Tuesday, December 31, 2019
Monday, December 30, 2019
|Dawody, second from tight.|
A word to the wise, directed to Soren Dawody, and to all the other CBI fraudsters who stole investor money out of a Citizenship By Investment (CBI) construction program in the East Caribbean states: the maximum fine, under US lawm for money laundering is twice the amount of money you have pased through the bank accounts that you controlled. That's thirty-six million dollars, Sheikh Dawody. think about that.
Of course, most people are far more interested in the Federal Prison time that District Judges mete out in a money laundering case. The max is twenty (20) years of imprisonment, of which eighty-five per cent (85%) must be served, as Parole was abolished. The guilty will also receive a term of Supervised Release, after they leave prison, and a fine, and most likely Restitution, paying back that $18m will delay the termination of Supervised Release, by the way.
We wonder whether those transnational criminals, who divert millions of dollars from CBI construction funds, or even fee to government, ever give a thougth to how they will cope with a long US prison sentence, in the company of inner-city drug traffickers much larger than themselves. Their lawyers never tell them that the Money Laundering Control Act of 1986 has deen deemed by the court to have extraterritorial jurisdiction, and their choice of the US Dollar as the type of currency to receive, further seals their fate on jurisdiction.
The knock on the door may come, in your case, sooner rather than later. Govern yourself accordingly.
Posted by Kenneth Rijock at Monday, December 30, 2019
Sunday, December 29, 2019
The 1501-page Report has been released to the public. To review the complete text, access it here.
Posted by Kenneth Rijock at Sunday, December 29, 2019
Saturday, December 28, 2019
Friday, December 27, 2019
This is Melanius Alphonse, Dominica's Minister of Propaganda. A self-styled "journalist " from St Lucia, this Canadian citizen's job is to place disinformation that supports the present Labour government of Dominica in online media, both to deceive the country's voters, and to promote the dodgy CBI industry, whereby high-risk individuals, and white-collar criminals, from sanctioned and hostile countries pay obscene fees for passports that allow them to pass through the cracks in the global justice and banking systems. He is reportedly very well paid to influence public opinion, receiving compensation from both the Labour Party of Roosevelt Skerrit and Range Development, Dominica's leading CBI project developer. He is also linked to Montreal Management Consultants.
National leaders in the other East Caribbean states may support the Skerrit government in public, but behind closed doors, they wish Ronald Reagan was still President, for he presumably would not hesitate to send in the US Marines, Grenada-style, and not only arrest Skerrit and his Cabinet, but deport the 900-plus Communist Chinese nationals working in the embassy, including the intelligence officers who are operating a sophisticated listening post, keeping tabs on US activity in the Caribbean.
Up and until the recent national election in Dominica, Alphonse churned out article after article that portrayed the country's Opposition leaders in a corrupt, criminal light; the sole purpose was to throw enough dirt on the candidates to guarantee a successful election for the Labour Party. His unlimited access to the Caribbean News Global webpage allowed him to publish article after article, containing negative, misleading, and even libelous, information about the candidate for Prime Minister, who won handily, amidst charges of massive corruption voter fraud, and vote buying. Democracy came in a poor second in that election, and Alphonse, as a hired gun, twisted the truth for his sponsors.
|Munaf Ali of Range, PM Roosevelt Skerrit, Mohammed Asaria of Range|
In the commercial sphere, Alphonse's many puff pieces about Range Development's 150-room luxury project, Cabrits Resort & Spa Kempinski Dominica, belie the sober fact that, after 20 years in power, the Skerrit government has failed to build an international airport*. Dominica remains a tourist destination without the means to get there. Luxury eco-tourists will NOT willingly take an airliner to a nearby island, and then a puddle-jumper (turbo prop) into Dominica's tiny, non- instrument flight equipped single runway airport*. Dominicans were sold a bill of good by the developer, who was able to repatriate thirty million dollars from the recently finished project, which now stands empty of the guests Alphonse predicted would overflow the facility. The voters in Dominica, who were intoxicated with promises of jobs and an expanding economy, returned Skerrit to office, and allowed Range to pocket millions without effective oversight. They have Alphonse to thank for all this.
* The Douglas-Charles Airport, with its short 4600 ft. runway, has a history of being used by Venezuelan bulk cash smugglers, seeking to place millions in drug profits in Dominica's dodgy offshore banks. It will not even accept regional jets, or short-haul Boeing 737 airliners, let alone wide body international jet transports.
Posted by Kenneth Rijock at Friday, December 27, 2019
Thursday, December 26, 2019
Why would an affluent individual choose to avail himself of the Citizenship by Investment (CBI/CIP) Programs currently offered by five of the East Caribbean states ? Most Western countries, such as the US, Canada and UK among them have similar programs of their own.
Legislation and administrative safeguards that are in place in the Western democracies are well known. The fact that such controls are not in place in Dominica, Grenada, St Kitts & Nevis and St Lucia is not an indictment of their programs, it is an indictment of the toxic combination of greedy political elites, and uneducated, uninformed or duped voters in these East Caribbean CBI states.
Common sense dictates that, since the First World countries have their own equivalent of CBI programs, why don't these passport of convenience shoppers go directly to their well-managed programs, to arrange their purchases ? Would not any affluent law-abiding, honest, tax-paying, globetrotting and above-board businessman needing visa-free international travel privileges want to be in possession of an American, Canadian or United Kingdom passport any day, rather than those from the East Caribbean, which have restrictions, for example, on free travel into North America ?
The news stories that abound of late, regarding corrupt financing of the recent national election campaign in the Commonwealth of Dominica, are not being ignored by officials in the US, UK and Canada, as they incriminate Prime Minister Roosevelt Skerrit and the staff of his CBI program. Substantial evidence supporting this fact has been gathered by Confidential Informants acting on behalf of the Department of Homeland Security (DHS), The Financial Crimes Enforcement Network (FinCEN) and the Department of Justice (DOJ) Criminal Division, confirming that PM Skerrit's program of providing passports questionable and unscrupulous individuals who are hostile to United States Foreign Policy interests has created a clear and present danger to the National Security of the United States and its pro-democracy allies.
Dominica's Prime Minister, Roosevelt Skerrit, an individual who was raised in humble circumstances, has corruptly used state power first to enrich himself, and secondly to acquire the resources needed to finance his political party and election campaigns, by shadowy and allegedly corrupt CBI facilitators and consultancies. Dominicans point to the new Cabrits Resort & Spa Kempinski. a 151-room luxury resort, which opened in October 2019, and was developed by Range Development, a CBI facilitator, managed by Mohammed Asaria, a controversial figure with CBI clients in Iran, Yemen & Sudan, all countries subject to international and United States sanctions.
Another CBI facilitator, Montreal Management Consultants, headed by Anthony Haiden, and based in the United Arab Emirates (UAE), is reportedly linked to a number of individuals with ties to foreign intelligence operatives hostile to US & UK interests.
CBI facilitators often create and sell impressive project presentations to desperately poor island governments, under the pretense of creating jobs, and upgrading the local economy, when in truth and in fact, it is deception. Most of the developers' shares of the CBI program are collected in advance, and thereafter a sub-standard construction project is completed, after which the builders sell of their shares and move on to another project in the Caribbean.
Dominica has become politically unstable of late, due to violent government suppression of peaceful protests. There is an increasing probability that the current Skerrit regime could be toppled, due to the possibility that the Prime Minister, and other senior members of his government, will be arrested or extradited to the United States, to face charges of money laundering and Conspiracy to Threaten the National Security of the United States.
Any new democratically-elected Dominica government would certainly strip the dodgy CBI passport holders of their citizenship and void their travel documents forthwith. CBI passport holders are unaware that their expensive passports may soon be useless, depriving them of their entire citizenship investment, which they belatedly have already learned does not grant them free access to all Western countries. Purchasers of CBI passports from the East Caribbean are taking on much more than they bargained for, and they are generally unaware of all increased risk that they have assumed when they accept what they believe to be a valued travel document.
Posted by Kenneth Rijock at Thursday, December 26, 2019
Wednesday, December 25, 2019
Tuesday, December 24, 2019
GEORGIA PUBLISHES ITS LIST OF HIGH-RISK MONEY LAUNDERING JURISDICTIONS: EAST CARIBBEAN DOMINATES LIST
The National Bank of the Republic of Georgia has published a list of what it has designated as the twenty-five countries it considers to be at high risk for money laundering. It should be no surprise that most of the East Caribbean states are listed, as their local financial institutions, for the most part, have not reached the level of Banking Best AML/CFT Practices that exist in North America and in the countries of the European Union. It is, in my humble opinion, a combination of factors that is responsible, but the banks appear to be in no hurry to adopt effective platforms and programs, and as a result de-risking of Caribbean banks continues unchecked.
The Caribbean jurisdictions named:
ANTIGUA & BARBUDA
ST VINCENT & THE GRENADINES
TRINIDAD & TOBAGO
TURKS & CAICOS
Therefore, please note that more than one-quarter of the jurisdictions on the list come from the Caribbean, Compliance officers who must calculate and update Country Risk for management please factor this information into your assessment.
The British "businessman" residing in Canada, Timothy Durkin, accused of leading a $4.9m Ponzi scheme, involving a bogus arbitrage computer program, has been contesting his extradition from British Columbia. His association, in Panama, with Ryan Bateman, the Cayman Gang of Four fraudster, which has been the subject of a recent article on this blog, has been brought to our attention due to the possibility that Durkin may have assisted Bateman transfer funds stolen from Canadian retirees in Grand Cayman. Both individuals appear jointly in a number companies, all known as B & C Capital, and formed in several jurisdictions.
|Cayman Gang of Four -1: Sharon Lexa Lamb, Ryan Bateman, Derek Buntain|
For readers who require more details about Durkin's criminal activities, please see below the INTERPOL Red Notice filed by the United States against this fugitive from justice.
Monday, December 23, 2019
|Soren Dawody, center|
An insurance company, domiciled in the US Virgin Islands, executed a promise of payment. The investors have indicated that they relied upon this promise; it provided an assurance of restitution, came from an independent third party, and appeared to decrease risk to a minimal level. Advertised as "The 5-Year Guaranteed Investment Buyback (emphasis from GSA webpage) with third party assurance," it appears to insulate the investor from loss.
The problem: GSA's owner, Soren Dawody, failed to fund the necessary capital to the insurance company, and therefore there was no operating fund from which to generate sufficient cash flow to repay investors at the end of the trial period contemplated in the agreements. Frankly, we do not know whether he ever intended to fulfill his contractual obligations to the investors, and to the insurance company.
Was the guaranteed buyback merely a pipe dream to lure in unwary investors ? Two years after most investors paid in their capital, there has been no project action, and they have not been reimbursed. Fraud or genuine business failure ? You be the judge of what the true goal of the GSA was.
Posted by Kenneth Rijock at Monday, December 23, 2019
Saturday, December 21, 2019
|Anthony Astaphan SC|
Astaphan's role in Dominica's dodgy Citizenship by Investment (CBI) program, and its illicit sale of diplomatic passports to foreign nationals, in clear violation of the United Nations Vienna Treaty, have been the subject of previous articles on this blog, as has his close personal relationship to the Stanford International bank scandal. New evidence, obtained in the Stanford case, by a reliable financial crime analyst, confirms Astaphan's role in that scandal as well.
While we know from previous information that PM Skerrit has been under investigation by US law enforcement agencies for some time, this is the first time that his personal attorney has been linked to alleged money laundering operations, including in the United States.
Astaphan is not admitted to the practice of law in the United States, through he is known to reside in the State of Florida from time to time. In any event, the Crime or Fraud Exception to the Attorney-Client Privilege states that clients who are engaged in criminal activities with their clients cannot assert the privilege, nor can their attorneys. Our investigation into this matter will continue, and we will report back to our readers on all developments as they occur.
HEAD OF FAILED GRENADA SUSTAINABLE AQUACULTURE PROJECT BLAMES GOVERNMENT, BUT FAILS TO REFUND MONEY TO INVESTORS
|Soren Dawody, far left.|
If you were wondering what excuse Soren Dawody, the owner of the Grenada Sustainable Aquaculture Project is alleging, to explain why his $40m venture was never built, here it is: He asserts that the Government of Grenada failed to give him the permits and licenses necessary to initiate construction of the facilities.
Let's for one brief moment assume that there is a grain of truth in his claim; in that case, would Mr. Dawody kindly explain these inconsistencies:
(1) Why were refunds not then disbursed to the investors ? Mr. Dawody, reportedly a very wealthy man, certainly must have these funds on hand. He did direct investors to send their payments directly to him in the United Arab Emirates (UAE), and in Singapore, and not wire the money to the escrow agents in Grenada. Therefore, he must still have the eighteen million ($18m) dollars he took in.
(2) Why has Dawody basically disappeared from the Grenada CBI scene altogether ? We understand that investors in the GSA project cannot locate him anywhere in the world. You will not find a current photograph of him online, or locate him at either of his two offices.
(3) Why has he failed to keep his investors informed ? A quick look at the GSA social media pages show that they have not been updated for a year or two.
(4) Why have creditors of the GSA project, all of whom apparently have not been paid anything, threatened the Government of Grenada, demanding that they be paid for their labor and materials ?
Given that Federal courts in the United States have interpreted the Money Laundering Control Act of 1986 to include extraterritorial jurisdiction, even to individuals who have never entered America, if they move US currency as the Proceeds of Crime through the global financial system, does he not fear being charged with a 20-year felony for his fraud ? He is known to be a highly educated businessman; if he fails to make restitution forthwith, he could follow in the footsteps of others who committed major fraud in the Caribbean.
Thursday, December 19, 2019
THE CAYMAN GANG OF FOUR FRAUDSTER RYAN BATEMAN MOVES HIS OPERATION TO PANAMA, JOINS WITH INDICTED PONZI SCHEMER
Remember the Cayman Gang of Four*, that gang of financial professionals working in the Cayman Islands who stole hundreds of millions of dollars from Canadian retirees and pensioners. We have extensively reported on the scandal, with special attention given to the fact that neither the Royal Cayman Islands Police Service, nor the Cayman Monetary Authority, saw fit to charge any of the fraudsters, lest the suitability of Cayman as a destination for investment capital come into question.
To update our readers: Ryan Bateman, the fugitive Canadian leader of the crew, and who illegally transferred the victims' money through his shell company, B & C Capital Ltd., claiming it was a "bank" and safe for investors, appears to have moved his illicit operation to the Republic of Panama, where he has taken upon with one of Britain's most notorious Ponzi Schemers, Timothy Durkin a/k/a Richard Lee Durkin a/k/a Lee Durkin**, who was indicted in the Southern District of Alabama, in a $5m Ponzi scheme.
Durkin, who was cleverly using the identity of his homeless brother, Lee Durkin, allegedly with his co-conspirators, promised investors profits through a "high-speed computerized arbitrage trading system," according to the Indictment. He fled to British Columbia to avoid arrest and prosecution.
Back to Mr. Bateman, who formed companies in several jurisdictions, all deceptively similar in name to his Cayman shell company, B & C Capital, to facilitate international transfers of the proceeds of crime. One company, formed in the Republic of Panama, was named B & C CAPITAL, INC. Official corporate records, which appear below, show not only Bateman, and his brother-in-crime, Cody Bateman, as officers, but Lee Durkin as well.
We have not confirmed whether Durkin was a recipient of the Cayman Gang of Four's criminal proceeds, but we have been conducting a continuing investigation into the matter, over the past several months, using the services of a financial crime analyst, among other sources, and will be publishing our results in further articles on this blog; stay tuned.
* The Cayman Gang of Four are:
RYAN BATEMAN, a Canadian national now believed to be living in the United States.
SHARON LEXA LAMB, A native of the Isle of Man, now a resident in Grand Cayman.
DEREK BUNTAIN, A Canadian national, now living in the Atlantic Provinces of Canada,
FERNANDO MOTTO MENDEZ, a Portuguese national, resident in Grand Cayman.
** White collar criminals often use their middle name, especially after they have been identified or convicted under their first name, to confuse and confound investigators, and to mislead anyone seeking information on them by accessing databases of known career criminals.
Tuesday, December 17, 2019
|Cash found inside pork barrels|
Bulk cash smuggling, to avoid the financial system altogether, remains a favored method of movement of large amounts of criminal proceeds in the United States. Local law enforcement in Cleveland County, North Carolina stopped a tractor-trailer on Interstate 85, for impeding the flow of traffic, and failing to stay n the proper lane. A police dog, assisting in the search, reportedly found approximately three million dollars in currency, wrapped in plastic, and hidden inside a shipment of port shoulders on board the trailer.
I-85, which runs from Virginia to Alabama, is a route known to be used by drug traffickers moving cash to Mexico. From Alabama, I-10 is generally employed to bring bulk cash shipments to Texas and the border. The driver, who is of Hispanic origin, was arrested and Federal authorities notified.
Readers who are charged with assessing Country Risk for their banks and non-bank financial institutions should review the latest Mutual Evaluation of the Financial Action Task Force (FATF), which detailed major AML./CFT defects. read the 238-page document here.
Sunday, December 15, 2019
HOW MUCH DID GRENADA GSA FRAUDSTERS GIVE POLITICAL PARTIES TO GET APPROVAL FOR THEIR BOGUS AQUACULTURE PROJECT ?
While Government has flatly denied that GSA made any payments to the NNP, or to the Prime Minister, or any other members of the present regime, and claimed that there are no entries in party financial records to support those allegations and claims, insiders in Grenada explain that bribes and kickbacks are commonly paid there in cash, or in other items of value, and as such are generally untraceable.
The operators of the GSA project had absolutely no prior experience in the construction and operation of a sustainable aquaculture facility, when the project received governmental approval, and inclusion upon the Approved Project List, which gives rise to the presumption that there were other, illicit, forces at work securing the approval. We note that the project operators also did not complete their aquaculture project in Antigua, and which was also abandoned last year.
While any lawsuit, filed by victims of the GSA scandal, might be barred as to the PM and senior officials, on Sovereign Immunity grounds, any suit against political parties could not invoke such a defense. Any judgment recovered against the NNP would have to be promptly satisfied, as the ability of that party to support its candidates would be either severely limited, or eliminated altogether.
|Leroy King and R Allen Stanford|
Leroy King, who as head banking regulator in Antigua, kept American investigators in the dark for years, as they sought information on the Stanford International Bank Ponzi scheme, was denied bail last week, after a US Magistrate Judge in Texas denied him bond, and remanded him into custody, pending trial. Friends and family members reportedly testified on his behalf at the bond hearing, but the Court did not grant him release; his lack of ties to the United States, and failure to agree to extradition since 2009, were probably contributing factors in the decision.
King, the last significant defendant in the billion dollar Stanford Ponzi scheme to evade justice, blocked extradition from Antigua for more than a decade, during proceedings that clearly demonstrated that political influence, and not the Rule of Law, governs court proceedings in that Caribbean country. His appearance, before a court in the United States was artfully delayed, due in large part to repeated judicial reassignment of the case, multiple appeals filed without any merit at law, and dilatory tactics of local government prosecutors.
The defendant faces a maximum of one hundred and seventy-five years imprisonment, on twenty-one counts, including mail, wire and securities fraud, and money laundering. The question court watchers have been asking is whether Mr. King, to reduce his sentence, will implicate present and former senior government officials, who allegedly accepted significant bribes from Allen Stanford, to allow him to operate his Ponzi scheme, which accepted depositors' money for supposedly secured Certificates of Deposit, while spending it on his opulent lifestyle.
King is allegedly suffering from cancer, and reliable Antigua sources claim that he will take his secrets about corruption to the grave. They originally thought he might pass away while still fighting extradition; whether he has had a change of heart about cooperation is not known.
|The real Le Drian, and the imposter|
If you have been following the case of the French crew that stole an estimated €85m from wealthy victims, by posing as a French cabinet minister, in a elaborate scheme involving the creation of a duplicate of the minister's office, and the use of a silicone mask, the gang had even grander plans. We have previously covered this case in two articles:
(1) French Fraudsters impersonate Foreign Minister, take €8m from Victim.
(2) Identity of Principal Player in Massive Fraud involving the Impersonation of the Foreign Minister of France remains a mystery.
New information has recently emerged that adds a new, and extremely disturbing, dimension to the story. Among the items that French investigators discovered, while going through the images on one of the fraudsters' smartphones,was a photograph of a silicone mask of Prince Albert II of the Principality of Monaco. The successful impersonation of the leader of Monaco would afford the fraudsters entry into the country's financial system, including stored precious metals and currency, and also into restricted government records.
|Prince Albert II of Monaco|
The financial advantages that the crew would derive from posing as Prince Albert, even for a brief period, are obviously infinite. While we do not know precisely what the fraudsters had planned, before a wave of arrests interrupted their operation, we can only speculate that it was to be something on a grand scale. We shall be reporting on the trial, which will occur in the near future.
Saturday, December 14, 2019
Friday, December 13, 2019
According to Malaysian media, the country's Sessions Court has made a ruling ordering Mun Chol-Myong, A North Korean businessmen living in the country, to be extradited to the United States, where he reportedly faces four counts of money laundering, and two counts of conspiracy to commit money laundering. Mun has been held in custody since his arrest in May; his defense is being paid by the local North Korean Embassy.
Though details are not known, Mun was engaged in the sale of goods, from Malaysia, to North Korea, through China. His attorney is claiming that the charges are politically motivated, aimed to pressure North Korea over its illegal ballistic missile program. The allegations, which have appeared in the local press, indicate a sophisticated money laundering operation, involving the use of front companies, and defrauding US banks, through the use of fraudulent shipping documents, all to support the illicit delivery of goods to North Korea, in violation of United Nations, and US, sanctions.
One report states that Mun had illegally purchased engines for maritime vessels, to be sent to North Korea, and there are also terrorism allegations against the defendant. His attorney has indicated that he will take an appeal to the High Court of the lower court decision. This case is believed to be the first involving the extradition of a North Korean national to the US on money laundering charges.
Posted by Kenneth Rijock at Friday, December 13, 2019
Thursday, December 12, 2019
Investors in the Grenada Sustainable Aquaculture/Citizenship by Investment program, whose funding for the GSA project was allegedly stolen by project managers, have demanded that the Government of Grenada reimburse each of them for the amount they paid into GSA, which was a government-approved project for individuals participating in the CBI passport program. There are estimates that eighteen million US Dollars was paid in, after which the project was abandoned by its operators, even before construction began.
The arguments made by investors, for Government relief, are supported by the fact that investment in an approved program was mandatory, for individuals seeking to acquire that prized Grenada passport. Investors assert that they relied upon the fact that GSA was a listed & approved project. They are claiming that they would not have invested otherwise, and that Government received lucrative fees in connection with the GSA program, which it should now disburse to the victims.
Additionally, there are well-placed concerns that, if Grenada declines to provide the requested relief to the investors, all of who are now bona fide Grenadian nationals, that litigation against the senior officials who were supposed to oversee and monitor the GSA program, both as individuals and as representatives of Government, will ensure, and the resulting scandal might destroy Grenada CBI, as consultancies that bring new clients into the program, will direct their customers to choose another jurisdiction, pending the outcome of litigation. Claims of Malfeasance in Office, and the acceptance of illegal kickbacks, as part of a scheme involving corruption, have been thrown about, which represent a direct threat to those officials allegedly involved.
For that reason alone, the reimbursement of investors' principal, since demand has been made, could be a solution that could save Grenada, especially its lucrative CBI program, from clear and present danger. Otherwise, expect litigation forthwith.
Wednesday, December 11, 2019
OFAC SANCTIONS ENTIRE MAHAN AIR FLEET - 48 AIRCRAFT - FOR PROVIDING LETHAL IRGC-QF MILITARY AID TO REBELS IN YEMEN
The entire Mahan Air fleet has been sanctioned by OFAC for the company's support of Iran's illegal ballistic missile program in Yemen. Readers who have bank clients in the aviation service industry may wish to review the list of Mahan Air aircraft sanctioned by Treasury, and notify their clients that these air frames cannot be serviced by US entities or individuals. The list appears here.
Posted by Kenneth Rijock at Wednesday, December 11, 2019
Tuesday, December 10, 2019
DUE DILIGENCE USING DATABASES OF HIGH-RISK INDIVIDUALS AND ENTITIES IS NO LONGER EFFECTIVE; WHAT'S NEXT ?
For twenty-five years plus I have been involved in anti-money laundering consulting, including seven years lecturing and writing for two companies selling commercial off-the-shelf databases of high risk individuals and entities, and a tour of duty with a major insurance firm, conducting enhanced due diligence of foreign applicants purchasing extremely large life policies.
While in the past, customer identification procedures and enhanced due diligence investigation at account opening, using databases and online resources, were generally effective to confirm client identities, that is unfortunately no longer the case. Standard commercial off-the-shelf databases, no mater how complete and how often they are updated, simply cannot cope with the current ability of financial criminals and terrorist financiers to obtain clean, bulletproof forms of identity, under aliases, that can stand up to the best Enhanced Due Diligence investigation, because even a deep dive will not expose a state-of-the-art passport, which has sufficient information support in place, to verify any and all inquiries as to identity. Customer identification can no longer be assured, at any level.
You can blame corrupt government officials, or the explosion of Citizenship by Investment (CBI) passport programs, which frequently afford financial criminals the perfect counterfeit identity, but we must focus on a solution. Thew only reliable Customer identification solution, the use of facial recognition technology to make a positive identification of a target, but there must be an extensive image library, of quality photographs, available to check the target's images against, and that does not yet exist for commercial, non-law enforcement, use. Whether it will ever be available, in a form adequate for CIP purposes, is not known; the sheer amount, and scope, of images required to be effective is huge.
So, if you cannot stop a financial criminal from opening an account, you must rely upon your ability to identify and interdict him, in real-time, using a financial crime detection platform. It is time to abandon traditional Customer identification techniques, as they are not effective today, and move on to identifying the money launderer by his transactions. If you do not have adequate programs for that purpose, you are advised to focus on acquiring them forthwith, lest you not only admit money launderers and sundry other types of financial criminals into your bank, but you fail to identify them in action.
A Federal Judge in New York has ruled that none of the seven pretrial motions filed by attorneys for Ali Sadr Hashemi Nejad, the Iranian owner of Malta's defunct Pilatus Bank, have any merit at law, and has entered an order denying all of them, thereby moving the case forward towards a 2020 trial. In a well-documented 37-page order, the trial judge analyzed all of the motions, and disposed of each of them in turn.
The defendant, who is charged with multiple money laundering and international sanctions offenses, allegedly moved $115m through the American banking system, artfully using four St Kitts & Nevis CBI passports in Switzerland to conceal an extensive Iranian-Venezuelan connection. The failure of Pilatus Bank in Malta placed that country under serious scrutiny by the European Union, for both failure to properly examine the bank, before awarding it a license, and neglecting to adequately monitor its operations. The bank's failure was reportedly costly for Malta's taxpayers, and official corruption allegations surrounding the bank abound, though no criminal charges have been filed.
Hashemi Nejad, whose relatively painless pretrial release puzzled court observers of the financial crime scene, due to his Iranian nationality, and his links to the regime in Venezuela, remains free on bond, though under somewhat restrictive release conditions, which he is seeking to reduce. Whether he constitutes a flight risk, as well as a continuing danger to the US financial sector, remains an open question. His travels, which included over 100 trips during the past several years, included multiple visits to Iran, as well as many of the world's favorite international financial centers, more commonly known as tax havens, all of which Iran has employed to evade international sanctions.
We shall continue to monitor all developments in this case, as they occur.
Sunday, December 8, 2019
PROPOSED AMERICAN LAW WILL REQUIRE COURT APPROVAL FOR CONTINUING SURVEILLANCE USING FACIAL RECOGNITION TECHNOLOGY
A bipartisan bill recently introduced in the United States Senate will, if passed, require Federal law enforcement agencies that conduct continued surveillance of targets, using facial recognition technology, to obtain a court order from a judge, authorizing such activity. Named the Facial Recognition Technology Warrant Act of 2019, bill requires court approval for any continuing public surveillance, using facial recognition technology, that occurs "over a period of time greater than 72 hours, " the law does provide for exemptions during exigent (emergency) circumstances, but there must be follow-up application to a court for an order.
For those who fear that the new law, if enacted, will prohibit single identification of suspects using facial recognition technology, such one-time uses are specifically exempted from the court order requirement, provided that continuing surveillance is not subsequently used to track that individual, in either real-time, or through the use of historical records. There is a 30-day time limit on orders awarding court approval, and a procedure to extend them.
It is noteworthy that the bill contains a provision allowing for filing of Motions to Suppress, whereby the procedure can be challenged in court. Readers who wish to review the bill may access the complete text here.
Posted by Kenneth Rijock at Sunday, December 08, 2019