.

*Written Agreement between Federal Reserve Bank & East West Bank


With process servers hot on her trail,  Sharon Lexa Lamb, the leader of the trading scam fraudsters known as the Gang of Four, has reportedly fled the Cayman Islands. She cannot be found anywhere on the island.  Cayman immigration has no record of her departure, which means her exit was covert, and unlawful.

Lamb could have been quietly picked up in a friend's yacht, and taken to the Republic of Cuba, where she has established residency, based upon an arranged marriage to an associate who is a Cuban national, José Fernandez Santana, who is himself suspected of having moved smuggled cash and stocks that the Gang of Four had misappropriated from their victims, to the Turks & Caicos Islands, or Cuba.

Lamb & Santana
 Accounts in T & C were used by B & C Capital, Ltd. fraudsters, as a part of their $450m trading scam, whereby the victims thought their money was safe in a financial institution, but in truth and in fact, it was in the hands of Gang member Ryan Bateman, who was illegally trading with it in the United States. Is she going to meet up with Ryan Bateman, her partner in crime ?

Prior to fleeing the Cayman Islands, an upset Sharon Lexa Lamb contacted the victim who filed the first civil case against her in this matter, and offered to refund his money in full, provided that he immediately dismiss the case pending against her. She alleged that the case was "ruining her business." She did not, however volunteer to remit to him the profits generated through the use of the victim's millions.

Will the long arm of justice catch up with Sharon Lexa Lamb, and will she be required to serve a lengthy prison term, for her sins and transgressions ? We cannot say, but you will read it all here first.

Saturday, November 14, 2015



Joel Steinger, the principal owner of Mutual Benefits Corp., the world's largest life settlement company, which turned out to be a billion dollar Ponzi scheme, has filed a Reply Brief in his appeal, where he seeks to set aside his guilty plea. Steinger obtained court approval to make a late filing. Notwithstanding his guilty plea, the defendant received a 20-year sentence.

In the brief, Steinger argues that the standard appeal waiver he signed when he pled "is neither valid nor enforceable, because Mr. Steinger's self-assessment skills and ability to reason were impaired by pain, and the strong pain medication he was prescribed, and was taking for more than a year, to try to control his severe, debilitating pain from Spinal Stenosis*."

He states that his competency evaluation was conducted ten months prior to his plea agreement, factual proffers, and change of plea in open  court. He asserts that he should be permitted to proceed with the appeal of his conviction and sentence**, and that he rambled on during the sentencing hearing, because he was under the influence of strong narcotics, deaf in one ear, and with diminished hearing in the other. Steinger is requesting that his appeal waiver be found to be invalid, also his plea agreement, and that his conviction & sentence be set aside. The Government has opposed his appeal.
*Reply Brief at iii.
**Reply Brief at 3.

Research Note: United States vs. Joel Steinger, Case Nos.: 14-14081/14088 (SD FL).


Readers who intend to follow Viktor Bout's Second Circuit appeal of the trial court's denial of his motion for a new trial, upon the grounds of newly-discovered evidence, it has been docketed. Find it at:
United States vs. Viktor Bout, Case No:. 15-3592 (2nd Cir). previous articles on this blog have dealt with the issues contained in his motion, and the Court's ruling.


Lamb and Santana
For the benefit of those readers who do not work in the Cayman Islands, and thus may have no access to the filed Statement of Claim against Sharon Lexa Lamb and Dundee Merchant Bank, we are attaching a true copy for your review. Further information on the progress of the suit will appear on this blog, which shall report on all major developments as they occur.

Friday, November 13, 2015


Our reliable sources in Panama City report that the Alaskan businessman Gary Lindgren has discontinued his interview operation at the Global Bank Building downtown. Lundgren, who also goes by Gary James Lindgren, and James Gary Lundgren, abruptly shuttered his ongoing program, whereby he was auditioning "hostesses" (read that prostitutes) to provide escorts for businessmen staying in his suites at the Trump Ocean Club in Panama. It has been said that he cancelled the program after it was exposed in the media, meaning this blog.

Gary Lundgren has not visited the Continental United States for several years. The reason: he has a pending environmental case, involving the repeated discharge of pollutants into American and Canadian waters, in the Pacific Northwest, and he fears arrest, and ultimately an extended period of incarceration, should he set foot in America. Of course both the Securities & Exchange Commission, as well as tax authorities, reportedly have investigations pending against him. We have previously reported on a prior environmental decision, and those articles can be accessed on this blog. Other investigations could also may have resulted in felony criminal charges by now; No wonder he will not come home.

Lundgren has a Panamanian passport, in a name slightly different from his legal name; it was given to him by Ricardo Martinelli; both men were closely linked to the convicted Colombian pyramid/Ponzi schemer, David Eduardo Helmut Murcia Guzmán.

Whether he also faces charges in the United States, for sexual offenses, is not known, but his illegal conduct in Panama City, including paying off several of his rape victims, or the prosecutors and judges, has earned him the dubious title of "The Bill Cosby of Panama." This is not an exaggeration; he is a a career sexual predator.

We shall be closely following the case involving the Trump Organization's $75m claim against him in the International Chamber of Commerce.


Sharon Lexa Lamb, considered by most observers to be the leader of the group of Cayman Islands fraudsters known locally as the Gang of Four, has gone into hiding, apparently to evade service of the civil suit* brought by one of the victims of the Gang's trading scheme. Athough Ms. Lamb had originally agreed, with plaintiff's counsel, to accept service of process, as soon as suit was filed, she left her residence and office, for parts unknown, and is in hiding.

Lamb's attorneys, Janet Francis, and Reneé Clark, have refused to accept service on her behalf, although they have deferred all inquiries from victims and their lawyers to themselves, thereby effectively shielding Lamb from direct contact. They have repeatedly deflected queries, by stating that their client has no records, nor information, regarding the victims' funds and assets, but now that suit has been filed, they are curiously refusing to cooperate, and to act on her behalf. It is not known whether they had provided legal representation for Ms. Lamb, during the time she, and others, perpetrated the massive trading fraud, or what they role they played, if any, was, in connection with Dundee Merchant Bank, or B & C Capital, Ltd., but the investigation is continuing.

Ms. Lamb disappeared from public view, as soon as suit was filed in Grand Cayman, and courthouse resources have stated that she had an insider in the clerk's office who alerted her to the fact that a writ & summons had been issued in her name. She has not been seen in the Cayman Islands  since November 5, 2015, and the process server is unable to locate her.

 It was previously thought that she might flee to the Republic of Cuba, where she had previously engaged in an arranged marriage, to José Fernandez Santana, to obtain residency, but she is believed to still be in the Cayman Islands.  The law provides for alternate methods of effectuating service of process, which will now reportedly be employed.

Lamb & Fernandez

Investigators have concluded that Sharon Lamb, together with her lover, Ryan Bateman, stole the vast majority of the $450m-500m that is missing, and owed to the victims, American & Canadian retirees and pensioners, who believed that their assets were safe, and on deposit in a financial institution. Unfortunately, they had been transferred, through Lamb's office, as Senior Vice President of Dundee Merchant Bank, to B & C Capital Ltd., a Cayman shell company operated by the fugitive, Ryan Bateman and Fernando Mota Mendes, who, together with Dundee Merchant Bank President Derek Buntain, comprise the Cayman Gang of Four.

Ryan Bateman (fugitive)

Lamb also has a paramour who works in the offices of the Royal Cayman Islands Police Service, and rumors continue to fly, to the effect that she has been able to stall the filing of criminal charges for that reason. She told witnesses that she is deathly afraid of a prison sentence; the correctional facilities in Grand Cayman, deemed by many to be sub-standard, are apparently the reason.

She should really fear the US criminal justice system, for the victims have been giving evidence to American law enforcement agencies, and her movement of criminal proceeds could result in her indictment, in Federal Court in the United States, for money laundering, which is a 20-year felony. Bateman and the other Gang members, having engaged in covert securities trades in the US, are also definitely subject to money laundering charges there.

We shall update our readers on this case, to include all important developments, as they  occur.

* Case No.: 202 of 2015, in the Grand Court of the Cayman Islands. The defendants are Sharon Lexa Lamb and Dundee Merchant Bank.

Thursday, November 12, 2015


The New York State Department of Financial Regulation, which is one of the most effective anti-money laundering, and anti-sanctions, government agencies in operation, should break protocol, and name & shame the bankers as Deutsche Bank who gleefully, and obscenely, managed the sanctions evasion program at the bank for many years, allowing Iran, Syria & Sudan access to the American financial structure. These people need to be outed, for the protection  of the rest of the banking industry.

the bad actors ran an extremely efficient sanctions evasion program; they zealously protected what was a criminal conspiracy, deleting and altering information that would have alerted American bankers to their illegal wire transfers. If you have not yet read, in detail, about this organized misconduct, you should visit the NYSDFS website, and read how they deceived the global banking industry .

Remember, it is not just former employees, who had resigned or been terminated, but those not disciplined, and merely transferred to other divisions, within the bank. We need all those names, please, and from them we can locate photographs of the offenders. Every last one of them should be permanently banned from any financial services position; let them go find work in Syria, whose civil war they prolonged by their actions.

Wednesday, November 11, 2015


Viktor Bout
Alexey Tarasov, the Russian-American attorney representing Viktor Bout, has filed a notice of Appeal from the trial judge's order denying his motion for a new trial, based upon newly-discovered evidence. Tarasov had previously announced his intention to do so, on behalf of his client. Readers who are interested in the grounds that were asserted by Bout, in seeking a new trial, are directed to review the prior articles appearing on this blog, as they cover the issues in detail.

The case has been surrounded by controversy, including claims of entrapment, and unlawful targeting of the defendant, who had ties to the American intelligence community, as well as to arms trafficking in the developing world. His original conviction was affirmed by the Second Circuit Court of Appeals.


Those who forget the lessons of history are doomed to repeat it. Take a moment to reflect and to remember.

Tuesday, November 10, 2015


The Bank of Nova Scotia, through both its Canadian headquarters, and its New York agency, has executed what amounts to a Consent Agreement with the New York branch of the Federal Reserve Bank, and the New York State Department of Financial Services (DFS), to correct deficiencies in the bank's BSA/AML compliance program, Customer Due Diligence. OFAC compliance, and SAR monitoring and reporting.

Readers who wish to review the complete text of the Agreement, can access it here*. Unlike most other agreements with the Fed and NYDFS, there was no monetary penalty levied upon the bank.


Trump's case against Gary Lundgren, which demands millions of dollars in damages, regarding Lundgren's illegal taking of control of management, at Trump Ocean Club International Hotel & Tower, may now add an additional claim, because of Lundgren's intent to walk on the wild side. Gary Lundgren, who is the owner of the largest number of units in the complex, is currently conducting interviews, of Colombian hookers, for his new Trump project, which he has apparently patterned after similar arrangements that exist in certain Hong Kong hotels. If Gary Lundgren is obsessed about anything in life, it is about sex, for he has the record to prove it, and now he wants to make money out of it. His wife, whom he has offered up to be the manager of the Trump, is to be the supervisor/madam of the venture.

Lundgren intends to offer visiting businessmen exclusive service, when staying at the suites at the Trump that he controls, including full-time access to prostitutes, who will also serve as hostesses to the individual guests of Lundgren's suites, which he calls lofts. Though rarely enforced, the laws against prostitution remain on the books in the Republic of Panama. Lundgen's arrogance continues to surprise businessmen in Panama, many of whom believe that the case involving his illegal actions at the Trump Ocean Club will end his sordid business career in Panama.

It is common knowledge that the Organization has an established policy of prohibiting prostitutes in its signature hotels and resorts, so this new information is sure to be poorly received by Trump, and his senior management. Certainly, the introduction of a criminal enterprise (Gary Lundgren is to receive a portion of the hookers' income) is a violation of condominium rules & regulations, as well as several other Panamanian laws.

Donald Trump is a candidate for the nomination, by the Republican Party, to be the candidate for President of the United States, and Gary Lundgren is seeking to create a program, at a Trump landmark in Panama, that could result in serious reputation damage to his campaign. Look for Lundgren's pimping project at the Trump to be dead on arrival. As soon as his advisers hear about it, they will kill it permanently.

Monday, November 9, 2015


If you have been following Haitian politics, you know that trouble is coming. The ongoing presidential election process in the Republic, reportedly again fatally flawed with election fraud, has a very good chance of resulting a popular explosion that will threaten domestic stability, and seriously damage a fragile and frail economy.

The candidate who is the designated favorite of the outgoing president is said to have received the largest popular vote in the election, but still insufficient to carry the day, which means that there will be a runoff election. The problem is, most observers believe that many of the votes cast for the front runner were fraudulent, and that he has absolutely no place in the runoff.

Is is feared that the blow back from the rampant election fraud will result in a chaotic domestic situation. Indeed, some seasoned observers of the Haitian political scene, worry that widespread violence will break out, and that ultimately, President Martelly will not serve out his term. Yes, it is that serious.

If Haiti reverts, once again, to the cycle of violence, there is no place for any capital investment, financial exposure, or even international trade. When you must worry about being able to visit a local bank, without being at risk for robbery or attack in the street, you know you have no business operating in that country, and if the situation deteriorates, as is expected, it will happen .

It has been my experience to have worked on bank compliance projects in Haiti, lectured at conferences there, and worked with government agencies in the capital, and I only wish Haiti the best in the future, but this current threat to stability unfortunately compels me to raise Country Risk on the Republic of Haiti to the highest level, which is a total bar to any financial, trade, or commercial, transactions, and to incurring any financial exposure, until we see a post-election normalcy established, with a government that the people are happy with.      

Sunday, November 8, 2015


The Alaskan fraudster operating in anything-goes Panama, Gary James Lundgren, reeling from the publicity generated by the high-profile case against him, filed by the Trump Organization, has begun closing down his dodgy operations. Lundgren, who has obviously tired of evading all the angry investors whom he has stopped paying an 8% per month return to, faces an uncertain future, due to multiple investigations reportedly pending against him. He refuses to personally meet clients, for fear that he will suffer physical harm at the hands of clients who have threatened him; he takes various, circuitous, routes to his office each day, and has increased security there.

In the Republic of Panama, his securities company, an unlicensed Panamanian branch of his US company, Interpacific Investors Services, has been ordered closed by the Government of Panama. In the United States, his business in Washington State is transferring all its existing clients to a national securities firm, and closing up its broker-dealer operations, as verified by a press release, making the announcement, though the company receiving this business may want to reexamine the situation.

The steep decline in new tenants, coming into Panama, due to the change in economic activity, and the public perception of a major increase in street crime, has resulted in a large number of vacant condominiums that he controls, meaning that his cash flow has been severely reduced. He has a number of civil suits pending against him in the Republic of Panama, and some of his victims, who allege he is guilty of sexual battery, are exploring their legal options.

Will the United States request the extradition of Mr. Lundgren, for securities violations, or will Panama do the honors, for the Petaquilla Mine scandal ? We cannot say, but his problems have multiplied exponentially in 2015.


Innovative money launderers are constantly on alert for new, and safe, methods of cleaning their clients' proceeds of crime, and of making a return on their "investment" in the process. It was only when a drug-laden smuggling vessel was seized off the coast of California, that US law enforcement learned about the abuse of Life Settlements, the secondary market for life insurance policies, by an insurance agent who was a laundryman in Colombia; we often learn too late about new avenues to launder illicit profits.

The proliferation of litigation financing, also known as litigation funding, in high-stakes civil lawsuits in the United States, should concern trial lawyers, not for ethical reasons, though there are valid issues, but because outside financing of their expensive major cases might be coming from a source of funds that they definitely do not want to accept; money launderers.

Litigation financing occurs in major products liability, personal injury, or several other types of lawsuits, especially where the defendant, or its insurer, has a deep pocket to defend the case. Depositions, pretrial discovery, motions, experts, consultants, investigations, all cost money, and some defense lawyers try to bankrupt litigants, through years of litigation, to force settlements, or even dismissal of cases against their clients.

It is logical that clients with limited means would seek out funding sources, to obtain non-recourse advance funding of pretrial, and trial, litigation costs. the problem is that the law has not yet caught up with this emerging field, and there is no requirement that the Source of Funds, or Beneficial Owner, behind such funding companies be disclosed, or obtained through due diligence. Since many offshore hedge funds are getting involved, why not domicile the "lenders" of the funds, to the bogus litigation finance company overseas as well. The lawyers, happy that their costs will be paid in advance, will not examine the golden goose.

Any good money launderer worth his salt could create a company that looks like a legitimate business, and borrows money, to lend out to law firms, for their clients' litigation finance needs. In truth and in fact, the captive litigation finance company is a shell, and it "borrows" funds from other shell companies owned and controlled by the money launderer, and funnels criminal proceeds into the lawsuit. After settlement of the case, a check, or wire transfer, from the winner's law firm will rarely, if ever, be subject to any regulatory, or law enforcement, scrutiny.

Only if the law firms conduct enhanced due diligence, in advance, will the wheat be separated from the straw, and illegitimate finding sources be unmasked, and refused. One wonders how many major civil cases have already been funded with drug profits.