POORLY PREPARED SHARE AGREEMENT IN GRENADA SUSTAINABLE AQUACULTURE PROJECT SHOULD HAVE ALERTED INVESTORS

One of the Red Flags of white collar crime is a poorly prepared purchase contract. The Share [sic] Sale Agreement, by and between Grenada Sustainable Aquaculture (GSA) Limited and the investors/victims suffers from numerous errors and defects, all of which should have deterred them from placing any funds with GSA. No responsible professional would have never let such a substandard product leave his offices for a client.

Here are just some of the issues we found, in a cursory examination:

(1) Obviously, no attorney in Grenada prepared this agreement; as the spelling grammar and syntax, and punctuation, confirm that the author, at least of the original form, was American. British English spelling of words is absent. Was an attorney in Grenada even consulted to confirm that the terms conform to local law ? Doubtful.

(2) The typographical errors, grammatical mistakes, awkward nature of several sentences indicate that either there was no proofreading of the draft, or that the agreement was a hurried cut-and-paste operation not subsequently checked, and then performed by individuals without professional training and experience.

(3) No responsible lawyer would allow such shoddy work to be passed off as finished product. While the Choice of Law provision, which dictates the Laws of Grenada shall apply, was added, the failure of the drafter to make Grenada the exclusive place suit may be brought, known as a Forum Selection Clause,  was a major error.  You want all litigation arising out of this Agreement ro be handled in th courts of Grenada, so that justice is done.

Look at the typos and errors yourself; there are far too many to chalk it up to harmless error. If CBI investors all had attorneys to advise them, in advance of placing any investment capital on GSA, the number of victims would be far less.

SPIRO GERMENIS, FUGITIVE NY PONZI SCHEMER, MAY BE LIVING IN GREECE

VICTIMS OF GRENADA SUSTAINABLE AQUACULTURE FRAUD RELIED UPON NONEXISTENT INSURANCE GUARANTEE

 
The foreign businessmen who invested in the Grenada Sustainable Aquaculture (GSA) project were induced to participate, in large part, due to warranties, written representations and promises of the deceptively similarly named Aspen Assurance Company Ltd., located in the US Virgin Islands, which basically guaranteed a "buy back" of their investment. Unfortunately, the company now appears to be little more than a shell, without any assets to make good on its promises.

Investors, who noted that GSA was on the Grenada Government list of approved CBI projects, and who placed their money into the project, also based on that fact, were not informed about these issues:

(1) The company's official address is what we call an accommodation address, which means a mail drop. Aspen has no physical location of operation; it is a shell, not a working insurance company.

(2) The signatory on the contract is a Panamanian attorney, located in Panama City, and not admitted to the practice of law in the US Virgin Islands. The agreement recites "Legal/Contract Department" of a company that is not operating. How can he legally bind Aspen ? He is neither the firm's attorney, nor an officer. The entire agreement may be void and unenforceable.

(3) Aspen was not in 2016, and is not now, offering other insurance products to the public.

(4) No financial statement has ever been produced, to verify that assets exist to pay for the buy back obligations. where are the "two billion dollars in available assets, " that appear in the solicitation ? It is the similarly named, but not affiliated, Aspen Insurance that has billions in assets.

(5) What about the Dominica-domiciled company with the same name from 2012 ? Who are the officers and directors of both companies ?

These are just a few of the issues that stand out in this $18m scam, in which affluent investors who were acquiring CBI passports from Grenada were duped into buying shares of a sustainable aquaculture project.

Some observers are also concerned that the GSA project shares may constitute a Security for the purposes of the American Securities Act of 1933, which requires registration in the US, and disclosure of financial and other significant information concerning the investment. Were SEC rules and regulations violated ? We cannot say at this time, but further investigation is warranted.

IRANIAN MABNA HACKERS WANTED BY FBI

IMF TECHNICAL NOTE - AML/CFT REGIME FOR FRANCE

Readers who wish to access the complete text of the  France-Financial Sector Assessment Program Technical Note - Anti-Money Laundering and Combating the Financing of Terrorism Regime in France  may access it here. Then click on "download pdf." The Table of Contents appears below for your ready reference.

READ THE HOUSE IMPEACHMENT INVESTIGATION RESOLUTION

Readers who wish to review the complete text of the Resolution can access it here.

SWEDEN'S DATA PROTECTION AUTHORITY APPROVES FACIAL RECOGNITION TECHNOLOGY FOR POLICE USE

The DPA, Sweden's data protection regulator, has issued a decision approving the use of facial recognition technology, for police use. A facial recognition software platform, utilizing facial biometric screening, with be employed to help identify criminal suspects. Reportedly, Swedish police have an existing biometric database to compare facial images to.

The DPA has stated that its procedures comply with both the country's Crime Data Act, as well as the European Union's Data Protection Law Enforcement Directive, also known as the GDPR. EU legislation on the use of the technology has been promised by the European Commission.

Europe's expanding use of facial recognition technology by law enforcement is in stark contrast to the opposition, by human rights and privacy activists in the United States, which has resulted in local bans on the use of the technology on body cameras, by some law enforcement departments. Resistance to its use us centered in California, where some municipalities have enacted bans, or substantial delays, in police use of facial recognition software.

WANTED BY THE FBI FOR DDOS HACKING ATTACKS

GRENADA SUSTAINABLE AQUACULTURE PROJECT OWNER'S COMPANY HAD NO TRACK RECORD

Facility never built out by GSA.

GSA principal Soren Dawody's UK fisheries company, DF AQUACULTURE CAPITAL LIMITED, which was to be the vehicle implementing the Grenada Sustainable Aquaculture Project, has no track record in the relevant fields. We can find no DF projects, whether actually in progress, or completed, where a sustainable aquaculture environment was created. DF Aquaculture appears to be merely a shell, with no operational capability or assets. The name itself suggests it is more of a fundraising entity, rather than the builder and operator of an aquaculture system, but the company touts itself as a joint venture partner that will offer turnkey financing, training and operation of a sustainable aquaculture project. So where are the successes ?

 In truth and in fact, DF was struck off (dissolved) earlier this year, and Dawody had to reinstate it. You are referred to the documents appearing above, obtained from Companies House. Another Dawody UK company, KDF LONDON LIMITED, was also dissolved and had to be restored. Why did these companies become defunct ?

Moreover, reliable reports from Grenada have confirmed that no professional business plan was ever submitted to the Government of Grenada, which resulted in a substantial delay in issuing any leasehold to GSA to commence construction of its facilities. Those victims and commission salesmen who have been casting blame upon Government for alleged failure to adequately monitor and supervise GSA may not be aware of this fact.

In fact, an exhaustive search has failed to turn up any confirmation that Soren Dawody has ever operated a sustainable aquaculture facility anywhere in the world. All the impressive  Internet information is dated 2017, and there is nothing since to confirm that actual work was ever performed since. So where did the eighteen million dollars go ?

US FORCES REPORTEDLY KILL ISIS LEADER IN SYRIA

The United States Government has reported today that ABU BAKR AL-BAGHDADI, the leader of ISIS, has been killed on a military operation neat Idlib, Syria.

NEW YORK SUPREME COURT ORDERS RANGE DEVELOPMENTS TO PRODUCE BOOKS AND RECORDS

The New York Supreme Court has entered a order against Range Developments, ordering the company to produce the books and records of its Dominica CBI project, for a plaintiff who alleged that he was not paid a specified percentage of profits by the developer, pursuant to a contract.

CONSULTANTS WHO SOLD INVESTMENTS IN GRENADA SUSTAINABLE AQUACULTURE WERE NOT PAID

It appears that consultants who sold the $275k investments in the failed GSA project have not been paid sales commissions. A number of demand letters, totaling many millions of dollars, have been sent to Soren Dawody, the project developer, but no payments have been reported received.

Payment schedules have been proposed by Dawody to some of the investor/victims, with long-term (3 year) payouts, so the consultants have presented similar proposals, but none have been reportedly accepted, nor any funds paid, to neither the victims nor the consultants.

Some of the consultants have histories of prior involvement in dodgy investment schemes, but as participants, not as creditors, as they have curiously described themselves in their demand letters. While the consultants have also directed their demands to the Government of Grenada, their contractual relationships are strictly with the project developer.

The issue has arisen regarding possible US jurisdiction over the fraud, specifically for money laundering, since the fraudsters who failed to deliver a turnkey project for the investors, who were to receive a return on their investment in the short-term, were paid in in US Dollars, and Bank of America was the Intermediary Bank on the wire transfers of the funds.

GRU HACKERS INVOLVED IN UNDERMINING ANTI-DOPING PROGRAM

FINRA FINES BNP PARIBAS FIFTEEN MILLION FOR AML FAILURES

The Financial Industry Regulatory Authority (FINRA), has levied a $15m fine upon BNP Paribas Securities Corp. and BNP Paribas Prime Brokerage, Inc., for Anti-Money Laundering failures. FINRA concluded that the penny stock and wire transfer areas  had no effective AML programs.

Readers who wish to review the details of the FINRA action may access the News Release here.

IRANIAN HACKERS WORKING FOR IRGC STOLE DATA FROM US GOVERNMENT AGENCIES

COMPLIANCE OFFICERS BEWARE ANY LOCAL MEDIA THAT YOU DO NOT KNOW

If you are a compliance officer who reviews local newspapers online, when seeking information on prospective bank clients during due diligence investigation, be very careful. Reports this week have confirmed that bogus websites, portraying fictional local newspapers, have appeared online.

Do not trust any of the articles on those sites, because they appear to be slanted to serve a political agenda. You may encounter favorable information about your subject that contains misinformation, disinformation, or misleading data.  In short, if you do not recognize the name of the newspaper from prior experience, and do not personally know it to be legitimate, ignore the information.

TURKEY NAMES HALKBANK CEO, CONVICTED IN US, AS DIRECTOR OF STOCK EXCHANGE

Mehmet Atilla, the executive from Turkey's state-owned Halkbank, was named this week General  Manager of the Istanbul Stock Exchange, according to the country's Minister of Finance and Treasury Berat Albayrak. Atilla was released from US custody in July, after serving a term in Federal Prison for assisting in Iran's billion dollar oil sanctions evasion scheme. The Iranian oil-for-gold sanctions evasion trader, Reza Zarrab, testified against Atilla at trial.

The appeal of his conviction is pending before the Second Circuit in New York. Turkey, which alleged that the Atilla case case was politically motivated, obviously was a willing participant in the lucrative global oil-for-gold sanction evasions program operated by Reza Zarrab, Babak Zanjani and Alireza Monfared.  

While it is not specifically known why Atilla, who was the number two executive at Halkbank, did not return to a position at the bank, most countries have laws that prohibit convicted felons from serving as officers at financial institutions.

NEW OFAC REGULATION REQUIRES ALL US COMPANIES DEALING WITH FOREIGN CLIENTS TO MAINTAIN A SANCTIONS COMPLIANCE PROGRAM

The Office of Foreign Assets Control,  OFAC, has cleverly implemented an Interim Final Rule which will, in effect, require ALL companies that buy or sell goods and services to foreign entities or individuals to create, and maintain, an effective AML/CFT compliance program. While the Rule does not specifically require such a program, the only prudent response to its impact is to create one forthwith, to protect your company, not just those engaged in the delivery of financial services.

The previous law required any US company or person, to file a report with OFAC, when any transaction was blocked, due to OFAC sanctions. This usually means wire transfers, payment orders, or other types of payment. Now, if a US company decides to cancel, withdraw, or decline any business because the foreign party is OFAC-sanctioned, a mandatory report must be filed as well.

This means that OFAC will be alerted, and may review prior transactions with that foreign party, and could impose a Civil Penalty for violations. In that case, the absence of en effective AML/CFT compliance program is a major factor in possible mitigation or even elimination of a large fine; a company's failure to have, in place, a compliance program is always specified in the "Name & Shame" public notices that OFAC published on the Treasury website, under Civil Fines and Penalties.

You can review the complete text of the Interim Rule here.

Therefore, prudence demands that, if your company provides ANY services to foreign nationals or entities, you had best have a working compliance program in place at this time. Programs that meet Banking Best Practices are the ones to emulate. They feature:
(1) A designated compliance officer.
(2) A written compliance program.
(3) Regular training of staff and officers on the program.
(4) An outside audit, performed regularly, to insure that the program is operating properly.

Treasury is to be commended for its ingenious method of insuring that all relevant industries create a compliance program, with one simple regulation.

GRENADA SUSTAINABLE AQUACULTURE DECEIVED INVESTORS ABOUT ITS TRUE LOCATION

If you look at the contracts between Grenada Sustainable Aquaculture Company Limited and the investors, whom we now must regard as victims, its specifies that GSA is a Grenada company, and itS principal address is that of attorney MARGARET V.L.A. WILKINSON, who is also the Local Agent and Escrow Agent. The Agreement also specifies that any Notice filed pursuant to its terms is to be delivered to said agent. This creates a presumption that the company is local to Grenada.

Now look at the address which appears on the Internet, on websites of GSA. It shows it to be in Dubai, in the United Arab Emirates. Specifically, 108 Sheikh Zayed Road, in the Shangri-La Hotel, Office 703. Would someone like to explain that inconsistency ? If I was a prospective investor in GSA, I would assume that its officers and staff would be in Grenada, on site or nearby, in order to efficiently and effectively create the aquaculture project. Any attorney or investigator examining the facts would question the ability of GSA to build and complete the project from afar. As it turned out, the project was not only not completed, it appears to have never been started, causing Government to cancel it in its entirety.

Victims of the scam have advised that they were ordered and directed to send payment to the UAE, and to Singapore, both jurisdictions far from the stated Grenada construction sites. If this investment capital is truly intended to be used to constructed state-of-the-art aquaculture facilities, why was it being sent to the Middle East or Far East ? These and other questions remain to be answered before a determination can be made regarding whether criminal fraud was committed, and whether the project manager, and other company officers, as well as local agents, can be charged with a crime.

Individuals who have an interest in a GSA investment, and who require further information, may contact this blog at :  miamicompliance@gmail.com

ZEUS MALICIOUS SOFTWARE HACKERS WANTED BY FBI

WHAT HAPPENED TO THE MISSING $18m FROM GRENADA'S CANCELLED GSA PROJECT ?

Investors who made USD $275,000 payments into the failed Grenada Sustainable Aquaculture (GSA) Project, which had a buy-back guarantee from project owner and developer Soren Dawody, report that they have still not received their funds back, notwithstanding repeated promises from the developer, who has allegedly defaulted on meeting reimbursement schedules. Only a portion of their original investment were to be returned, and even those smaller sums were not to be fully repaid for three years. Where are these project development funds ?

While no accurate figures have been made public, it is estimated that GSA developers took in over $18m. The project was never initiated, and was eventually cancelled by the Government of Grenada in 2018, even though the developer reached its investment targets. The investors were promised six per cent annual returns after three years. Mr. Dawody has gone on involvement in a number of other projects in Europe and the Middle East, including a similar aquaculture program in Antigua & Barbuda, but the estimated sixty-five victims have never been repaid.

It is noteworthy that the GSA payments to the developer were not made into accounts in Grenada, but into accounts in the United Arab Emirates (UAE) and Singapore. Whether there is criminal liability for fraud, misappropriation or illegal diversion of funds, and money laundering, under the laws of Grenada, has been the subject of debate among legal observers; Dawody has been absent from Grenada for several months. and creditors of GSA have not received payment, which are other indicia of fraud. He is reportedly a resident of Canada, but presently lives in Dubai, UAE. Was the missing $18m invested in other Dawody projects ?

READ THE CIVIL SUIT MOSSACK AND FONSECA FILED AGAINST NETFLIX OVER "THE LAUNDROMAT"

  
A Federal District Court has judge denied a request for Injunctive Relief, in a Connecticut case filed against NETFLIX, to prevent it from giving its members access to the motion picture "The Laundromat," which they allege defames them in the movie's depiction of their reputed money laundering activities. We note that both MF partners have been charged, in the Republic of Panama, with a number of offenses. The Court transferred the case to California, according to media reports.

Readers who wish to review the complete text of the 42-page Verified Complaint may access it here.

IRANIAN HACKERS WANTED IN $30m SAMSAM RANSOMWARE SCHEME

COUPLE ARRESTED FOR ฿1bn DRUG MONEY LAUNDERING IN THAILAND FACE DEATH PENALTY

A husband and wife financial crime team in Thailand are looking at the death penalty, after they were arrested in a seizure of ฿100m in a drug money laundering case, linked to the country's largest drug trafficking syndicates. Naruepol Phapphathee and Patthama Buathong, named as the leaders of the ring, had  ฿25m in cash seized, including ฿5.5m hidden in a washing machine.


 A Thai criminal court sentenced a major money launderer to death earlier this year, and a similar sentence is expected in this case. Over 500 bank accounts have been identified with this laundering syndicate.
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Note: 1 Thai Baht (฿) is is worth 3 1/3¢ (USD).

HEZBOLLAH TELLS ITS SUPPORTERS TO TARGET LEBANESE BANKS THAT FOLLOW US SANCTIONS AGAINST IT BY PROTESTING, ATTACKING AND STORMING THEM

Beirut's Bank Street

Arab media reports that Hezbollah has instructed its Shi'ite supporters to "attack and storm banks" in Beirut that adhere to US sanctions against it, its leadership and economic institutions. While the public statements call for public street protests. the fear is that such actions will lead to violence, disrupting bank operations, and thereby damaging the Lebanese economy.

Beirut banks are anxious to avoid the fate of Jammal Trust Bank (JTR Bank), which was forced into liquidation, after OFAC sanctioned it for providing financial support to Hezbollah, and a number of Hezbollah officials in Lebanese government were also targeted by US Treasury.

Other unspecified affirmative steps to confront the banks have apparently been approved by the terrorist organization, which wields serious political as well as military power within Lebanon, are reportedly being organized at the behest of Iran, which hopes to use the resulting chaos to force the United States back to the bargaining table; American sanctions upon Iran have had a major effect upon its economy, especially in international trade. Even though the US supports Lebanon, whether or not it will render concessions to Iran, to protect the Beirut financial structure, is doubtful.

Nevertheless, the threat of abrupt bank closures, due to damage as the result of organized violence by Hezbollah, remains a concern. Country Risk for Lebanon must now be substantially increased, as well as reducing any temporary financial exposure that is currently outstanding. 

IS THERE INSIDER TRADING AHEAD OF WHITE HOUSE PUBLIC ANNOUNCEMENTS ?

Insider Trading*, where an individual illegally profits by engaging in securities trades using non-public information he possesses, generally refers to intelligence about companies' future sale, merger, expansion, unveiling of new products, or other secrets, recent allegations surrounding what may be illegal use of upcoming announcements from the White House have emerged, with supporters, allies or associates of President Donald Trump as the guilty parties. Given the disrespect for the law by certain present or former government officials, Insider Trading on their part is not an unexpected event.

Controversial accusations that securities traders have earned $3.5bn, by trading in advance knowledge of public statements later issued by President Trump, have been appearing in major media, along with rumors that such conduct is under Investigation by the Securities & Exchange Commission, which enforces Insider Trading laws and regulations.

It is true that stock prices often rise or fall, based upon public policy statements made from the White House, especially regarding international trade issues with China, but they also can be affected by announcements regarding changes in American policies regarding foreign affairs, military deployments, and other critical international issues. The claim is that certain traders, who are the recipients, known in the securities industry as 'Tippees," are receiving this information, in advance of its public disclosure, and making obscene profits by executing stock trades based solely upon that intelligence. They would have received the advance information from someone in the White House, or from individuals who themselves received it from such a person.

Given that the maximum Federal prison sentence for Insider Trading is twenty years, or a five million dollar fine ($25m fir corporate entities), we hope and trust that transactions that appear to have been made after illegal and unauthorized receipt of inside information are thoroughly and properly investigated, and that criminal charges be brought where the evidence supports indictment.

It may also be necessary to inquire into whether the information, at one point, is classified, and that disclosure violates the Classified Information Procedures Act, which has a maximum 10 year sentence or a significant fine.
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*A good definition: the illegal practice of trading on the stock exchange to one's own advantage through having access to confidential information.



 

RUSSIAN HACKERS WHO STOLE FROM US BANK ACCOUNTS

LETTER TO CONGRESSIONAL COMMITTEE INVESTIGATING TRUMP FROM RUDY GIULIANI'S COUNSEL

The President's private lawyer has refused to cooperate with the permanent Select Committee on Intelligence of the US Congress conducting the Impeachment investigation. Below is his letter.

US CHARGES TURKEY'S HALKBANK WITH FACILITATING $20bn IRAN OIL-FOR-GOLD SANCTIONS EVASION SCHEME

The Turkish state-owned TURKIYE HALK BANKASI A.S., trading as HALKBANK, has been charged, in a 6-count Indictment, alleging  the bank's involvement in a $20bn Iran oil sanctions evasion scheme. The operation, known as Oil-for-Gold, involved the bank's illegal facilitation of the transfer of billions of dollars in illicit profits, benefiting Iran.

Halkbank Deputy GM Mehmet Atilla and the Iranian oil trader, Reza Zarrab, have both been convicted for their roles in the scheme to evade US and UN sanctions on Iran. The allegations also accuse other Halkbank senior staff of participating in the lucrative sanctions evasion scheme.

The Counts:
(1) Money Laundering.
(2) Conspiracy to Commit Money Laundering.
(3) Bank Fraud .
(4) Conspiracy to Commit Bank Fraud.
(5) Conspiracy to Defraud the United States.
(6) Conspiracy to violate the IEEPA.

Readers who wish to review the complete text of the 45-page Superseding Indictment may access it here.

FRONT COMPANY USED BY RUSSIAN-AMERICANS IN ILLEGAL CAMPAIGN CONTRIBUTION CASE

Readers who wanted to see the Florida corporate documents of FRAUD GUARANTEE LLC, the front company that allegedly was used by two Florida businessmen, now under arrest, to move illegal foreign campaign contributions into the hands of American politicians may view it below. The Incorporator, Florida attorney Donald Allison, was a former Assistant United States Attorney during the same period that Rudy Giuliani was an Assistant Attorney General, and the US Attorney in New York.

FINCEN, SEC AND CFTC JOINT STATEMENT ON DIGITAL ASSETS