TURKISH BANKER CONVICTED IN IRAN OIL-FOR-GOLD SANCTIONS EVASION CASE RELEASED FROM PRISON, RETURNS HOME

Mehmet Hakan Atilla, the former senior officer at Turkey's state-owned Halkbank, who assisted Reza Zarrab in paying billions of dollars in gold for illicit Iranian oil sales, has been quietly released from Federal Prison, having served his sentence, and returned to his native Turkey. Atilla served most of a 32-month sentence, having received credit for his pre-trial confinement.

Reza Zarrab, the principal defendant in the case, testified against Atilla after he began cooperating with US law enforcement. Zarrab's partners in the massive billion dollar oil-for-gold sanctions evasion scheme, Babak Zanjani and Alireza Monfared, are both known to be in custody in Iran; Zanjani was sentenced to death; Monfared has not been seen since he was taken into custody and flown to Iran.

 It is not known whether Zarrab has been sentenced, as several pleadings in his court file are sealed and unavailable to the press and public. He has testified, before a Grand Jury, in a major pending investigation conducted in the Southern District of Florida, related to The Office of Special Counsel inquiry into whether the Government of Russia illegally influenced the 2016 US Presidential Election.

IRANIAN HACKERS WANTED BY FBI

ANTIGUA ATTEMPTS DAMAGE CONTROL AFTER ITS DIPLOMAT IS CHARGED WITH MONEY LAUNDERING

In the aftermath of the fallout surrounding the American money laundering indictment of Alex Nain Saab Moran, the Antiguan Economic Envoy, who holds a diplomatic passport from Antigua & Barbuda, the government is desperately trying to distance itself from the scandal. Saab is a Colombian national of Middle Eastern extraction; in fact, when his accountant and auditor were arrested in Colombia, and Saab was a known fugitive from justice in Colombia,  the Antiguan government was still singing his praises.

In a thinly-disguised press release appearing in local media, purporting to originate from the Foreign Ministry, but actually issued by Maurice Merchant, the press agent in the office of Prime Minister Gaston Browne, the fact that Antigua is not specifically named in the indictment is employed to allegedly show that Saab passed no illicit financial transactions through its banks, and that he was not really involved in Antigua. Nothing could be further from the truth.

In truth and in fact, the SAAB indictment alleges that the defendant, and his partner, Alvaro Pulido Vargas, also a named defendant in the criminal case, laundered the proceeds of crime through US banks, especially those located in Miami, and the money then went onward into tax havens abroad. Considering that Saab owned an offshore bank in Antigua, and also moved money through one of Antigua's largest locally-owned banks, we must assume that Antigua is one of those unnamed offshore financial centers.

Additionally, where Mr. Merchant claims Saab had only a minor connection with Antigua, perhaps he would care to explain how A & B Prime Minister Gaston Browne publicly stated that Saab was a "close personal friend," and that he was destined to assist Antigua to develop to its total potential. Antiguan businessman, with Browne's approval, visited a factory in Venezuela said to be owned by Saab.

 It was PM Browne that named Saab Economic Envoy, and sold him that diplomatic passport, when he was already listed as a high-risk individual in the databases used by the world's financial institutions, and for due diligence purposes. Does this mean Antigua does not check out foreign applicants whom is sells diplomatic passports to for cash ?

I am afraid that it is a bit too late from Browne to claim that Saab was only an acquaintance; We wonder just how the Saab indictment reflects the level of ongoing US law enforcement investigations into money laundering and official corruption in Antigua. 

GRU HACKERS WANTED BY THE FBI

KOSOVO DESIGNATES HEZBOLLAH A TERRORIST ORGANIZATION

The Republic of Kosovo has named Hezbollah a terrorist organization; this designation follows the position of the European Union. Countries that have also listed Hezbollah as a global terrorist organization include the United States, United Kingdom, Canada, Germany, the Arab League, Israel and the Netherlands. 

REGULATORY AGENCIES' PUBLISH JOINT STATEMENT ON RISK FOCUSING

All the principal American financial regulatory agencies, OCC, NCUA, FDIC and FRS, have issued a Joint Statement on Risk-Focused Bank Secrecy Act/Anti-Money Laundering Supervision.  The white paper explains that agency auditors will focus on the requirement that banks and credit unions to identify, measure, monitor and control risks, and to report possible money laundering, terrorist financing and illicit financial activity.

It further reminds us that the risk-focused approach is the foundation for the FFIEC BSA/AML Examination Manual. Readers who wish to review the Statement, may access the complete text here.

FBI OFFERS $1m REWARD FOR ROMANIAN FRAUDSTER

SWITZERLAND'S TRIBUNAL FEDERAL RULES DATA ON 40,000 UBS CLIENTS WILL GO TO FRANCE

The Tribunal Fédéral, the Swiss appeals court has held that data on 40,00 UBS clients can be delivered to Paris tax authorities. The decision, which was an appeal taken by the Swiss Federal Tax Authority, reversing a ruling of the Swiss Federal Administrative Court. French tax authorities were seeking information on UBC client who were French citizens or residents suspected of tax evasion.

UBS has a boatload of other problems, including:
(1) Its pending appeal of the €3.7m penalty imposed by France, after a finding that UBS facilitated tax evasion.
(2) The $780M fine, imposed by the United States for aiding & abetting tax evaders.

Readers who wish to review the court decision (in French) will find it below.

FRONT AND SHELL COMPANIES EMPLOYED BY ALEX SAAB MORAN TO LAUNDER THE PROCEEDS OF CRIME

Compliance officers should check these corporations carefully, as they are all OFAC-sanctioned front and shell companies utilized by accused Colombian money launderers, Alex Saab Moran and Alvaro Pulido Vargas, to move criminal proceeds through the international financial structure, and launder them. Are you banking any of these companies, or have your bank clients conducted any transactions with them ? They are now all OFAC Specially-Designated Nationals.

(1) ASASI FOOD FZE (UAE).
(2) GROUP GRAND LIMITED (Hong Kong).
(3) GROUP GRAND LIMITED, SA de CV (Mexico).
(4) MULBERRY PROJE YATIRIM ANONIM SIRKETI (Turkey).
(5) SEAFIRE FOUNDATION (PANAMA).
(6) CI FONDO GLOBAL DE ALIMENTOS LTDA. (Colombia).
(7) EMMR & CIA,, SAS (Colombia).
(8) GLOBAL STRUCTURE, SA (Panama).
(9) MULTITEX INTERNATIONAL TRADING, SA (Panama).
(10) SUN PROPERTIES LLC (Delaware).
(11) CLIO MANAGEMENT CORP (Panama).
(12) SILVER BAY PARTNERS FZE (UAE).

ALEX NAIN SAAB MORAN



Research Note: Readers who wish to review the Indictment may access the complete text here.
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PEOPLES' LIBERATION ARMY HACKERS COMMITTED INDUSTRIAL ESPIONAGE AGAINST US COMPANIES

US INDICTS COLOMBIAN MONEY LAUNDERER WHO IS AN ANTIGUAN DIPLOMAT AND CLOSE ASSOCIATE OF VENEZUELA'S NICOLAS MADURO

Alex Nain Saab Moran, a Colombian national who reportedly cleaned $350m in a massive illegal bribery scheme that violated the FCPA, much of which he moved through South Florida, and into overseas accounts, has been charged with seven counts of money laundering, and one count of money laundering conspiracy. Saab's partner, Alvaro Pulido Vargas was also charged with those crimes.

There were meetings, in furtherance of the money laundering operation, conducted in Miami, Florida. One of the shell companies used by the defendants maintained its principal address in the downtown area.The $350m forfeiture allegations specified that more than $12.5m in cash was seized by the US Government in 2018 & 2019.  Saab's close relationship with Venezuela's president Nicolas Maduro allowed him to perpetrate a multi-million dollar fraud upon the Venezuelan treasury and economy, using the special Dollar-Bolivar exchange rate, and being paid for invoices where he failed to deliver the goods under sweetheart government contracts.

Significantly, after Saab's accountant and auditor were arrested by Colombian law enforcement, and the fact that he was a wanted man in his native Colombia became public knowledge among bankers and attorneys in the Caribbean, the Government of Antigua & Barbuda refused to strip him of his Antigua diplomatic passport, and denied that he had been engaged in illegal activities in Antigua. Saab allegedly laundered dirty money through a private bank in Antigua that he owned, and also through a local indigenous Antiguan bank known to be facilitating drug money laundering.

It is not known whether either defendant is in custody. Given the amount alleged to have been laundered, and the number of counts, each of the defendants face a possible Life Sentence. We shall cover the shell companies sanctioned by the US Treasury in a subsequent article.
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*Saab had previously owned two private banks in the Commonwealth of Dominica, ASA BANK AND TRUST CO. and FGC BANK AND TRUST, both of which had their licenses revoked.

FBI WANTED POSTER - HACKERS FROM CHINESE MINISTRY OF STATE SECURITY

WILL THE EU BAN CARIBBEAN CBI PASSPORTS IN 2020, BECAUSE OF THE 5TH MONEY LAUNDERING DIRECTIVE ?

If you closely review the Fifth Money Laundering Directive, which takes effect in 2020, you will learn that EU Member States will be required to institute Enhanced Due Diligence (EDD) on all applicants for their Citizenship by Investment (CBI) program. Currently, Malta & Cyprus are operating the only active CBI programs, as Moldova has suspended its new program.

But what about the CBI/CIP programs operated by the five East Caribbean States, St Kitts & Nevis, Antigua & Barbuda, Dominica, Grenada and St Lucia ? As we have painfully observed in recent years, there are no true EDD investigations conducted in those jurisdictions; career criminals, corrupt PEPs, sanctions evaders, fraudsters, drug traffickers and other suspects have been approved for CBI passports in the East Caribbean States, which confirms that due diligence, if it is not totally suspended after bribes are paid, is ineffective at best.

Therefore, given the EDD requirements of the 5th MLD, will Schengen Zone Border agents in the countries of the European Union be required to reject CBI passports from the East Caribbean in 2020 ?  Are such passports, which were issued based upon non-compliant programs, not acceptable under EU law ?

We are wondering which EU agency will ultimately rule upon this issue, and what response the global citizenship consultancies, which rely upon EC CBI sales for most of their income, will muster. Will those firms disclose this to applicants in the future ? We seriously doubt it, for the value of CBI passports issued by East Caribbean States may decline, and become less attractive, if only due to the fear that they might eventually become worthless for entry into the countries of the European Union.

Are CBI passports issued by the countries of the East Caribbean now an endangered species ?

  

ICIJ ANNOUNCES THE MAURITIUS LEAKS, DETAILS OF OFFSHORE TAX EVASION

The International Consortium of Investigative Journalists (ICIJ) has announced that it has published a database of information, collected from professional firms doing business in the offshore tax haven of Mauritius,  showing how multinational corporations cheat African, Asian and Middle Eastern countries out of millions of dollars in taxes.

The tax haven professionals have enabled the multinationals to exploit tax loopholes that deny some of the world's poorest countries essential tax revenue. Information on 200 of the world's biggest companies, and how their attorneys and accounting firms work the system of Mauritius' favorable tax laws to their clients' advantage.

Readers can find the Mauritius Leaks  here.

PARK JIN HYOK, NORTH KOREAN HACKER IN SONY PICTURES CASE; HAS BEEN SEEN IN CHINA

MALTA'S ANTI-MONEY LAUNDERING PROGRAM IS RATED "POOR" BY MONEYVAL

MONEYVAL, the Council of Europe's anti-money laundering monitoring agency, has given the Republic of Malta a "Poor Overall Rating," at its recent plenary meeting, which is essentially an "F". The country, which had received a failing grade in a prior draft report did not make any of the necessary reforms to increase its final score. One source stated that the final report was essentially identical to that of the draft report. The "Poor" rating was handed down due in part to the country's complete and total lack of attention to the problem areas cited by the regulatory agency.
'
Leaks of the final report appeared in local media in Malta, and the government's first concern was the source of the leak, rather than the truth of the statements contained therein. the report may have been confidential, and the Ministry of Finance of Malta publicly complained about the leaks, but it ignored the sad truth about the dysfunctional status of AML/CFT in Malta. Government in Malta disputes the findings of fact made by MONEYVAL.

Should Malta fail, within one year, to remedy the many defects in its anti-money laundering program, it will be designated a "High-Risk Jurisdiction," which is MONEYVAL's blacklist, a step guaranteed to seriously damage the country's financial industry.

RUSSIAN HACKERS WANTED FOR BANK FRAUD AND MONEY LAUNDERING

CFTC ISSUES GUIDELINES FOR CIP AND BENEFICIAL OWNERSHIP

The Commodity Futures Trading Commission has issued Inerpretive Guidance Regarding Voice Broker Customer Identification Program and Beneficial Ownership Rule Requirements.

NCA SEIZES €4m IN GOLD AT HEATHROW, COMNG FROM THE CAYMAN ISLANDS

Information has become available regarding a major seizure of criminal assets on June.1 The UK Border Force at that time seized 104 kilograms of gold when it arrived  at London's Heathrow Airport, on a private jet coming from the Cayman Islands. According to reports, the gold shipment, which is Cartel drug proceeds, and is said to have originated in Venezuela, was bound for Switzerland. Such a transport of illicit wealth, which completely avoids the global banking system, with its records, makes traditional tracking of narco-profits extremely difficult, if not impossible.

The National Crime Agency was identified as the source of the intelligence, and it is assumed that the authorities in the Cayman Islands alerted the NCA about the arriving flight. The question remains: if Cayman law enforcement was aware of the existence of smuggled gold on the aircraft, why did it not seize the shipment in Grand Cayman, upon arrival ?

Compliance officers have for years noted the reluctance of Cayman law enforcement and regulators to make arrests, even when crime is ongoing, investor assets at risk, or the risk of offender flight is high, in money laundering or financial crime matters. Did Cayman authorities pass the buck to the UK simply to avoid the potential negative publicity that might arise when seizure of such a large shipment of obviously criminal proceeds occurs ?

IRGC-AFFILIATED CYBER ACTORS WANTED BY FBI

COURT RULING DENYING CRIMINAL DEFENDANT ACCESS TO NONMATCHES OBTAINED IN A FACIAL RECOGNITION SOFTWARE SEARCH STANDS WHEN FLORIDA SUPREME COURT DECLINES TO HEAR CASE

Florida Supreme Court

The Supreme Court of Florida has determined that it "lacks jurisdiction" to entertain a petition filed, seeking to review Willie Lynch vs. State of Florida, A District Court of Appeal decision that held the failure of law enforcement to deliver non-matches, obtained in a facial recognition software search that identified a defendant in a narcotics sale case, was not error under Brady vs. Maryland,  a US Supreme Court case that requires defense attorneys to receive any evidence which might tend to prove the innocence of their client. The test of Brady is whether the result of the trial would have been different, had defense counsel received the evidence.

Florida's highest court ruled that the Lynch decision did not conflict with another decision of a District Court of Appeal in the same question of law. Defense counsel had submitted Florida case law but the Court  ruled that any conflict asserted was not "express and direct." This means that the decision in Lynch remains the law in Florida, which states that non-matches, which are the result of a facial recognition identification search in a criminal case, need not be submitted to defense.

MOLDOVA SUSPENDS ITS NEW CITIZENSHIP BY INVESTMENT PROGRAM

The Republic of Moldova has suspended its new Citizenship by Investment program, known as MCBI, "pending further review." The announcement was made on July 17, 2019, after a meeting of the country's Supreme Security Council. The grounds for the suspension have not been publicly revealed, though the program, and its service provider, Henley and Partners, are reportedly said to be under review, but no allegations of misconduct, or problems with the program, have been announced.

Applications that have already been approved will be completed, but no new application shall be accepted at this time.

Moldova is actively pursuing accession to the European Union, and the EU recently went on record to recommend to its Members that they abandon such programs, due to money laundering, financial crime and tax evasion concerns. Bulgaria abruptly cancelled its new CBI program, and Malta has been under severe criticism about how it has administered its program. Whether this was a major consideration for Moldova is known known, as is whether the suspension will become a permanent measure. Alternatively, it may simply have been the action of a newly-installed government, which is reportedlyreviewing all government departments and agencies.

OFAC SANCTIONS IRAQI ARMS TRAFFICKING COMPANY THAT ASSISTS IRAN IN EVADING FINANCIAL SANCTIONS

SOUTH WEALTH RESOURCES COMPANY (SWRC),  an Iraqi firm that has trafficked arms worth millions of dollars to Iraqi-based IRGC affiliated militias, and drew an OFAC SDGT designation  this week, should be of interest to compliance officers at international banks for another reason. SWRC covertly facilitated IRGC-QC access to the Iraqi financial structure, this evading international financial sanctions in place against Iran.

SWRC known aliases are:
Manabea Tharwat Al-Janoob General Trading Company
Manabea Tharwat al-Janoob General Trading Company LLC
Shirkat Manabi' Tharawat Al-janub Liltiarah Al-'Ammah
South Wealth Resources Ltd.

IRGC-QF uniform patch

The two Iraq-based SWRC officials, also both sanctioned by OFAC, who are instrumental in Iran financial sanctions evasion, are:

(1) MAKKI KAZIM 'ABD AL-HAMID AL-ASADI a/k/a Makki Kazim Al-Asadi.
(2) MUHAMMED HUSEYN SALIH AL-HASANI

Another individual involved in the SWRC arms smuggling operation is ABU MAHDI AL-MUHANDIS, previously named by OFAC. He is an adviser to OFGC-QF Commander Qasem Soleimani.

Abu Mahdi Al-Muhandis

US STATE DEPARTMENT REWARDS FOR JUSTICE $7m FOR OFAC-SANCTIONED HEZBOLLAH LEADER

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ARGENTINA DESIGNATES HEZBOLLAH A TERRORIST ORGANIZATION

The Government of the Republic of Argentina, by Decree, has designated Hezbollah a terrorist organization, and ordered that all its assets in the country be frozen forthwith. The sanctions imposed came twenty five years after Hezbollah committed two major terrorist bombings in Argentina, one against the AMIA Jewish Center, and one against the Israeli Embassy; both resulted in a large number of deaths (87 and 29 respectfully) and hundreds of injuries.

Additionally, the government has created a Register of Persons & Entities Linked to Acts of Terrorism and Terrorist Financing, designated RePET and Renapost. Argentina's act of designating Hezbollah is the first such action by any Latin American country. Its Financial Intelligence unit has ordered that all assets of individuals, and companies considered to be Hezbollah be immediately frozen.

CHINESE MILITARY OFFICER WANTED BY FBI FOR HACKING INTO US COMPANIES

HOW MANY IRANIANS HOLD EUROPEAN PASSPORTS ?

The Austrian passport; it's not ONLY for Jeffrey Epstein anymore. Epstein, whose Austrian passport, complete with alias, and a bogus Saudi Arabia residence address, was found by law enforcement in his home safe, allegedly used the Austrian passport for anonymous international travel. Iranians, who have been employing Austria'n bankers'  "Don't Ask, Don't Tell" willful blindness attitude, when it comes to dealing with sanctioned entities and individuals, have also spent the necessary €2,000,000 to obtain Austrian citizenship  and passport, under the country's Citizenship by Investment program. Many Iranians speak German, in part because they have a long history of  doing business in countries where German is spoken, especially Germany and Switzerland.

Yes, Iranians have Austrian passports, but they also hold literally thousands of CBI passports issued by Malta and Cyprus. Again, many Iranians are multilingual, and English is one of the languages most speak.

Of course, just as Reza Zarrab, Iran's billion dollar poster boy for oil-for-gold sanctions, was listed as Risa Sarraf on his Turkish passport, many Iranians have acquired EU passports in other than their original legal names.

Reza Zarrab becomes RIZA SARRAF

Compliance officers who have noticed that certain of their new high net-worth bank clients have passports that show Iranian places of birth should immediately employ their facial recognition software systems to properly identify those clients, lest they onboard PEPs, IRGC officers, or Iranians who are subject to OFAC or international sanctions.

let us suggest that, when Iranians in sheep's clothing (EU passports) are suspected, have a staff member who is a native speaker of the European language the client speaks, serve him or her. It may be easier than you think to uncover  that hidden PEP, sanctions evader, terrorist financier, or career criminal. Watch yourselves when it comes to such bank customers.