US WILL DESIGNATE THE MUSLIM BROTHERHOOD AS A FOREIGN TERRORIST ORGANIZATION

Reports from Washington, Cairo and from State Department sources appear to suggest that the United States Government will soon sanction the Muslim Brotherhood* as a foreign terrorist organization. President Trump has reportedly made the decision to sanction the Brotherhood, notwithstanding opposition by forces that fear such as designation, though warranted, could cause push back in the Middle East.

In truth and in fact, the violent history of Brotherhood, its direct influence upon the birth of Hamas, another designated terrorist organization, and its anti-democracy and anti-West agenda all serve to justify the imposition of US sanctions. Several countries, especially those in the Middle East, have previously designated the Brotherhood as a terrorist entity. It is high time that United States adds its counter-terrorism voice to this issue. 

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* Also known as the Society of the Muslim Brothers.

MILITARY UPRISING IN VENEZUELA IS A REAL POSSIBILITY

Leopoldo Lopez, the former Opposition leader in Venezuela, has been freed from prison by the Venezuelan Army, and there have been calls by Opposition leaders for a military uprising. Any violence on a large scale could completely disrupt financial between Venezuela and the US & Canada. If your bank clients are trading with Venezuela, you should be closely monitoring the situation in Caracas.

PLANNER OF TERRORIST ATTACK ON KHOBAR TOWERS IN SAUDI ARABIA

WHAT WERE THREE CHINESE BULK CASH SMUGGLERS DOING WITH $3.5m AT THE AIRPORT IN CAMBODIA ?

The detention of three Chinese nationals, when they arrived at Cambodia's Phnom Penh International Airport with $3.52m in large denomination bills, begs the question; whhat did these money launderers intend to do with all this cash ? They reportedly asserted that the funds represented gambling winnings and loans from relatives, reasons that were quickly discounted. They also claimed their purpose was to invest on real estate, but they could not verify their story on Source of Funds.

The trio arrived on a flight from Hong Kong, rather than one from the Peoples' Republic, obviously a tactic meant to deceive Customs officers. Given that Cambodia is definitely not a jurisdiction where one can clean dirty money easy ans efficiently, why did the laundrymen travel there, and what made them think that they could enter Cambodia without being discovered ? There is no information regarding any efforts to bride government officials to gain entry. What was their true goal ?

HM TREASURY PUBLISHES UPDATED CONSOLIDATED FINANCIAL SANCTIONS LIST

United Kingdom readers please note that OFSI has updated its Consolidated List of Financial Sanctions Targets in the UK. You can access it here.

AYMAN AL-ZAWAHIRI, THE TITULAR LEADER OF AL-QAEDA

DID PANAMA BURY THE MOSSACK AND FONSECA CRIMINAL CASES ?

Two years after their very public arrest, the criminal cases against Jurgen Mossack and Ramón Fonseca remain in limbo, and experienced Panama watchers believe that the two name partners' case will never go to trial. it seems the law firm of Mossack & Fonseca performed confidential services for a number of officials in the current government, including the sitting President of Panama, and if they are forced to name names at trial, several high-level officials presently holding office will have their corrupt acts exposed. Do not expect to see them pay for their crimes, as Panama's corrupt judicial system operates on a cash-and-carry basis for bribes, which are paid to judges, prosecutors, and even legal secretaries.

Just as important is the present status of all those attorneys, paralegal assistants, secretaries and overseas satellite office managers of M & F, who formed the anonymous companies, and hid client assets, many of whom simply deleted Mossack from their resumés, and moved on, in other Panama City law firms. Did they take some of the firm's prized clients with them ? One must assume that to be the case, due to the personal relationship some of the Mossack staff had with their dodgy clientele. We have previously identified most of the M & F alumni, in prior articles on this blog; use the white search box to locate them. 

Will the Mossack Fonseca criminal case die for lack of prosecution ? We cannot say, but it certainly is beginning to look that way.

CONVICTED PFLP TERRORIST ARRESTED IN SOUTH TEXAS IN MONEY LAUNDERING/TERRORIST FINANCING INVESTIGATION

George Zahi Rafidi, convicted  and imprisoned for terrorist acts in Israel, and who lied about his membership in the Popular Front for the Liberation of Palestine when he applied for political asylum in the US, has been arrested by Federal authorities in Brownsville, Texas, in connection with a money laundering investigation. Rafidi was sentenced to 18 months imprisonment for acts he committed for the PFLP, including attempted arms trafficking, but he was later released and deported in a prisoner exchange. Local media believe the investigation involves terrorist activity.

Rafidi, who entered the US on a tourist visa, concealed his PFLP membership when seeking asylum, and a Federal indictment is pending against him for making false statements and fraud. His arrest, however, appears to be connected to a money laundering investigation involving the operation of underground casinos. There is no additional publicly available information concerning how the money laundering is connected to terrorist financing.

Twenty one motor vehicles reportedly owned by Rafidi's brother Fayes, at two automobile sales businesses, were seized, as  well as cash, documents and computers.

US RESPONDS TO HASHEMI NEJAD DISMISSAL MOTIONS, SAYS THERE ARE MORE ST KITTS CBI PASSPORTS HOLDERS INVOLVED IN MONEY LAUNDERING CASE

The US Attorney's Office in New York, responding to the many motions to dismiss prepared by the lawyers for the Iranian defendant Ali Sadr Hashemi Nejad, the owner of the defunct Pilatus Bank of Malta, has filed an extensive 97-page Memorandum of Law,  responding adequately to each and every pending defense motion. The memo contains extensive citations to relevant favorable authorities, and the motions will most likely be denied, as the allegations appear to be properly pled, in what is essentially a sanctions evasion and money laundering case.

While defense counsel has a professional obligation to zealously represent their client, multiple motions, as a sort of shotgun approach, are often filed to test the sufficiency of the indictment, but they generally do not survive. Since all well-pleaded allegations are taken as true for the purposes of a motion to dismiss, well pled counts on an indictment are seldom dismissed through motion practice, especially in Federal Court, where memoranda of law are required.

The motions, for those who did not read our prior article, include failure to state an offense, failure to state a conspiracy to defraud,, to dismiss bank fraud, to dismiss for lack of specificity, and for a Bill of Particulars. to strike, and to suppress evidence.

Of particular interest was the statement that Ali Sadr Hashemi Nejad was not the only Iranian national using a St Kitts & Nevis Citizenship by Investment passport to conduct sanctions. though other CBI passport holders were not named, the memorandum does make reference to them. St Kitts remains one of the five East Caribbean states still selling CBI passports, notwithstanding that the European Union policy is to discourage their Member states from issuing them, for their abuse by money launderers, financial criminals, and terrorist financiers.

ABD AL-AZIZ AWDA, SENIOR PALESTINIAN ISLAMIC JIHAD WANTED BY USA

MALTA DEAD LAST IN THE EU ON TIME TO COMPLETE MONEY LAUNDERING CASES

If Malta is the country presently sitting on the hot seat among all the Members of the European Union on a number of issues; corruption, the Panama Papers, its Citizenship by Investment program, its dodgy foreign-owned banks, and the unsolved murder of an investigative journalist, it just got worse.

EU Statistics are out, and they show that Malta is dead last among Members, regarding the time it takes to finish money laundering cases. The graph shows that it takes more than 1400 days to complete such cases; that's almost four years. In that period of time, defendants can transfer their ill-gotten gains to jurisdictions where they will never be recovered, destroy documents and other  evidence, intimidate witnesses, relocate their immediate families, and launder millions more, while conveniently out on bond. What's wrong with this picture ?

Malta's reputation among the Members of the European Union continues to slip; this news about the sad fact that, to obtain a money laundering conviction in an active case takes 3.8 years on average, will further raise Country Risk on that jurisdiction, in the eyes of compliance officers, as well as any attorney who has ever taken a case to trial.

HERE ARE THE THREE HEZBOLLAH FINANCIAL FACILITATORS NAMED BY REWARDS FOR JUSTICE

 Here are the images of three Lebanese "businessmen" (read: Hezbollah) named by the Rewards for Justice program, in connection with the issuance of the $10m reward for information leading to  the disruption of the financial mechanisms of Hezbollah.

Adham Husayn Trabaja DOB 24 Oct 67

Ali Youssef Charara DOB 9 Sep 68

Mohammad Ibrahim Bazzi DOB 10 Aug 64

SUMITOMO MITSUI BANK SIGNS CONSENT AGREEMENT WITH FEDERAL RESERVE BOARD

Sumitomo Mitsui Bank has entered into a Consent Agreement with the Board of Governors of the Federal Reserve System, requiring the bank to improve its AML/BSA compliance. Readers who wish to review the complete text can access it here.

US TREASURY SANCTIONS EUROPEAN-BASED COMPANIES FOR TIES TO HEZBOLLAH

The Office of Foreign Assets Control, OFAC, has given a number of European companies SDGT designations, for their use by Hezbollah agents as terrorist financiers and facilitators. The individuals named are WAEL BAZZI and HASSAN TABAJA, both of whom are linked to family members who are active in Hezbollah. The authority is the Hezbollah International Financing Prevention Act.

The corporations are:
(1) BSQRD Limited, Cheshire, United Kingdom.
(2) OFFISCOOP NV, Antwerp, Belgium.
(3) VOLTRA TRANSCOR ENERGY BVBA, Antwerp.
(4) ENERGY ENGINEERS PROCUREMENT AND CONSTRUCTION a/k/a GLOBAL   TRADING  GROUP, Antwerp, Freetown, Sierra Leone, Banjul, the Gambia, Abidjan, ivory Coast, Cotonu, Benin.

KHOBAR TOWERS BOMBING LEADER STILL AT LARGE

ESTATE OF AMERICAN KILLED BY HAMAS TERRORISTS DURING FAILED KIDNAPPING SUES IRAN AND ITS BANKS FOR $360m

The estate of an American murdered in Israel by Hamas terrorists seeking to kidnap him has sued Iran, the IRGC, and several prominent Iranian banks in US District Court in Washington, for $60m plus $300m in punitive damages. Eitam Henkin and his wife were shot and killed on a major highway, in their family car, while their four young children watched from the back seat. The terrorists were convicted, and are now serving multiple life terms in prison; their residence was destroyed. The minor children are also plaintiffs in the suit.

The action, which was brought under the terrorism exception of the Foreign Sovereign Immunities Act, names Iran, the IRGC, The Iranian Ministry of Intelligence and Security, Bank Melli, Bank Saderat, the Syrian Arab Republic, and Iran's central bank, Bank Markazi Jomhouri Islamic Iran.

Researchers of terrorism and terrorist financing may want to review the Complaint, which is extensively footnoted with terrorism references, most of which are hyperlinks to relevant documents and articles. The style is The Estate of Eitam Henkin, et al vs. the Islamic Republic of Iran, et al Case No,: 19-cv-1184-RJL ( D.D.C.) See the pages below for all defendants.

IS THE STORY OF DONALD TRUMP'S MISADVANTURE IN PANAMA IN THE MUELLER REPORT, BUT REDACTED FOR NATIONAL SECURITY REASONS ?

Donald Trump at the Trump Ocean Club

 
The controversy over the more damning details regarding Donald Trump's alleged nocturnal actions in Moscow, during the Miss Universe pageant in 2013, surfaced again yesterday, when text messages from a Russian contact of Trump attorney Michael Cohen appears to have proven that Trump knew about the so-called Russia tapes back in 2016 surfaced in the media. Whether the tapes actually exist today remain a mystery, but there is another dark episode in Donald Trump's life that may be in the Special Counsel's Report, but redacted for national security reasons.

During the period when Donald Trump was traveling to the Republic of Panama, in support of the Trump Ocean Club project, multiple Panamanian sources have confirmed that he engaged in similar conduct in Panama City, and that such activities were the subject of pre-planned video surveillance on the part of the Panamanian government. Those tapes are known to exist, as is the identity of the individual who engaged in the act of taping Trump, as well as who currently has possession and control of them. They are also said to be far more damaging than that the Russia tapes.

Given the extensive investigation conducted by the Office of Special Counsel, we doubt that Robert Mueller was not aware of the existence of this material, which has been curiously not reported in mainstream American media. Is this story in the Mueller Report, but redacted because of the national security implications ? If an adversary of the United States was to gain access to a copy of the tape, could they not exert undue influence over Trump to bend to their wishes ?

Russian organized crime is deeply entrenched in Panama; in truth and in fact many Russian nationals of colorful backgrounds purchased units in the Trump Ocean Club. Do the Russians have a copy of that tape ?

Also, given that a number of Specially Designated Global Terrorist organizations not only operate in Panama City, but are allowed to maintain offices there, to facilitate their money laundering activities,  there is a clear and present danger that one of those organizations might gain access.

Lastly, do mainstream American media have this story, but for some reason have declined to publish it, and thus incur the wrath of the Trump Administration ?

SEMION MOGILEVICH: AMERICA'S MOST WANTED RUSSIAN CRIMINAL MASTERMIND

COMPLIANCE OFFICERS, REMEMBER THAT CANADIAN LAWYERS ARE EXEMPT FROM REPORTING REQUIREMENTS UNDER MONEY LAUNDERING LAWS

If you are a compliance officer in the United States, and your international client or bank customer is dealing with you through a Canadian attorney, note well that lawyers in Canada are exempt from the reporting requirements inder Proceeds of Crime and Terrorist financing Act, as well as all regulations promulgated thereunder. You can thank the Supreme Court of Canada for that, as a 2015 decision of the Court held that requiring them to disclose information about their clients violated the attorney-client privilege, and that the legal profession was the sole regulatory body for lawyers.

If you were wondering just how efficiently the various law societies in the provinces are with regulation, an attorney in British Colombia, who laundered CAD$25m through his trust account, received only a 6 month suspension, and a twenty five thousand dollar fine, which represented his fee in the matter. Oh, and it took five years for that decision to be handed down. Do we trust Canadian attorneys that funds they send from their trust accounts are clean ?

Govern yourself accordingly, compliance officers.

LAWYERS FOR VICTIMS IN HEZBOLLAH BANK CASE OPPOSE BEIRUT ATTORNEY'S MOTION TO INTERVENE

The law firms representing the victims of terrorism that are suing most of Lebanon's banks in US District Court in New York have filed a memorandum of law in opposition to attorney Achraf Safieddine's Limited Motion to Intervene. The attorney is seeking to have all allegations that he is associated with Hezbollah-controlled corporations removed from the Complaint.

The issues presented;
(1) The attorney fails to meet the legal standard necessary to intervene. He has no interest in the transactions, or the outcome.

(2)  He cannot prevail on his Motion to Intervene, under the case law interpreting the rules of procedure.

(3) If his motion was granted, it would result in a large amount of litigation, not relevant to the case at hand, to determine the attorney's extent of his relationship, if any, to Hezbollah and its money laundering operations.

The attorney wants to clear his name, and the plaintiffs want to test the sufficiency of their evidence in court.

HUSAYN MUHAMMAD AL-UMARI "THE BOMB MAN"

CHOKSI'S PARTNER IN CRIME ALSO SEEKS ANTIGUA CBI PASSPORT WHILE FIGHTING EXTRADITION IN THE UK, BUT IS REJECTED

Mehul Choksi and Nirav Modi

Nirav Modi, the nephew and fellow bank fraudster of Mehul "CBI" Choksi, has been turned down after he applied for a Citizenship by Investment passport from Antigua & Barbuda. Choksi, his uncle and co-defendant in the Punjab National Bank fraud case in India, has delayed his extradition indefinitely, relying upon Antigua's notoriously corrupt court system to deny India justice.

Modi, who is himself fighting extradition to India from the United Kingdom, also sought a passport in Singapore, according to Indian media reports. Modu was monitoring his uncle's successful dilatory actions in Antigua while living in Britain,  and thereafter filed his own application for a CBI passport.

Antigua's reputation as an East Caribbean state that follows the Rule of Law has taken a major hit, due to the country's failure to extradite Choksi to India, where he is the country's most wanted white collar criminal. His Antiguan attorneys have totally blocked his extradition since last August, notwithstanding that he has lost all his motions and appeals, as no local judicial officer will remove him. It is believed that bribes have cemented their cooperation with his lawyers, who have successfully prevented Leroy King, Antigua's ex-financial regulator, from being extradited for more than a decade.

Modi was only refused a CBI passport because of all the attention Choksi has received; far too many white collar criminals have received CBI passports from Antigua, St Kitts, Dominica and Grenada.

US ENDS IRAN OIL SANCTIONS WAIVERS; WATCH FOR JAPAN, SOUTH KOREA, TURKEY RISK LEVELS TO RISE

 

The United States has announced that it will not renew the six month Iran oil sanctions waivers it extended to six countries when they expire in May. Japan, South Korea & Turkey, which are among those countries granted waivers, have not agreed to cease purchasing oil from Iran. Those nations will therefore be at risk for US sanctions and penalties. The United States could seek to enforce to sanctions, though these countries are allies.

Compliance officers at financial institutions in North America and the EU may want to increase Country Risk for: Japan, South Korea & Turkey.

US OFFERS $10m REWARD FOR INFORMATION DISRUPTING HEZBOLLAH'S ILLICIT FINANCIAL NETWORK

The US State Department, through its Rewards for Justice program, which provides financial incentives for information leading to the arrest of terrorists and terrorist financiers, has announced a new, proactive program against Hezbollah. Individuals who provide "information leading to the disruption of the financial mechanisms of Lebanese Hezbollah" will receive a reward of up to ten million dollars.

Reward will be provided for information that leads to the identification and disruption of:
(1) A significant source of revenue for Hezbollah, or its key financial facilitation mechanisms.
(2) Major Hezbollah donors and financial facilitators.
(3) Financial institutions and currency exchange houses that knowingly facilitate significant Hezbollah transactions.
(4) Businesses and investments owned or controlled by Hezbollah.
(5) Front companies engaged in international procurement of dual-use technology.
(6) Criminal schemes involving Hezbollah members and supporters, who are financially benefiting the organization.

DO WE NEED AN INTERNATIONAL COURT AGAINST CORRUPTION, FRAUD AND MONEY LAUNDERING ?

Transnational crime often adroitly exploits the gaps between jurisdictions. Here is a proposal for the establishment of an international court to plug that gap, and redistribute the seized criminal proceeds equitably, Establish the International Court against Corruption,Fraud and Money Laundering

YASIN AL-SURI: AL-QAEDA'S SENIOR LEADER IN IRAN

REVOLUTIONARY GUARD LAUNDERING OF CONSTRUCTION FUNDS INTO CANADIAN REAL ESTATE PRESENTS A MAJOR CHALLENGE FOR CANADA

The massive flooding experienced recently in Iran IS said to have occurred in large part due to underfunded construction of dams and railway lines by the Islamic Revolutionary Guard Corps. Reportedly, the floods are so bad that IRGC leaders, seeking to examine the problem up close, have been stranded in the field. The IRGC is known to have diverted huge sums from construction projects that it was building, resulting in substandard structures. While Iran now faces reconstruction, the IRGC actions have created a money laundering here problem in the Western Hemisphere.

Much of the millions stolen from the IRGC-managed construction projects  was laundered through the purchase of real estate in Canada; the previous government there has been accused of willful blindness in allowing dodgy capital from Iran to acquire large real estate holdings, much of it in the Province of Ontario. While the current Canadian government has ramped up its anti-money laundering program, it will take years to uncover all the properties purchased with IRGC flight capital. It seems that Canada's zeal to attract foreign capital has gone astray.

Note that there are some allegations that the IRGC, while placing most of its diverted funds in Canada, has also purchased properties in the United States, especially in California, though to date no evidence has been made public.

RICARDO MARTINELLI WILL FACE STILL MORE CHARGES IF THE US & PANAMA MODIFY THEIR EXTRADITION TREATY

Reliable sources have confirmed that the United States and the Republic of Panama are engaged in negotiations which, if successful, will result in a modification to the existing extradition treaty between the two nations. This will spell big trouble for Ricardo Martinelli, Panama's charismatic former president now on trial in Panama, because a new treaty is said to carve out exceptions to the international Doctrine of Specialty.

The Doctrine of Specialty is an important principle of international law; it provides that a criminal defendant may only be tried for the crime or crimes that he or she was extradited for; no additional charges may be brought once the individual has been extradited to the receiving country. This rule has been incorporated into Federal criminal law in the United States, and it is also the law in Panama.

Apparently, the United States and Panama find a mutual benefit to creating an exception to this rule, which would allow the addition of new charges, provided the country that extradited the defendant consented. The US often wants to pile on additional charges upon defendants extradited from Panama, and Panama has several major other felonies on file that Ricardo Martinelli faces at home, none of which were a part of his original extradition warrant, which was limited to his illegal surveillance upon Panamanian leaders, businessmen and other civilians, and is known as Political Espionage under local law. it clearly wants to be able to prosecute Martinelli for all his crimes at this time.

Will Ricardo Martinelli now be tried on all his pending cases, and spend the rest of his life in a Panamanian prison ? We cannot say, but we will be closely monitoring his case, as well as the effoerts of Panama and the US to change the game on extradition law.

MOHAMMAD AL JAWLANI, LEADER OF AL NUSRAH FRONT

ENHANCED DUE DILIGENCE IS NOW THE ORDER OF THE DAY ON ALL TRANSACTIONS EVEN REMOTELY RELATED TO HIGH-RISK JURISDICTIONS

As you can see below, from the HM Treasury Advisory on money laundering and terrorist financing countermeasures and monitoring required for high-risk countries, enhanced due diligence is required for all Iranian transactions. It is humbly suggested that you apply this wisdom regarding enhanced due diligence above and beyond what is required, meaning only Iran and the DPRK. Smart compliance officers are now employing enhanced due diligence measures on ALL countries that have ever been on the FATF list, are known source countries for narcotics, or are known to allow, or facilitate, terrorist financing.

Consider ordinary due diligence to be obsolete for any queries other than low-risk jurisdictions.

FLORIDA ATTORNEY GENERAL: FLA SUPREME COURT HAS NO JURISDICITION IN FACIAL RECOGNITION CASE

 

The Attorney General has filed brief to the Florida Supreme Court in Lunch v. State, the District Court decision that holds law enforcement does no have to submit all the results of a facial recognition software program search to the attorneys for a criminal defendant so identified by it, under the Brady decision.  The thrust of the brief is that the high court has no basis to invoke its discretionary jurisdiction to hear the case, and that therefore the Lynch  case should remain the law in Florida on the subject. Brady requires that evidence that would tend to prove innocence must be disclosed to the defense.

The issues presented;

(1) There is no Conflict Certiorari, which would give the Supreme Court the ability to hear the case, as the two cases cited by the Petitioner are not on point with the Lynch facts, on the same question of law.

(2) To prevail under Brady, Petitioner must show that the results of the trial would have been different if the suppressed document were admitted into evidence. Non-matching photographs produced in a facial recognition program search would not have resulted in a verdict of innocence, as they would not have cleared the defendant.

(3) The lower court did not expressly construe any Constitutional provisions in its opinion.

(4) The lower court did not ask the Supreme court to Certify a point, based upon a question of great public importance.

If the Court declineS to hear the case, then Lynch v. State shall remain the rule in the State of Florida, and law enforcement agencies and prosecutors will not be required to disclose all results obtained through a facial recognition system search being used to identify a criminal defendant.

Readers who wish to review the brief may access it here.

HAMZA BIN LADEN REWARDS FOR JUSTICE POSTER

IRAN CONTINUES TO PUSH BACK ON IRGC SANCTIONS THROUGH CLEVER PROPAGANDA

 
We are continuing to see subtle Iranian manipulation of global public opinion, seeking to plant the thought that America's sanction of the Islamic Revolutionary Guard Corps was a mistake. Today's example comes from a UK website, run by Iranians,  Bourse & Bazaar*, which has published an article tellingly entitled Iranian Bankers fear IRGC Terrorism Dooms Vital Financial Reforms, which attempts to convince the reader that reform cannot occur in Iran, specifically  due to the IRGC sanctions.

The article goes to great lengths to detail a ficticious AML/CFT reform movement, now cut down by the IRGC sanctions. Other articles on that B & B website may look like objective reporting, but they have a distinctly anti-American perspective, often seeking to mold public opinion through spin and disinformation.

Given that Iran is a State Sponsor of Terrorism, any belief that AML/CFT will ever occur, as a matter of state policy, is not only an illusion, but is an artful attempt to reach out to a global audience with a hidden agenda. This is just one more example that we found today. Expect to see more examples of  such grey propaganda, using "white' media, not identifiable as Iranian-controlled, to push back at the OFAC SDN designation in a public forum.
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*https://www.bourseandbazaar.com/




 

HAMAS EL KHAIRY - LEADER OF MOVEMENT FOR UNITY AND JUSTICE IN WEST AFRICA

LACK OF FREE PRESS IN THE EAST CARIBBEAN STATES AFFECTS DUE DILIGENCE IN NORTH AMERICA

Compliance officers at financial institutions in Canada and the United States who are conducting due diligence on individuals or companies located in the East Caribbean CBI states, and who routinely access open-source information on the internet, in an effort to check out applicants for new accounts, should be aware that, in essence there is no truly free press in the region, and a large degree of self-censorship exists in local media. This means all news originating from the region must be taken with a large amount of salt.

Many of the East Caribbean states exist under who political scientists call "strongman" rule. the leaders of those countries, though legally elected, remain in power through a combination of bribes, kickbacks, offers of employment, threats, and in some cases, physical violence perpetrated upon their voting population. There are few, if any, democratic checks and balances upon their power, and generally, the members of local parliaments are allied with the leaders, and often receive monetary compensation, of one sort of another, to remain so.

Local media exists under the shadow of these powerful leaders, and most is pro-regime, receiving advertising revenues as an incentive to publish only favorable news and feature stories. The few  media outlets that expose corruption, money laundering, illegal Citizenship by investment or diplomatic passport scandals, often find themselves the target of regime action, including bogus arrests and civil libel or slander actions, or some other form of intimidation. In rare cases, violence against journalists seeking to publish the truth occurs, as we saw in the incident in Malta, where a crusading journalist was murdered by a car bomb.

The influence of powerful and wealthy CBI consultancies, who have a vested financial interest in suppressing negative news, which could impact Citizenship by Investment (CBI) passport sales abroad, is also a problem, for they are allied with the corrupt local regime leaders who do not want those lucrative sales impacted in any way. The CBI consultancies also go after journalists who are whistle blowers about corruption, governmental misconduct,  and suspicious official conduct involving money laundering.

Compliance officers in North America should therefore not consider local East Caribbean media stories as truthful, when conducting due diligence inquiries, and should not interpret the lack of negative information about a target subject as positive, for the truth may be suppressed, either by pro-government media, or self-censorship of opposition media concerned about survival.

IRANIAN PROPAGANDA CLAIMS US SANCTION OF IRGC KILLED AML PROGRAM EXPANSION

It appears that Iran is quite upset with the US sanction of the Islamic Revolutionary Guard Corps (IRGC). It has deployed Internet propagandists to allege that the sanctions reduce the chances that Iran will ever adopt "international standards on money laundering and  terrorist financing."

The article, which appeared on antiwar.com, claimed to be taken from a website cleverly called The American Conservative . The article claimed that "hardliners" would now insure that so-called reformers like Rouhani would not be able to pass bills designed to counter money laundering. In truth and in fact, there are NO reformers in Iran, just various shades of radical.

Of course, this propaganda leaves out the simple fact that the powers that rule Iran have absolutely no interest in abandoning their country's role as a State Sponsor of Terrorism. They believe that any effective AML/CFT program adopted by Iran favors the Western democracies, and is a threat to their regime.

Call this article a small part of Iran's Information Warfare; it is designed to cause discord and dissent over American sanctions on Iran. Since one cannot tell which articles are artful propaganda abut Iran and which are truthful news stories. Therefore, ignore ALL Internet information on Iran, unless you personally have vetted the source, lest you buy propaganda as truth.