Friday, August 31, 2018


Is your new wealthy client a PEP, or isn't he  ? He claims to be the CEO of a large company in a foreign country not known for transparency; is he really a senior colonel in his nation's military, and the head of a government-controlled company, but he is really masquerading as a civilian executive ?

You can unmask him if you have the right equipment in your compliance toolbox.

We have all read the Congressional testimony about Facebook's use of what is known as Shadow Profiling; accumulating information on individuals who are not on Facebook, through their online activity when they visit facebook sites. This technique can be a valuable compliance tool for identifying foreign Politically Exposed Persons (PEPs).

Compliance officers who are tasked with eliminating prospective clients as Politically Exposed Persons (PEPs) can adapt Social media sources and methods, even though the target is not a user or participant of social media sites. It is accompliahed by using facial recognition software programs that have total access to social media resources. A target may not be personally engaged on social media, but his photograph has most likely been taken at a charitable event, holiday party, major social encounter, private party or dinner among close friends, and facial recognition software, if employed, will extract his images from social media pages, newspaper stories, blogs, websites and CCTV footage.. Was the colonel in civilian clothes at all these functions ? I doubt it, for he was not aware that his off-duty activities have been recorded and accessed at what were private events, out of the public eye.

Whether the individual is a corrupt foreign government official taking bribes or kickbacks at home, military officer stealing from government accounts, a leader of an NGO or charitable organization, suchindividuals wish to conceal their PEP status, but compliance officers can identify them by the proper use of facial recognition software programs that have access to social media resources. It is the only way to unmask a well-concealed PEP seeking to hide his illicit wealth by posing as an affluent foreign national attempting to open an account at your bank.


Shi'ite military organizationas in the Republic of Iraq have reportedly received ballistic missiles from the Government of Iran, in a disturbing development that could see Iraq being drawn into a regional war with Saudi Arabia, or Israel, resulting in chaos within its financial structure. Though these weapons are said to be only intermediate-range missiles, they could still hit Riyadh or Jerusalem, provoking a massive response.

The presence of American troops in Iraq, assisting in the mopping up of pockets of ISIS resistance, further complicates the picture, for attacks on US military units in a future Middle East conflict could embroil America as a participant, with potentially devastating effect upon Iraqi infrastructure. 

Iraq's poor economy might not recover from yet another war; in addition to the missile shipments, Iran has allegedly supervised the opening of weapons factories, capable of manufacturing missiles within Iraq. What if Israel regards them as threats, and attacks them ?

Given the increased possibility that Iraq will be drawn into the next war in the area, raise Country Risk at this time, after you have assessed the situation. Foreign investment, and indeed any substantial extension of credit,  could result in a total loss, in the aftermath of a third, and more destructive, war in the region.

Thursday, August 30, 2018


Jho Low a/k/a Low Taek Jho

Jho Low, the fugitive Malysian fnaancier accused of stealing billions from the Malaysian sovereign fund known as 1MDB, and who is currently a fugitive from justice, thanks in part to his St Kitts CBI passport, is under US Department of Justice investigation, due to his links to a support network composed of associates of President Donald Trump. Additionally, Jho may have given laundered criminal proceeds to pay his Ameerican attorneys, includiing former New Jersey Governor Chris Christie.

Jho's associates have allegedly called upon close Trump friend and fundraiser,  Elliott Broidy, to assist him. Jho, also known as Low Teak Jho, allegedly took $4.5bn from the 1 Malaysian Development Berhad, and laundered it through the global banking system. It is not known whether any of those proceeds of crime ended up in St Kitts' banks, but legal observers in Malaysia believe Jho is attempting to reach St Kitts, which provides a non-extraditable safe haven for its citizens, CBI passport holders included.

Questions have been raised regarding how St Kitts approved Jho's CBI application, given the circumstances surrounding the billion dollar theft in which he was the primary player, according to Malaysian government authorities.

Wednesday, August 29, 2018


Leroy King and his patron, Allen Stanford
After a decade of evading extradition to face the music in the United States in the billion dollar Stanford International Bank scandal, Leroy King, the cashiered Antiguan banking regulator, is said to be seriously ill, and it is doubtful that he will live long enough to see the inside of a Federal courtroom in the United States, thereby cheating justice.

King's extradition case, which has been a textbook example of how to indefinitely delay court proceedings in a corrupt third world setting, may not have a satisfactory ending, but Karma now seems to have intervened. Had Mr. King agreed to be extradited, years ago, he would have quickly been examined, and received outstanding medical care while in the custody of the US Bureau of Prisons, probably saving his life. We wonder if this fact has occurred to Mr. King.

Will Mehul Choksi (a/k/a Jabba the Hut), also hiding out in Antigua, also fall victim to Karma ? We cannot say, but given his obvious health issues, he may also fail to be extradited from Antigua. Stay tuned.



The recent arrest, of a career criminal from Pakistan, known to be the personal assistant to one of the world's most wanted fugitives from justice, has again spotlighted the dark fact that he is yet another wanted individual, who the Antigua CBI unit knew or should have known was legally unqualified wor a CBI passport, yet received one nevertheless, in a country where abject greed trumps the Rule of Law. He holds a CBI passport from Antigua & Barbuda, although he is a wanted fugitive in the United States.

Jabir Motiwala, arrested by Scotland Yard on an American, request, is also known as Jabir Siddiq. He works for Kaskar Dawood Ibrahim, a major Pakistani drug kingpin and known terrorist. Motiwala reportedly is wanted in the United States on charges of money laundering, extortion, kidnapping and drug trafficking. He had been living in Dubai, and was detained after he entered the United Kingdom.

Under what perversion of the regulations governing CBI passports issued by Antigua did this career criminal pass even the most primitive due diligence check ? Obviously, in Antigua, so long as you agree to pay a clearly excessive fee, over and above the listed charges, you will qualify for a CBI passport, even if you are known to be engaged in criminal or terrorist activities.

In the aftermath of the Choksi scandal, Antigua sustains yet one more black eye for its CBI program, which is regarded by compliance officers in North America and Europe as a government-operated racketeering enterprise. Any individual holding an Antiguan passport suspected of being a CBI-issued document is now subject to serious scrutiny.

Tuesday, August 28, 2018


Donald Trump and Scott Rothstein

The brief of the United States, in Scott Rothstein's Eleventh Circuit appeal of the District Court's order allowing the US Attorney to withdraw its pending Rule 35 motion to reduce his 50-year sentence only contained one issue:

"Whether the District Court Properly granted the Government's request to Withdraw its previously filed Motion for Reduction of Sentence, after the Court correctly concluded that the  Government had the Discretion under the Plea Agreement to withdraw the Motion."

While the Plea Agreement does not specifically empower the Government to withdraw their Rule 35 motion to reduce Rothstein's sentence, it does give it sole discretion regarding whether or not to reduce his sentence. Additionally, case law is well settled regarding that discretion, and the courts have uniformly agreed that, under basic contract law, the Government is within its discetion, when deciding whether to reduce an inmate's sentence.

The chances that Scott Rothstein will be successful in his appeal are small, due to the above well-settled questions of law. Whether the fact that Rothstein forged the signatures of Florida and Federal judges, in crafting bogus court orders and judgments will influence the appeal court cannot be quantified, but as it was an aggravating factor in his criminal trial, it certainly marked him as a public enemy. We will advise our reades further when a decision is handed down.


Monday, August 27, 2018


Now that the United States has reimposed sanctions upon Iran, agents of that country's government are setting up shop next door, in Canada, to operate evasion programs aimed at acquiring and moving US Dollars, and in conducting prohibited international trade transactions. Today we will focus upon the illegal use of prepaid cards as instruments that Iran has sought to use in the recent past*, and is currently seeking to employ to evade US sanctions, and to conceal illicit operations from US law enforcement agencies, and regulators.

Canada's immigration-friendly policies, together with the country's known reluctance to publicly name and shame financial institutions with ineffective anti-money laundering regimes, have long made its financial centers a favored destination for Iranians engaged in illicit activities, whether they be financial criminals or government agents acting undercover. The fact that the present government has been friendly to Iran, and has turned a blind eye to suspicious Iranian investments in Canada is an additional factor that cannot be ignored.

Due to industry pressure, and frankly, regulatory indifference, prepaid cards continue to be a major resource for sanctions evaders, money launderers, and bulk cash smugglers. We have identified two ongoing operations, located in the Province of Ontario; they are recently-formed money service businesses, controlled and openly led by Iranian nationals with a long history of suspected money laundering activities, or operations as intelligence agents of Iran, or both. Their stated business is the sale and distribution of prepaid cards to the public, but their true objective is the movement of dollars, in support of Iran's global sanctions evasion program, whether that be the purchase of prohibited dual-use goods, or to facilitate the transfer of restricted Western technology to Iran.

How can these Canadian MSBs interact with the US financial structure, you ask ? They have partnered up with a prominent American bank well known as a prepaid card distributor. The American bank is telling its customers and vendors that it will be selling prepaid cards, in bulk, to dual nationals, who it has decided to regard as non-Iranian nationals, for the purpose of the sanctions laws. This is, of course, utter nonsense from a legal viewpoint, and not supported by any interpretation of the law that we are aware of.

Furthermore, the American bank involved with the Canadian companies has a history of problems in the past with US regulators, especially in the anti-money laundering sector. Senior bank management has pushed its staff, especially compliance and IT, into cooperating with the Canadian companies, reportedly against their better judgment. The joint operation should be shut down before it can begin to move dollars in and out of the United States, and further Iran's illegal WMD and ballistic missile programs. If you know the prepaid card field, you should have an idea who the bank is, and steer clear of it in the future.

While we fear that Canadian regulatory agencies will ignore this information, and we will not hear from them, we trust that their American counterparts will take the hint, and open investigations forthwith into this brazen, and illegal, sanctions evasion scheme. Prepaid cards are not to be used as instruments of sanctions evasion.
* A few years ago, in the midst of major sanctions, some of these same Iranian nationals sought to purchase an interest in a Panamanian money service business, where the "clients" would be provided with mailing addresses in the Republic of Panama, to avoid being identified as Iranian nationals.


The master Malaysian criminal, Jho Low*, who is busy evading arrest with his handy little St Kitts CBI passport, has been charged with seven counts of money laundering. Low has been accused of being a key player in the theft of $4.5bn from the government investment fund, known as 1 Malaysian Development Berhad (1MDB), which local media there have dubbed the country's biggest white collar crime in its history.

The fraudster who also known as Low Taek Jho, is believed to have escaped via China, and Malaysian authorities believe he is attempting to reach the safety of St Kitts & Nevis, from which his citizenship will effectively guarantee immunity from extradition, and he will never face justice in Malaysia.

Low Hock Peng, the defendant's father, has been charged with one count of money laundering; it is not known if he also holds a St Kitts CBI pssport as well. 
*St Kitts sold CBI Passport to Buyer from Malaysia, which prohibits Dual Citizenship

Sunday, August 26, 2018


The Government of Antigua & Barbuda, as part of its continuing non-cooperation with India, which is seeking the extradition of its fugitive billionaire. Mehul Choksi, has refused to divulge Choksi's home address in Antigua, where he has been living a lavish lifestyle. Antigua failed to deliver the address upon demand, which indicates that it will protect him, notwithstanding his status as the most wanted man in India. India has reportedly asked the US for assistance, but the decade-old Leroy King extradition to the US is still pending, so it is doubtful that America can facilitate the Choksi case.

As the consequence of its policy of non-cooperation, Antigua's standing among CBI providers has reportedly fallen from first place to fourth in a recent ranking.Voters in Antigua are angry about how their country's image is being degraded internationally, due to the Choksi scandal, and their Prime Minister appears to be the primary protector of this fugitive from justice.     

Thursday, August 23, 2018


Readers who are interested in details of the proposed Government of Anguilla Residency by Investment (RBI) program may wish to listen to a meeting, called by Government, to explain it, at 6 PM, Eastern Time. Watch at

You may also tune in to any one of these local stations; not all of them have confirmed that they will carry it live.    


Above please see yet another of those so-called ratings or indexes of the jurisdictions offering Citizenship by Investment (CBI-CIP) programs, which sell foreign investors valid passports issued by the participating countries. For a number of reasons, not only are the rankings skewed in favor of the East Caribbean stattes (all five of them curiously hold the first five positions on the list) but the calculations do not take into account any possible negative factors. They are therefore inaccurate and misleading, and only serve as selling points in international CBI consultancies' marketing programs.

Here's a short list of what factors are not used in compiling the lists. The most important indicator of the value of a specific CBI program seems to be the number of countries one may visit, without the necessity of acquiring a visa in advance. This would indicate that the sole criteria of importance is the ability to enter  multiple nations without being cleared through a visa application process. What type of individual requires that benefit ? Obviously criminal elements.

Here is my list:

(1) Applicants do not know that a specific CBI jurisdiction was, or is, a known tax haven a/k/a offsshore financial center, where corporation secrecy and/or bank secrecy is the law, is never discussed. This is like painting a bull's eye target on your back, for Western law enforcement agencies, who have a long memory regarding tax havens used for illicit purposes.

(2) Investors are not told that the issuing country can revoke your passport and citizenship privileges at will, and you have little or no legal recourse, inasmuch as the local court system does generally follow only political direction, and not the rule of law. Several of the jurisdictions are not true democracies, due to massive voter fraud and bribery programs conducted each election day.

(3) CBI Applicants do not know how many financial criminals, international sanctions evaders, corrupt PEPs, fugitive from justice abroad also hold the passport you have purchased.

(4) Applicants are not told about the stability, or lack of it, regarding the local economy, ruling political party in power, security situation, external influences, and visa waivers, any one of which could result in the collapse of the CBI program, or the mass cancellation of passports issued pursuant to its authority, or the serious diminution in their value to the holder.

The bottom line: a CBI passport, issued by an Eastern Caribbean state, may not be as durable as one issued by a European CBI jurisdiction, when one compares political stability, but the European jurisdictions are ranked delow all the East Caribbean ones. We wonder how that happened.

Wednesday, August 22, 2018


 A senior government official, from one of the five East Caribbean states that are operating Citizenship by Investment (CBI/CIP) programs, has been engaged in negotiations with a law enforcement agency of the US Government, to cooperate in a pending investigation. That individual is seeking immunity from prosecution, in what appears to be a major corruption investigation of high-ranking government officials in one jurisdiction.

Additionally, one of the principal targets of the investigation is the prime minister of that unspecified East Caribbean state. While much has been made this year, of the alleged failure of the United States to charge Caribbean officials with corruption, especially when the proceeds of their crimes are deposited in American financial institutions, we recently saw one individual charged. Donville Inniss, the former Minister of Industry for Barbados, is facing money laundering, and conspiracy to commit money laundering, for accepting bribes to obtain lucrative insurance contracts for Barbados.

While we certainly do not wish to alert the targets, as they could flee the region, to avoid arrest and prosecution, the CBI states are:

(1) Antigua & Barbuda.
(2) St Kitts & Nevis.
(3) Dominica.
(4) St Lucia.
(5) Grenada.

When indictments are handed down in the matter, we shall update this developing story accordingly.

Tuesday, August 21, 2018


Readers who were confused about exactly how much prison time, fines, court assessment, and restititution, Trump's personal attorney, Michael Cohen, has agreed to, below please find two pages below from the letter which is the basis for his guilty plea.


Tax havens apparently do more than cheat countries out of tax revenues. A study from the publication Nature Ecology & Evolution has reported that corporate secrecy jurisdictions are being used to conceal the beneficial ownership of commercial activities that are destructive to the environment

The white paper concludes that offshore financial centers that have strict secrecy laws form corporations used to register vessels engaged in illegal overfishing on the high seas, and destructive land use in the Amazon Rainforest. The information, which was culled by researchers from the Panama Papers and the Paradise Papers, was a major source of previously-unavailable data on beneficial ownership.

Specifically named as jurisdictions that have formed opaque companies for businesses that are causing serious ecological damage to the environment were:

(1) The Netherlands Antilles (Rainforest damage).
(2) The Cayman Islands ( Rainforest damage).
(3) The Bahama Islands (Rainforest damage).
(4) Belize (illegal fishing).
(5) The Republic of Panama (illegal fishing).

Compliance officers should always inquire into the specific lines of the client's business, when opening a banking relationship for a corporation from the above jurisdictions, to insure that they do not unwittingly accept illicit profits, earned at the expense of environmental damage, as the possible negative press that could result from the public disclosure of such a client relationship might clause legitimate clients to close their accounts, and bank elsewhere.

Sunday, August 19, 2018


Nidal Waked Hatum

Attorneys for convicted Panamanian money laundering kingpin, Nidal Waked Hatum, have requested, and received, substantial additional time to file their brief on his behalf, in the pending Government appeal of the denial of entry of a $20m forfeiture order against Waked. The trial judge, after sentencing Waked to a term of imprisonment, which he has already served and been returned to his native Panama, declined to enter a fortfeiture for reason that the Government has contended was reversible error. The Government has made a convincing case for reversal.

What is troubling about the delay is the fact that counsel for Waked is not a sole practitioner, but a member of a major criminal defense law firm, with a number of other lawyers also available to be   attorney of record, any one of whom  is competent to write a brief. The longer a final decision on the appeal is delayed, the easier it is for Waked, shown to be one of Panana's most experienced money launderers, to move assets, and therefore to insure that the United States will never be able to recover on a forfeiture order, when it is eventually entered. 


St. Johns, Antigua

During my misspent youth as a money launderer, in the "Miami Vice" era of the 1980s, the US Government alleged that I had spent a couple of weeks operating from a Caribbean tax haven. It reached that conclusion based upon the fact that there was no evidence to show that I had exited that jurisdiction. In truth and in fact, investigators had simply failed to find the arrival/departure card that i had surrendered when it left,

What if law enforcement investigators were then able to track and trace my movements there, in and out of a dodgy attorney's offices, and into an offshore bank, with narcotrafficking clients in tow ? That may sound like science fiction, but due to the unique advantages offered by facial recognition software platforms, it is now within the ability of  law enforcement agencies, should they choose to avail themselves of its features.

To understand how this is a real possibility, we need first to be aware of the expanding global nature of the rapidly expanding use of CCTV, for the purposes of tactical crime suppression. You may not know that the coverage is no longer limited to Central London, which you certainly have seen up close when visiting, but it is now widespread:

George Town, Grand Cayman
(1) Caribbean tax havens, faced with an unwanted increase in street crime, have vastly increased the number of CCTV cameras in downtown urban areas. These also happen to be the locations of offshore banking facilities, attorneys' offices, and the financial services firms who form shell companies.

(2) The Peoples' Republic of China has the largest closed circuit monitoring system in the world, with over 170 million cameras; it is slated to expand to 400 million by 2020, and its system paid CCTV with an advanced facial recognition software platform that was able to locate a BBC reporter in seven minutes, in a test of its capabilities.

(3) China, as well as other countries, including the UK, Germany and several manufacturing centers in the European Union, are exporting vast number of surveillance systems to governments in the Middle East, Asia, and Latin America. The result will eventually be a global network of CCTV  footage potentially available to law enforcement agencies looking for specific money launderers and financial criminals.

Basseterre, St. Kitts

Will the US Drug Enforcement Administration (DEA) soon be tracking the movements of a known money launderer, as he traverses the downtown area of a tax haven jurisdiction's capital city, in and out of offices, on a particular day, to prove that he was engaged in bulk cash smuggling ? What about the FBI, actually following a Ponzi schemer down the street of an offshore financial center, in real-time ?  These are not sheer fantasies, but the artful use of facial recognition software programs to conduct successful money laundering investigations. It could vastly improve the ability of law enforcement to track and trace criminal activities abroad.

Saturday, August 18, 2018


Rather than relying upon the minimal details regarding the lies that Trump foreign policy advisor George Papadopoulos told the Federal Bureau of Investigation, readers should review the complete facts that are only available in the ten page Government's Sentencing Memorandum. You may access it here.


The Government of India is relying upon the United Nations Convention against Corruption to compel Antigua & Barbuda to extradite the $2bn fugitive fraudster Mehul Choksi from Antigua, where he has been evading arrest, based upon a CBI passport he reportedly bought for $2.5m.  The UN treaty, of which India and Antigua are signatories, applies where the crimes charged are offenses in both countries. Choksi was the alleged mastermind of the billion dollar scam perpetrated against state-owned Punjab National Bank, and if India had a "Most Wanted" list, he would be the number one target.

Antigua's "Jabba the Hutt" Mehul Choksi
Antigua appears to be already sowing the seeds of delay; it is refusing to move forward with the extradition until the Public Prosecutor is back on duty, and he has curiously been allowed to take an extended holiday. Also, an attorney closely connected to the government, David Dorsett, is presently representing Choksi, and since he has denied that his client was involved in any criminal conduct, you can expect his representation to include diatory action. It is believed he will follow the decade-long pattern employed by lawyers for the fugitive former Antigua banking regulator, Leroy King, who faces a probable life sentence in the United States, in the Stanford International Bank billion dollar Ponzi scheme.

The Choksi case is the latest in a long line of scandals  involving Citizenship by Investment (CBI) passsports being sold by Antigua to fugitive career criminals, money launderers, international sanctions evaders, and corrupt foreign government officials, who run afowl of the law. Antiguans fear that their country's passport will eventually become unwelcome in Europe and North America, due to the increasing number of CBI passport holders who commit global offenses, and the continual failure of the country's government to approve only legitimate applicants.

Friday, August 17, 2018


With all the negative press surrounding  cases where financial criminals obtain a citizenship by Investment (CBI) passport from one of the East Caribbean states offering these economic citizenship programs, and then are accused of criminal acts, you would think that the remaining Caribbean jurisdictions might choose to avoid CBI altogether. Unfortunately, the lure of what looks like easy money is still attractive to their governments, due to budget shortfalls, dysfunctional economies, and the desire to attract the foreign capital that often accompanies economic passport applicants.

Over in the British Overseas Territory of Anguilla, the local government is ramping up what it refers to as a Residence by Investment, or RBI, program, whereby legal residence will be conferred upon individuals making a large financial investment there. Successful applicants will, after a time, become elibigle for British Overseas Territory Citizen (BOTC) passports, according to the press releases.

This is where a serious potential problem emerges. Holders of a BOTC passport, which you can see is similar to a British passport, enjoy visa-free entry into the United Kingdom; they may remain there for up to six months and even longer stays are permitted, assuming they can prove financial security. While Caribbean CBI passport holders have visa free access, due to the Commonweath of Nations membership their new nationalities possess, a BOTC passport holder will be regarded as British, and routinely admitted, CBI passport holders are recently subject to scrutiny. Which one would you prefer, if you were a money launderer needing assured access to the UK financial structure, without being questioned or searched ?

Now, on to the secondary concern: British Overseas Territory Citizens can apply for British passports; though it is not a routine matter, we imagine a top-flight UK immigration attorney, suitably retained, can succeed for clients sufficiently motivated to obtain one.The holder of a British passport is usually waved through upon arrived in the UK, and that document is priceless in the hands of a financial criminal moving money on a global scale.

Therefore, Anguilla's seemingly innocuous Residence by Investment program could spawn a group of BOTC passport holders, with free and easy UK access, some of whom might actually seek to upgrade to a British passport, but even if they don't they have achieved their goal of the ability to enter the United Kingdom, for the purpose of committing financial crimes, terrorist financing, laundering of the proceeds of corruption, and facilitating international sanctions evasion.

BOTC passports from the Caribbean

We trust that Anguilla's leaders will read this article, and govern themselves accordingly. No RBI applicants can graduate to BOTC status, nor be issued any passports; give the applicants solely legal residence, without granting any passports to them, to prevent their possible criminal misuse.


The large number of financial crimes being committed globally by Citizenship by Investment (CBI) passports holders, and foreign nationals who have bought diplomatic passports sold by the five CBI East Caribbean states, have now caused real problems for bona fide Caribbean nationals arriving in the United Kingdom, who have nothing to do with the criminal activities of others.

West Indians are reporting that their luggage is receiving special scrutiny from the UK Border Agency, and they are being questioned extensively, under circumstances some are calling interrogations, about their visit, as well as their background, and planned activities in the UK and elsewhere. UK sources are reporting that the reason is the well-founded fear, on the part of UK authorities,that undesireable foreign nationals are accessing visa-free entry into the UK through CBI passports issued by Commonwealth of Nations states.

Additionally, UK sources have confirmed that the Border Agency is not accepting ANY Caribbean diplomatic passports at face value, unless and until the "diplomat" is duly qualified as an accredited  envoy or emissary to the UK. This means previously accepted by the UK Foreign Office, which rules out all those "pay-for-play" bogus diplomats buying their credentials in the East Caribbean. We have previously detailed specific cases where accused financial criminals have attempted to evade arrest in the UK by brandishing diplomatic passports issued by the five CBI East Caribbean states; in every instance, British law enforcement agencies have refused to accord diplomatic status to the holders.

What we are seeing is an appropriate law enforcement response to the many threats posed by the individuals who seek the protection, and privileges, of CBI and diplomatic passports, for illicit purposes, The UK doesn't want them coing for a visit and committing crimes while there. No wonder they are giving the third-degree to arriving Caribbean nationals. So long as the East Caribbean states continue tosell their passports to career criminals, sanctions and tax evaders, and corrupt Politically Exposed Persons (PEPs), you can expect the UK Border Agency to look very closely at every arrival from the region.  

Thursday, August 16, 2018


If you are the director of compliance at a financial institution, your organization may very well have to face one or more of the following circumstances:

(1) Your bank has become the subject of a regulatory action, which happened as the direct result of non-compliance wirh specific BSA/AML regulations.

(2) Your bank is undergoing a regulatory examination, or recently completed an examination.

(3) There is regulatory activity that indicates a heightened focus on a specific group of regulations in the industry.

(4) There have been a number of publicly-disclosed regulatory civil fines and penalties, which include mandatory look-backs and remediation.

Whether look-backs and remediation ordered by a regulatory authority, or initiated by your bank, in the light of ongoing industry or law enforcement developments, effective look-backs and remediation efforts, which review prior bank actions, for a specific extended period, are vital, as they will clean up your past compliance errors, and missed transactions.

To more effectively locate, and identify, prior issues, it is suggested that you avail yourself of facial recognition software, which can show you where your prior compliance efforts may have fallen short. You employ it to verify these customer identities:

(A) Run facial recognition software on your clients' government-issued photo identification documents on all new accounts opened during the look-back period.

(B) Run facial recognition software on all your clients who closed their accounts during the look-back period.

(C) Run the facial recognition software on all your clients that your investigation concludes may have had suspicious transactions.

The object is to absolutely confirm client identity, and to uncover, through the use of facial recognition software programs, those career criminals, OFAC SDNs, PEPs, and users of bogus passports whom your compliance staff failed to spot at account opening, or closing.

The identification of these criminal elements will show regulators that you are assessing the causes of your prior compliance breakdown, have analyzed the situation, and have positively identified your remediation approach, using improved technology, including but not limited to the use of facial recognition platforms, as part of Enhanced Due Diligence.

Although most compliance officers are familiar with the customary applications of facial recognition software, at account opening, to check counterparties, and to avoid sanctioned individuals, its use in look-backs illustrates that there are a large number of additional potential uses by compliance, which will result in a larger number of users, and eventually its universal deployment, as a required component of their Enhanced Due Diligence procedures.

Wednesday, August 15, 2018


Trump and Martinelli at the Trump Ocean Club
 While corruption prosecutors in the Republic of Panama joust with Ricardo Martinelli's criminal defense team, there's some nasty unfinished business back in Federal Court in Miami, where Martinelli's closed Habeus Corpus extradition case remains strangely unavailable to the press and public. What are they hiding ?

The Martinelli District Court case, which he filed to stop the enforcement of a Federal court order requiring his extradition, to face criminal chages in his native Panama, where he had served as perhaps the country's most corrupt president, was, from the beginning, not available to view. It was not done through a sealing order, but through a curious administrative act: someone at the District Court simply denied total access to the public, to the pleadings and documents on file.

Observers in Panama have long asuspected, ands have repeatedly alleged, that there are two embarrassing reasons why the United States doesn't want the press, and the public to see this information in Martinelli's petition. Exactly how Martinelli was able to enter the US, due to the rampant corruption allegations in Panama is also an open question. The allegations:

(1) Ex-President Ricardo Martinelli was a confidential informant for a US law enforcement agency, or an intelligence service, and he detailed that relationship in his petition, and in subsequent filings.

(2) Then private businessman Donald Trump, when visiting Panana City in support of the Trump Ocean Club Hotel and Resort, participated in certain "extra-curricular leisure activities" which Martinelli's national security agency had captured on video, and Martinelli disclosed this fact in the petition.

(3) Martinelli also holds recordings of actions taken by US Government agencies in Latin America that would severely damage American diplomatic relations with its regional allies.

Is the public being denied access to the court file, long after it is closed, to save embarrassment to President Trump and/or US Government agencies ? We cannot say, but there has never been any mainstream press coverage of the mere fact that the file has never been available. It makes you wonder what is in that file.


When looking for ways to achieve an effective Enhanced Due Diligence solution, regarding Ctizenship by Investment (CBI/CIP) programs, we must be mindful of the profiles of the applicants:

(1) If you are aware of the public statistics, released by the five East Caribbean CBI states, you know that one-half of the CBI passports issued by Antigua & Barbuda have been to applicants from China, and allmost one hundred per cent of the CBI passports issued by Grenada have gone to individuals from China.

(2) Many of the other successful applicants for CBI passports, whether they choose European or Caribbean jurisdictions, are from countries using non-Latin alphabets, such as the Middle East (Arabic and Farsi), and East Asia (Korean, Malaysian and Thai, to name a few).

(3) When transliterating applicant's names, from the non-Latin characters, into the English language equivalent, there are universally accepted translation norms to guide us. Therefore, any number of correct variations on an English language name are deemed acceptable, which is a recipe for disaster.

CBI applicants, most of whom come from countries of elevated risk, often include financial criminals, assorted other bad actors, fugitives from justice, and international  sanctions evaders. Others are PEPs, Politically Exposed Persons, who are artfully concealing their PEP status, whether because they are corrupt bribe or kickback recipients, or tax evaders at home, or are closely associated with one who is such. He may have even come to you with an alias, all properly documented by his government, but accomplished through corrupt payments for a bogus passport.

So, you end up with an individual being arbitrarily assigned what you hope and trust is the genuine English equivalnt to his original name, which may mean that his high-risk status is never discovered through normal data inquiries. How do we identify him ?

The answer is to employ a facial recognition software platform, which will cull through news photographs, passports, social media images, newspaper and magazine articles, CCTV footage and other sources, and extract from them your target's image, verifying his stated identity, or show him to be a completely different person altogether. Without facial recognition confirmation, the chances that the CBI jurisdiction has issued a passport, under a clean alias, to a career criminal, foreign intelligence agent, or other unsuitable party, is unfortunately good. Due to the elevated level of risk with CBI applications, it has become a necessary, and yes, even mandatory, element of their Enhanced Due Diligence efforts. Let us hope that the agencies operating these programs get the message, as facial recognition software is the only effective solution.

Tuesday, August 14, 2018


Industry reports confirm that the European Commissioner for Justice, Vera Jourová, has made a public announcement that the upcoming agency report on Citizenship by Investment (CBI) programs has been advanced several months. There are rumors that the new report will attempt to set down specific guidelines, for national security reasons, for CBI programs.

Nonprofits and industry advocacy groups are expected to present comprerhensive responses to any negative findings and conclusions, especially in the area of due diligence, which to most objective observers has been an intentional failure, allowing career criminals, terrorist financiers, international sanctions evaders, and other unacceptable risks to acquire CBI passports. Without Enhanced Due Diligence (EDD), unsuitable applicants will continue to acquire CBI passports, and use them to launder the proceeds of crime.

We hope that the Commissioner's recommendations result in the passage of regulations that will result in the actual imposition of EDD requirements on all CBI passports, whether they are issued in the European Union, or the Caribbean, and in the event that this is not strictly adhered to, visa-free entry will be terminated, and visa procedures will be strict.


Former Fort Lauderdale attorney/fraudster Scott Rothstein, who is currently in the Federal Witness Protection Program (WITSEC), and serving a fifty year sentence for  a billion dollar Ponzi scheme, simply refuses to face the fact that he will not be receiving a Rule 35(b) sentence reduction in his case. He has filed an appeal from the District Court's order granting the Government's motion to reduce his sentence, and to also deny him an evidentiary hearing on the matter.

You may remember that the Government asked that the pending, generic motion for reduction of Rothstein's sentence be withdrawn, on the grounds that he engaged in misconduct, in connection with his former wife's efforts to hide their jewelry from being used to reimburse victims of the Ponzi. Considering the Government's sole discretion, in considering whether to reduce a sentence, Rothstein's contract argument was weak at best, and now he is appealing what appears to have been a sound judicial decision, based upon the rule of law. Nevertheless, the appeal is proceeding.

While the Appellate Brief has not yet been filed a proposed draft, presented to the Court in connection with a request to file it late indicated these are the issues presented:

(1)  The Court erred when it rules that the Governmen's sole discretion to file a Rule 35 motion includes the discretion to withdraw it.

(2) The Plea Agreement does not give the Government the right to withdraw a previously-filed Rule 35.

(3) The Court erred when it refused to give the appellant an evidentiary hearing on the issues.

Rothstein's counsel has requested Oral Argument.

Monday, August 13, 2018


The Government has filed its brief in the the 11th Circuit appeal it brought after the trial judge declined to enter an Order of Forfeiture against convicted Panamanian money launderer Nidal Ahmed Waked Hatum. It claims that the Court committed reversible error, by refusing to order Sr. Waked to forfeit properrtty, or by failing to enter a forfeiture money judgment, even through he had laundered over $10m.

The issues presented on appeal:

(1) Criminal Forfeiture is mandatory pursuant to US law. The Court apparently considered that the statutory $520m sum would violate the 8th Amendment's Excessive Fines Clause.
(2) The fact that Waked no longer possessed the funds involved in the money laundering conspiracy does not preclude forfeiture judgment of an equivalent amount.
(3) a forfeiture amount for Waked's money laundering conspiracy cannot be reduced or eliminated merely because Waked had repaid the defrauded bank. (The banks sustsained no losses).
(4) The District Court's subsequent misinterpretation of language in the Plea Agreement to forego entry of a forfeiture order against Waked also is reversible error.

The brief detailed how Waked moved funds, through wire transfers, from Panama to Miami, and back to Panama, outward bound from International Commercial Bank of China (ICBC) to Ocean Bank of Miami, and return to ISBC. He gave bogus invoices to the banks in support of the criminal money laundering scheme, in an amount in excess of $10.4m, to draw on lines of credit.

At sentencing, the Government requested 51 months' imprisonment, but the Courrt only imposed a sentence of 27 months, noting that the banks had suffered no losses, and that Waked's role was not paramount. Legal observers have been puzzed about the length of the sentence, the fact that he was not obligated to testify against any other individuals, and the lack of a forfeiture judgment against an individual who is known to have been a major player in the Waked Money Laundering Organization.

The Waked MLO operated openly* for more than a decade in Panama, and Central America, reportedly cleaning narco-profits for Colombian and Mexican cartels. Waked has since served his short sentence and returned to Panama, through still personally sanctioned by OFAC. Why was a member of a prominent money laundering organization not sentenced to 20 years ? Justice does not appear to have been served in this case, as the punishment did not fit the crime.
* The authorities in the Republic of Panama had overwhelming evidence of money laundering in the Waked companies for at least eight years prior to Waked's arrest in Colombia on US charges,, but corrupt officials in government there protected him and his associates.


The District Judge in the DC case involving Russian-linked companies involved in the social media campaign to affect the 2016 Presidential Election, Concord Management & Consulting LLC, has refused to dismiss the charges, due to the alleged unauthorized appointment, (and therefore lack of authority) of the Special Counsel.

 Above are the first and last pages of the 41-page Memorandum Opinion.

Sunday, August 12, 2018


Although there has been no press coverage of the New York Federal case against Reza Zarrab since his Turkish banker, Mehmet Atilla, was convicted earlier this year, the investigation continues. The fact that Zarrab, months after he agreed to cooperate with prosecutors, has not yet been sentenced, speaks volumes about the extensive debriefings that he must be undergoing, and those are strictly for the purpose of obtaining indictments against others in the multi-billion dollar oil sanctions evasion conspiracy.

If you need an indicator of the zeal with which the Government continues to act in this case, look at this. Although it has not been reported, a search of the docket of the Second Circuit Court of Appeals reveals that The United States Attorney in the Southern District of New York has quietly appealed the 32-month sentence handed down against Zarrab's Turkish banker, Mehmet Atilla. Only if Atilla is facing a long prison term will be be more inclined to implicate others.

Whether Zarrab's information has resulted in additional indictments is not known, but there are a large number of sealed filings in the case, which can mean indictments of individuals out of the reach of the long arm of the US Justice Department, be they in Turkey, Iran, or elsewhere.

(A) The sanctions evasion syndicate, in which Zarrab was a principal player, has a number of members active oustide Iran.Who are the other members, and have they been indicted yet ?

(B) No further information has been made public exactly how the syndicate was able to accomplish its goals of covert sales, outside of the details appearing regarding Alireza Monfared, the Iranian holding a Dominica diplomatic passport, and working out of Labuan. Are there other counterfeit diplomats in the network, and what Diplomatic and CBI poassports are they employing to cover their operations ?

We will continue to look for signs of progress in the continuing investigation of the Iran Oil-for-Gold sanctions evasion scandal. 


Saturday, August 11, 2018


While corrupt Caribbean officials wonder whether they are next, details surrounding the Federal money laundering charges filed in New York, against Donville Inniss, a prominent former minister and ex-Member of Parliament in Barbados, in a bribery scandal involving a Bermuda-owned insurance company, remain a mystery.

Inniss was arrested in Florida, and posted a $50,000 bond in Federal Court in Tampa; the case is pending in the Eastern District of New York. The court file remains sealed to the public, which is a good indication that there are addditional named defendants outside the jurisdiction of the Court, meaning overseas, and the US Attorney in that district does not wish to alert them before they are in custody.

The fact that there will be additional parties defendant in the Inniss case will only serve in increase the fear of arrest for corruption among East Caribbean government officials with something to hide, meaning the acceptance of bribes or kickbacks, especially if they were careless about moving those criminal proceeds through the US financial system, which confers jurisdiction in the United States.


Have you ever seen the motion picture Groundhog Day ? In that film, actor Bill Murray is forced to repeat the same day's bad events, over and over again, ad nauseum. That is what is happening again in Antigua, where the government sees to it that that fugitives from foreign extradition requests never see the inside of a criminal courtroom, anywhere, so that Antiguan corruption is never publicly exposed abroad, or bad actors charge with crimes there.

In the United States, we are painfully aware of this sordid fact; for a decade, Antiguan courts, which follow the lead of their senior government officials, rather than the Rule of Law, have prevented the extradition of the country's former banking regulator, Leroy King. Mr. King artfully, and illegally, kept US regulators from the truth of Allen Stanford's billion dollar Ponzi scheme for years, and reportedly financially benefitted royally at the time, as did Antigua's power structure, from his actiions.

Fugitive Leroy King

When the US Department of Justice sought his extradition, the local court system began a campaign of engaging in extremely dilatory measures, all designed to keep King out of an American courtroom indefinitely. Many in Antigua have stated that, should he be extradited, and eventually cooperate with Stanford case prosecutors, he will implicate many of Antigua's present, and former government leaders, including members of the Bird family, Bird's alleged fixer, Asot Michael, and current Prime Minister Gaston Browne.

Disgraced former minister Asot Michael

 The legal tactics, which are obviously intended to interpose delay, include these dodgy tricks:

(1) The Court repeatedly changes the judge or judges assigned to the case. Each time, the newly-appointed member of the judiciary claims that he or she needs sufficient time to "review" a routine extradition request, adding six months to year to the already lengthy time frame.

(2) The Court assigns judges from other countries in the East Caribbean to hear the multiple, and meritless, appeals, filed by King's legal team, who allegedly have their own schedules and workload, which also extends the time they require to respond.

(3) The sitting judges grant King repeated, and legally improper, appeals and further proceedings, long after two court rulings have ordered his extradition to the United States. Many of his legal arguments to the local courts, and appellate courts, are totally bogus, but they are not dismissed out of hand by the cooperating members of the judiciary.

(4) The defense brings in prominent additional local, as well as regional, attorneys, who have immense influence upon the local judiciary. They file Constitutional motions and briefs, endlessly challenging the right of the US to extradite King; still more delays ensue.

Asot Michael and PM Gaston Browne
Most legal observers believe that King, who travels around Antigua with several bodyguards, to avoid being detained and removed to the United States by bounty hunters or US Marshals, will never be extradited. He has reportedly declined settlement offers from the United States.

Now, this legal nightmare is happening again, in a new case involving the fugitive Indian billionaire Mehul Choksi. India correctly fears that Antigua will delay his extradition, which is duly authorized from one Commonwealth country to another, while it enjoys the financial advantages of a free-spending financial criminal's immense pocketbook. Also, many Antiguans are concerned that the Choksi case will focus so much negative attention upon their country's rampant corruption, that foreign investment, which is in serious decline, will completely dry up.

Antigua has already planted the first intentional legal obstacle to Choksi's extradition. Governement sources have told local media that the Public Prosecutor, who overseas extradition rerquests, is conveniently on vacation for 30 days, and that the matter must be handled by him alone. Are there no other government attorneys on staff in Antigua, we wonder ? It seems to be legal Groundhog Day all over again in Antigua, where justice delayed and therefore denied is the only thing on the menu.