PRESIDENT OF COLOMBIA: FARC MUST DISGORGE CRIMINAL PROCEEDS FOR REHABILITATION

As we expected, and as we predicted on this blog last year, the President of Colombia, Juan Manuel Santos, has now gone on record as stating that the FARC, whom Colombians will shortly vote to approve a comprehensive settlements, must now release the billions of dollars in drug and kidnapping profits that it holds. This is now a matter of Colombian national policy, and not subject to negotiation. The money is to be used to restore damaged lives, businesses, and rehabilitate those who suffered injuries at the hands of FARC soldiers, who committed terrorist acts for 50 years.

Inasmuch as the criminal proceeds are believed to have been mostly laundered, and invested around the globe, as well as on deposit in banks of the world's tax havens, the process will take years to accomplish. It also depends upon whether some FARC leaders will then choose to keep that money for themselves, and flee, rather than face expected prison terms, for murder, kidnapping, theft, and drug trafficking. Don't expect soldiers who are, in truth and in fact, operating as career criminals, to change overnight.

Compliance officers at international banks, where wire transfers from tax haven banks, of FARC "flight capital," are most likely to transit, en route to other, more remote and obscure offshore financial centers, should watch the October vote in Colombia, closely, and thereafter alert their staff about the risk of fleeing FARC criminals, or their money launderers, moving assets to "safety." FARC so-called diplomats would be my choice to be the individuals designated for this task.

It is also important to remember that much of the FARC's cash went straight into any one of a dozen dirty, cooperating Panama city banks, and into accounts held anonymously by bearer-share corporations, or foundations, and could have gone anywhere at that point.