COURT DECISION THAT HELD GOOGLE PHOTOS COULD COLLECT IMAGES FOR FACIAL RECOGNITION HAS BEEN APPEALED

The District Court decision of Lindabeth Rivera and Joseph Weiss vs. Google has been taken up to the Seventh Circuit Court of Appeals.  The lower court in Illinois held last year that Google Photos, which collected, and applied its facial recognition software to, facial images without permission of the individual Plaintiffs, could not maintain a suit for damages because they had not suffered any concrete injuries sufficient to establish standing to bring suit.

The Court held that the Plaintiffs therefore lacked subject-matter jurisdiction, and granted Summary Judgment to Google. the Plaintiffs appealed.

Both Appellant and Appellee have, pursuant to order of the appeals court, filed memoranda directed to the jurisdictional issue; the Seventh Circuit has not yet ruled .




 

WHY IS MALTA A CBI PASSPORT DESTINATION FOR CORRUPT PEPS ?

The concerns that several officials of the European Union have repeatedly voiced concerning the threats posed to the EU by Malta's issuance of CBI passports to applicants from high-risk jurisdictions are well founded. CBI passports have been issued, in large numbers, to Iranians, Russians, and other Middle Eastern nationals, and there are other grounds for concern regarding CBI passport nationals from other developing countries.

One specific category of applicants that are of particular interest to the EU are Politically Exposed Persons (PEPs), as those individuals often have direct access to government funds, hold senior positions as government purchasing agents, making them targets for bribes and kickbacks, or can divert government funding to illegal, personal use. A PEP armed with a Malta CBI passport has visa-free access to all of the countries of the European Union, and more.

We note that statistics are showing a 125% increase in CBI applications from nationals from the Republic of South Africa, whose passports require a visa to enter most advanced Western countries. The fact that only one-half of the applicants are white South Africans is disturbing, because most of the remaining South Africans cannot afford Malta's substantial CBI fees, which require that the applicant be a high net worth individual. While there are affluent South African businessman, they are only a very small percentage of the population.

Some South African government officials are among the applicants, notwithstanding their extremely low salaries, giving rise to the presumption that the Source of Funds for their application fees are illicit income, such as bribes and kickbacks, trafficking in illegal substances, smuggling, and financing of terrorist organizations. Given the favorable political position of major South African political figures towards sanctioned Middle East organizations, terrorist financing is a serious concern.

Therefore, we have corrupt South African PEPs, armed with Malta CGI passports, giving them visa-free entry to the EU, free to place their criminal proceeds in European banks, while enjoying the privileges of their Schengen zone status.  Can anyone say Country Risk ?

ABRUPT DISMISSAL OF MONEY LAUNDERING CHARGES IN THE BAHAMAS VALIDATES EU CLAIM OF ZERO MONEY LAUNDERING CONVICTIONS

If you thought that the recent statement*, on the part of an official in European Union government, that the Bahama Islands were placed on an EU blacklist due to, among other things, the total absence of any money laundering convictions in the country, was wrong, look at this case.

According to local media, all of the money laundering charged brought against five Bahamians were dropped by a local magistrate. One of the defendants is former urban Renewal Deputy Director Michell Reckley, who is also accused of nineteen other charges, including fraud, corruption and conspiracy.

The magistrate stated that his dismissal of money laundering charges was due to the fact that they were not brought within six month of when the crime occurred, but the Director of Public Prosecutions has asserted that such a deadline is only applicable to summary offenses, and the magistrate's order was error.

Perhaps now we now better can understand the position the EU official took regarding the inclusion of the Bahamas in the EU blacklist.
_____________________________________________________________________________
*EU Official to Bahamian Query about the Blacklist entry: you have Zero Money Laundeing Convictions

STATE OF FLORIDA FILES ITS SUPREME COURT BRIEF IN FACIAL RECOGNITION SOFTWARE CASE

The Attorney General of Florida has filed the Brief of Respondent in State vs. Willie Allen Lynch, the Supreme Court of Florida case which could rule upon whether law enforcement agencies that identify a criminal defendant using facial recognition software must show defense counsel all the individuals that the software search returned. At this point, the appellate decision from the First District is the law in Florida.

The First District Court of Appeal decision held that the State Attorney's Office that prosecuted the case against Mr. Lynch had no duty, and the Public Defender is seeking further review from the Florida Supreme Court, on the grounds that two District appellate courts have filed opinions that conflict, which is commonly referred to as "Conflict Certiorari."

There are other possible grounds for the high court to take the case, to invoke Discretionary Jurisdiction, but none are apparent in this case.

The State's jurisdictional brief:
(1) There is no conflict with any other decision. The two Fourth District opinions cited are not relevant. They are not on point.
(2) There is no Certified Question of Great Public Importance.
(3) There is no express interpretation of the US Constitution in the appellate decision.

The Case Number is SC19-0298. Readers who wish to review the brief can access it here.

UN SECURITY COUNCIL PASSES FIRST RESOLUTION ON TERRORIST FINANCING

  The United Nations Security Council has passed its first Resolution on Terrorist Financing. Readers who may need to quote from the material, or who wish to review the complete text may access it here.

ST KITTS AND NEVIS GOVERNMENT REASSURES ITS ECONOMIC CITIZENS OF THE VALIDITY OF THEIR CITIZENSHIP

This government announcement was made in the aftermath of a major scandal involving foreign CBI consultancies which we have previously covered on the blog.

UPDATE ON FEDERAL CASE AGAINST ELEVEN MAJOR BEIRUT BANKS FOR SUPPORTING HEZBOLLAH

If you read our recent article,  Are you Sending any Payments to these 11 Beirut Banks that provide Material Support to Hezbollah ? published on February 23, 2019, which is a case of great public interest, here is an update:

(1) All the eleven defendants have been served (international service abroad).
(2) Notice of Appearance, by bank counsel, have been filed.
(3) The Court has ruled that the "Defendants' time to answer or otherwise respond to the Complaint is extended to 5/31/2109. The Parties may stipulate to any earlier schedule, but given the length of the Complaint, the fact-intensive investigation required to respond to the Complaint and the complex legal issues rasised by the Compliant, the Court will not require the Defendant to respond by the proposed earlier dates."
(4) the Initial Conference has been set for 7/17/2019.

Banks accused of being Hezbollah financiers are in top 10

For those who did not see the first article, the eleven Beirut banks that the Plaintiffs allege provide financial support to Hezbollah are:
BLOM BANK SAL
 BANK AUDI SAL
SOCIETE GENERAL DE BANK AU LIBAN SAL,
JAMMAL TRUST BANKS, SAL
 FRANSABANK SAL
 BYBLOS BANK SAL
 LEBANON AND GULF BANK SAL
 BANK LIBANO-FRANCIS SAL
 MIDDLE EAST AND AFRICA BANK SAL
 BANK OF BEIRUT AND THE ARAB COUNTRIES SAL

Check the rankings of defendants in top 15 banks

When the eleven bank defendants answer or otherwise plead to the Complaint, we shall examine and analyze their filings.

MALTA AND CYPRUS AMONG THOSE EU COUNTRIES NAMED AS TAX HAVENS BY EUROPEAN PARLIAMENT

In case you missed it, the countries in the European Union which were designated by the European Parliament as Tax Havens, meaning that their tax rates are far less than those of the other EU states. Take this designation into account when calculating Country Risk.

The states listed:
MALTA
CYPRUS
HUNGARY
IRELAND
LUXEMBOURG
BELGIUM
THE NETHERLANDS
 

ATTORNEY GENERAL BARR'S LETTER ON THE RELEASE OF THE MULLER REPORT

This is the letter Attorney General wrote to Congress regarding the release of the Report he received from the Office of Special Counsel, concerning the Russia investigation.

US TREASURY DESIGNATES UAE AND TURKISH FRONTS FOR IRGC

The Treasury Department has named a number of companies, located in the United Arab Emirates and Turkey, as SDN, for their role in acting as fronts for the Islamic Revolutionary Guard Corps (IRGC). Read the complete list of firms on the chart below here. Many are connected to Ansar Exchange and Ansar Bank.

TWICE-CONVICTED FELIX SATER, ADVISOR TO DONALD TRUMP, SUED BY BTA BANK

 
Felix Sater, the career criminal known to be a longtime advisor to Donald Trump and the Trump Organization, has been sued, in US District Court in Manhattan, by BTA Bank of Kazakhstan, and the country's capital, Almaty.  The Suit seeks tens of millions of dollars in damages for laundering stolen embezzled funds, for punitive damages, and for other relief.

The Complaint alleges that Sater laundered "the stolen funds through at least five separate schemes in the United States." One of those projects is "the Trump Soho scheme" at page 32 of the 61 page Complaint.  You can read the Complaint here.

Sater is infamous here in the State of Florida for engaging in a major fraud in a South Florida construction project; the investors who were victims could not know that Sater has been convicted in a $40m stock fraud case, because a Federal Judge in New York sealed the conviction, due to the fact that Sater was a Confidential Informant for law enforcement.

TWO PARENTS IN COLLEGE ADMISSIONS SAT CHEATING SCANDAL CHARGED WITH MONEY LAUNDERING

As if their problems weren't bad enough, two of the parents who orchestrated an illegal upgrade of their child's SATa score, so that he could more easily gain admission to college,  were charged with money laundering, a 20-year felony. Amy and Gregory Colburn, of Palto Alto, California, were already facing mail fraud & wire fraud charges. They actually claimed a tax deduction for their alleged $24,000 payment to a bogus charity.

Their son's SAT scores were illegally changed by a test proctor hired by the individual that ran the illicit operation.

FACING LIFE IN PRISON, CONVICTED KINGPIN "EL CHAPO" GUZMAN SEEKS A NEW TRIAL FOR JUROR MISCONDUCT

 
Drug kingpin Joaquín "Shorty" Guzmán, more commonly known as El Chapo, who faces a life sentence in an American Federal Prison after his conviction on several charges, including money laundering and drug trafficking, as the leader of the Sinaloa Cartel, has filed a Motion for a New Trial.

His attorneys are alleging  juror misconduct. The trial judge repeatedly admonished the jurors to avoid watching all media during the case, which is standard practice. Reportedly, after the verdict, jurors not only disclosed the fact that they looked for news of the case on media, they openly boasted about it on media.

Defense counsel has filed a Memorandum supporting Joaquin Archivaldo Guzmán Loera's Fed. R. Crim. P. 33 Motion for a New Trial upon an Evidentiary Hearing. You can read all the allegations contained in the motion in the Memorandum here.

READ TRANSPARENCY INTERNATIONAL REPORT ON MONEY LAUNDERING THROUGH REAL ESTATE IN CANADA

Transparency International Canada has published a 60-page report entitled Opacity: Why Criminals love Canadian Real Estate (and how to fix it). It details the ease through which money launderers place their clients' dirty money into Canadian real estate, and how their successful operations have driven up prices past the ability of many legitimate buyers to become homeowners. You may access the complete text here.

FACIAL RECOGNITION SOFTWARE CAN OFTEN BE THE ONLY MEANS OF IDENTIFYING TERRORISTS

If you have been following the ongoing attacks on the border with Israel by Hamas terrorists, you may have also seen the articles, in the Arab press, about Sajid Muzher, an Palestinian medic who was killed recently near Bethlehem.  Much was made of his noncombatant, unarmed status, his reflective vest, and his purported mission, to tend to Palestinians injured and wounded while attacking the Israel Defense Forces, by throwing stones and Molotov cocktails. The medic died as the result of a gunshot wound.

The articles, which made much of what was described as the 'heroic" actions of the medic, went to great lengths to describe his death as a war crime. The truth, however, is a different matter. Images taken at the scene show the "medic" removing his reflective vest, and throwing Molotov cocktails at the IDF. His identity was confirmed by using a facial recognition software system. The pairing of image databases, and social media resources, with a facial recognition software system consistently results in positive identification of terrorist targets. 

CONSULTANTS GIVING UNDER-THE-TABLE UNAUTHORIZED DISCOUNTS TO EAST CARIBBEAN CBI APPLICANTS

a major scandal involving the illicit sale of discounted SKN CBI passports & citizenship by dodgy overseas CBI consultants continue to roil the industry.The issue first became public last year when St Kitts' opposition leader, Denzil Douglas, himself a former Prime Minister, noted that consultants in the Middle East were selling SKN CBI passports for as little as USD$37,500. Reports from the UAE indicate that there are perhaps two thousand Emiratis that now fear the cancellation of their CBI passports, due to SKN government statements regarding taking such action in case where fraud was involved in the purchase arrangement.

The scam appears to take two different forms:

(1) So-called "third-party financing" covers part of the purchase price, while the applicant assigns over his interest in and to the real estate investment that he or she is making to qualify for a CBI passport. It is not know whether the financing actually results in funds being paid out to developers, or whether it is purely a sham transaction.

(2) Developers charge the applicant for  the more expensive donation option on his contract, but later report the transaction less expensive real estate option to the Government. Obviously, some of the money that the applicant intended to pay for a real estate investment is diverted, and the applicant has only his passport for the payment.

These techniques constitute fraud on several levels. If we start to see CBI passport cancellation on a large scale, consumer confidence in the product will evaporate. Unfortuntely, there is no regulatory supervision of CBI consultants, who are spread all around the world, and have no formal qulaification requirements other than salesmanship ability. Whether the St Kitts scandal will seriously and permanently damage the entire CBI passport industry is unknown.

US SUPREME COURT DECISION IN SUIT BY VICTIMS OF USS COLE TERRORIST BOMBING AGAINST SUDAN

USS Cole

Readers who have been following Republic of Sudan v. Harrison, et al, the action by victims of the bombing of the USS Cole in Yemen, against the Government of Sudan, can find this week's opinion of the US Supreme Court in the case, can access it here. Please note that the primary issue presented in the decision involves the sufficiency of service of process upon the Republic of Sudan. The High Court did not rule upon the merits of the case at this time.

CHAIRMAN OF PILATUS BANK LENT OUT MILLIONS TO COMPANIES HE, AND HIS FAMILY AND FRIENDS, CONTROLLED

Reliable sources inside Iran have confirmed the reports from Malta that Pilatus Bank Chairman/owner Ali Sadr Hasheminejad improperly lent out millions of Euros to insiders; companies controlled by himself, and close relatives and friends, all in Iran and that none of those loans were ever repaid. Many local Maltese businessmen lost access to their accounts, and it appears that they will sustain a total loss; Some were forced to close. Large depositors, who were reportedly linked to one major client, also have been unable to recover their money, since the banking license was withdrawn.

Investigators in Malta found that the bank's entire loan portfolio, which was delinquent and  non-performing, was concentrated in only a few bank clients. These borrowers failed to make required interest payments while the bank was in operation, placing the loans in default. In truth and in fact, the chairman looted his own bank.

There are no reliable figures on the amount left in the bank; one source said total liquid deposits were originally €100m, but published figures show €309m, which appears to be inflated.

MONEYVAL DRAFT REPORT SAYS MALTA AML/CFT EFFORTS ARE UNSATISFACTORY

Major media in the Republic of Malta is reporting that Council of Europe agency MONEYVAL, in a Draft Report, has given the country a "low" (failing) grade in anti-money laundering, declaring that its efforts have been ineffective. While this is only a draft report, Malta now has several months to upgrade its program, if it wishes to pass muster.

 For the purposes of Country Risk, compliance officers should take note, for a failing grade in the Final Report would result in Malta being placed under supervision, or even Blacklisted, by MONEYVAL, whose proper name is The Committee of Experts on the Evaluation of Anti-Money Laundering Measures and the Financing of Terrorism.

Malta is fast getting a reputation as the EU "Bad Boy," due to its dodgy CBI passport program, the Pilatus Bank scandal,  its Tax Haven substandard income tax rates, and the perception of widespread corruption, reinforced by the Panama Papers disclosures. Whether it will be able to achieve meaningful reform is a matter of concern for the other members of the European Union.

AS CHOKSI'S EXTRADITION PROCEEDINGS BEGIN, AFTER A SEVEN MONTH DELAY, HE PLEADS MEDICAL PROBLEMS

 Since Antigua, after sitting on the Mehul Choksi extradition documents for seven months, actually began to move the case forward last week, is it all merely a sham for foreign consumption ? The Court in Antigua immediately adjourned the matter to April 9, which after such a lengthy delay, indicates that the activation of the extradition process is merely a hasty response to the UK arrest of Choksi's partner in crime, his nephew, Nirav Modi, and will not result in any action.

In another move, Choksi's attorneys in India have petitioned to have the pending arrest warrant against him cancelled, due to his purported poor state of health. Given that he seems to have no trouble living a lavish life in Antigua. the argument fails.

Whether Choksi will indefinitely, like Stanford International Bank Ponzi scheme fugitive, Leroy King, evade justice, by remaining in Antigua, where prominent fugitives find safe harbor, so long as the share their criminal proceeds with local politicians and businessmen, we cannot say, but we will be watching.

READ THE 1974 REPORT SUBMITTED BY SPECIAL PROSECUTOR LEON JAWORSKI TO THE US CONGRESS

Forty four years later, the Court unsealed the 1974 Watergate report that Special Prosecutor Leon Jaworski was unsealed and made available to the public late last year. Given the recent course of events, readers who wish to review the document can access the complete text of the Report and Recommendation here.

 

US KNEW ABOUT ALI SADR HASHEMINEJAD'S ACTIONS FOR IRAN IN 2011

Ali Sadr Hasheminejad and Keith Schembri, Malta's PM Chief of Staff

US law enforcement agencies were aware of Ali Sadr Hasheminejad's activities on behalf of Iran as early as 2011, when he sought to purchase, in bulk, Panama's coveted bearer-share corporations. Information which recently surfaced in Hasheminejad's US money laundering case confirmed that warrants were issued, upon court approval, to search sixteen e-mail addresses connected to the defendant, his business associates, and extended family members, in 2014. He was a target long before the Pilatus Bank application was ever filed.

One of the  e-mails

Why the Government of Malta would issue Pilatus a banking license to the Iranian, (although he held himself out as a Kittitian, due to his St Kitts & Nevis CBI passport), is a mystery. Any enhanced due diligence search would have uncovered Hasheminejad's substantial and longtime ties to government officials in the Islamic Republic of Iran.

Was the transaction facilitated through the artful payment of bribes ? We cannot say, but no director of compliance worthy of that title would have approved Pilatus Bank's application. Something corrupt certainly occurred to make that approval happen.

 

WHAT WAS HEZBOLLAH FINANCIER ARRESTED IN KUWAIT DOING WITH A FLORIDA CORPORATION ?

Mazen Al-Tarazi, the Syrian businessman arrested recently in Kuwait and charged with money laundering for Hezbollah, and alleged to be Syrian President Assad's "Man" in Kuwait, has ties to Florida. He is listed as the Vice President and Director of Four Brothers International, Inc., a Florida corporation formed in 2013 in Orlando. There are 4 directors of the company, which provides a clue to the origination of the name. They appear to be Kuwaitis.

 His listed address on the Articles of Incorporation is a large single-family home now listed for sale for $600,000. The registered Agent is a local CPA. The corporation was dissolved by the Florida Secretary of State in 2014 for failure to file an Annual Report.  Given Mr. Al-Tarazi's alleged criminal occupation, we wonder why he, and three other foreign nationals from the Middle East, formed this company, and what kind of business it was. Director Rabee Fattal was the resident at 5719 Argosy, the listed address for Al-Tarazi.

 Allowing a company to be dissolved the year after its formation, and after it has served a limited purpose, is a technique often employed by money launderers and other financial criminals, for they never have to file any additional information, obtain a Federal tax number, or update in formation on the incorporator or initial directors.

Just what was Mr. Al-Tarazi doing in Florida, we ask ?

RESEARCHER USED FACIAL RECOGNITION SOFTWARE AND SOCIAL MEDIA RESOURCES TO PROVE GAZANS KILLED WERE HAMAS AND PIJ TERRORISTS

Gaza border violence

A civilian American researcher, armed with only his facial recognition software system, and his tenacity, repeatedly accessed obscure Palestinian social media and social networking resources, and proved that many of the individuals that the United Nations Human Rights Council Commission of Inquiry Report listed as casualties of the Gaza border riots were, in truth and in fact, senior Hamas, PIJ and DFLP militants. His reporting clearly disproved the UN statement that the dead were peaceful civilian protestors and innocent victims. He even named which militant units they were members of.

Apparently, the researcher, working on his own time, and without any sponsor, was able to access esoteric Palestinian social media sites, where he was able to identify individuals that the United Nations Commission of inquiry listed as non-military, with specific civilian jobs. His information regarding the militants so identified by the researcher, who were killed when they engaged the Israel Defense Forces at the border, including their photo, their military rank, and which Hamas, PIJ or DFLP unit to which they were assigned. Some of the individuals were senior leaders, indicating that they were directing the attempts to breach the frontier, and attack IDF soldiers defending it.

The fact that the researcher was able to obtain actionable intelligence, verifying that these were armed Palestinian militants, rather than unarmed protestors, is a testament to the ability of facial recognition software programs to extract needed images from the massive amount of information present online in social media, and to identify targets on demand. His results raises the issue of whether the UN, for poitical reasons, and to pacify its large number of Members from the Islamic world, is skewing the narrative.

US THREATENS MORE SANCTIONS ON VENEZUELA, AS RUSSIA LANDS TROOPS AND EQUIPMENT

Antonov AN-124 cargo plane on the ground in Venezuela

Amid multiple reports that the United States intends to institute broad-based sanctions against Venezuela, a Russian Antonov 124 cargo plane, and a Russian Air Force Ilyushin IL-62  passenger jet landed in Venezuela. Eyewitnesses stated to European media that approximately one hundred Russian soldiers deplaned, and thirty five metric tons of military equipment was unloaded from the cargo plane.

Whether this is the first step in Russian reinforcement of President Maduro's regime is impossible to tell, but the recent visit of Russian bombers to Venezuela signaled that Russia was increasing its direct support, to prop up Maduro's failing popular support, or to deter a regime change.

Russian Air Force aircraft in Venezuela

Meanwhile, the recent OFAC sanctions upon BANDES, Venezuela's government development bank, and it subsidiaries, most likely means more sanctions are in the works against Venezuela; compliance officers whose bank clients are still engaged in international trade with Venezuelan companies should monitor the developing situation closely, especially the US Treasury sanctions website. 

OFAC SANCTIONS VENEZUELA'S NATIONAL DEVELOPMENT BANK, FOUR OTHERS IT CONTROLS

The Office of Foreign Assets Control has pronounced sanctions upon BANDES, Venezuela's national development bank. Its full legal name is Banco de Desarollo Economico y Social de Venezuela. 

Four other banks controlled by BANDES are also sanctioned; they are:

(1) BANCO BANDES URUGUAY SA: based in Uruguay.

(2) BANCO BICENTENARIO DEL PUEBLO, DE LA CLASE, OBRERA, MUJER Y COMUNIAS, BANCO UNIVERSAL CA: based in Venezuela.

(3) BANCO DE VENEZUELA, SA BANCO UNIVERSAL; based in Venezuela.

(4) BANCO PRODEM SA: based in Bolivia.

 

ATTORNEY GENERAL'S VIEW OF MULLER REPORT CONCLUSIONS

Below is the 4-page summary of the conclusions of the Special Counsel's Office Report on Russia, as interpreted by the Attorney General.

EU OFFICIAL TO BAHAMIAN QUERY ABOUT THE BLACKLIST ENTRY: YOU HAVE ZERO MONEY LAUNDERING CONVICTIONS

When government officials from the Bahamas questioned why their country was placed upon the EU Blacklist of non-cooperative jurisdictions, the answer, from a member of the EU Parliament, was both blunt and true: The Bahamas has zero money laundering convictions. It has been listed as a high-risk jurisdiction for financial crime, due in no small part to the fact that, in a country that is a transit center for narcotics, where dodgy foreign nationals seek to evade their taxman, where human trafficking exists, and where corrupt PEPs secrete their ill-gotten gains, there are no money laundering convictions.

If that was not an indicator that enforcement of anti-money laundering laws and countering terrorist financing is sorely lacking, Bahamians do not understand the global problem. Perhaps they had best starring enforcing the proceeds of Crime Act and the Anti-Terrorism Act, before complaining to the EU that the inclusion of the Bahamas on the EU Blacklist was contrary to the evidence.

HAMAS REOPENS UNREGISTERED PANAMANIAN FUND TO RAISE MONEY IN EUROPE

Abi Amin Rashid with Hamas leader Ismail Haniyeh

Amin Abu Rashid who is reputed to be Hamas' most senior terrorist fundraiser in Europe, and the Dutch national Okke Ornstein, who has a long record of felony white-collar crime activities in Panama and elsewhere, have reopened Ornstein's defunct Tulip Fund in Europe, with the alleged goal of selling gold to support Palestinian housing in the Gaza Strip and in Syria. They are operating their fraud from the Netherlands, where Ornstein has been hiding from judgment creditors.

Panama's National Securities Commission, back in 2002, issued an alert against Tulip Universal Project SA d/b/a The Tulip Fund, as it had no license in Panama to market securities, and constituted a fraud upon the investing public. Ornstein, who was fraudster Mark Harris' general manager, was banned from ever entering Panama, upon pain of further incarceration, after his third felony conviction there. He has since picket up a fourth conviction in the Netherlands, as well as a $5m money judgment. We have previously reported upon his activities in the Republic of Panama, including his time spent in prison.

The Tulip Fund operators claim that it is selling gold coins, for $1000 each, with the profits to go towards rebuilding homes in the Palestinian Territory of Gaza, and in Syria, where a large number of Palestinians reside. They have not disclosed the actual value of the coins they are selling to the public.

Given that funds raised by the pair, supposedly for Hamas, were later diverted to Ornstein's personal use, and Hamas was seeking Ornstein for that money, one must assume that the resurrected Tulip Fund is also a scam, and investors should avoid it at all costs. Do not respond to solicitations or emails with any reference to the Tulip Fund. Ornstein is currently facing additional prison time in the Netherlands; Rashid's location is unknown.

IS PAUL MANAFORT PLAYING THE SHELL CORPORATION GAME TO KEEP $1m IN CRIMINAL PROCEEDS ?

A Nevada limited liability company, Woodlawn LLC, is seeking to recover $1,025,000 that it allegedly lent to former Trump Campaign Chairman Paul Manafort. The problem is that government prosecutors believe that the "loan" was a sham, and that Manafort is manipulating the system to recover one million dollars of his criminal proceeds.

Woodlawn is totally opaque; Beneficial Ownership cannot be established; it is a typical shell company, not in any active business operation, and without any real officers and directors. Remember, financial criminals often "lend" money to themselves, through intermediaries, as loans are not treated as income for tax purposes. They simply fail to ever repay the debt. Prosecutors, in a recent filing, told the Court that they believe that Manafort was the source of funds for his "loan."

The fact that he engaged in this transaction after the Special Prosecutor's Office had begun to openly investigate him renders the loan suspicious on its face, and may create a rebuttable presumption that it was, and is, bogus and fraudulent. How does somebody in the public eye have the arrogance to do this while under the microscope ?