HERE'S THE LIST OF NAMES FOR THE UPCOMING HASHEMINEJAD/PILATUS BANK TRIAL

Ali Sadr Hashemi Nejad

If you cannot attend the upcoming money laundering and sanctions evasions trial of Ali Sadr Hasheminejad, here is the complete list of identities of individuals and entities that the US attorney and defense counsel agree will be named. Note the names of the US banks involved. 

It goes without saying that the name of every individual on this letter should be run against your client list, and Enhanced Due Diligence immediately performed on any positives. While we do not know why many of these names appears therein, prudence demands that you assume some connection with sanctions evasion or money laundering, and govern yourself accordingly.

ORIGINAL POSTER OF SUSPECTED MEXICAN DRUG TRAFFICKERS WANTED BY MEXICO -2009

NORTH AMERICAN COMPLIANCE OFFICERS CONTINUE TO IGNORE FACIAL RECOGNITION TECHNOLOGY AND SOCIAL MEDIA RESOURCES FOR CUSTOMER IDENTIFICATION PROGRAMS

OBSOLETE ?

If I am the typical compliance officer at a bank located in the United States and Canada, I may be woefully behind the times, when it comes to banking best practices, for I am neither using facial recognition software, nor social media resources, when it comes to effective customer identification. Here's why this is important in 2020.

The march of modern technology, and economics, have made it much easier for transnational criminals to obtain, and employ, official identification documents under aliases that your CIP database searches cannot detect as bogus.

(1) Corrupt government officials, often drawing very small salaries, facilitate white-collar crime by creating passports under aliases, and then ensuring that any subsequent inquiries or searches will not uncover any red flags which lead compliance officers to question them.

(2) The plethora of Citizenship by Investment (CBI/CIP) programs has resulted in an explosion of valid passports, many of which are either under aliases, or transliterated spellings, and do not identify the holders by their true legal names. Moreover, many CBI jurisdictions supply birth certificates, drivers' licenses, even utility bills or deeds to real property, which give a complete, albeit totally false, sense of security to compliance officers requesting the,

(3) Technology has advanced to the point where forgers and makers of false identity documents, employing inside information or proprietary programs stolen from Government sources, can create a close to 100% foolproof, undetectable document.

Therefore, facial recognition platforms, the best of which have access to passport-picture quality image libraries, must be deployed to positively identify your subject. You will not find your subject's alias in any commercial off-the-shelf database of high-risk individuals. Only through facial recognition technology do you have a good chance of making correct identification, yet most compliance officers in the US and Canada are not there yet. Let us hope they are beginning to understand that money launderers and financial criminals can now gain easy entry to their banks, unless they abandon their current CIP methods, and move to facial recognition.

Additionally, as a supplemental tool, the use of specific software programs that search social media and socialnetworking sites are extremely useful, when compliance wants to rule out criminal associations, undisclosed PEP status, or other potentially negative facts about their targets. Social media programs often reveal something that the client wants to conceal, which may affect risk levels or suitability for onboarding altogether. It is a recommended component of your CIP toolbox, to rule out any nasty surprises after the client has been approved at account opening

Some experienced compliance officers have gone even further, believing that only through post-account opening transaction monitoring can a new client's risk profile be accurately measured, but for the majority, I would humbly suggest facial recognition tools be deployed at this time, with social media/social networking resource software also available to frontline compliance officers performing Customer Identification.

ADRIAN HONG CHANG, WANTED FOR INVASION OF DPRK EMBASSY

HENLEY AND PARTNERS' CHRISTIAN KALIN'S NAME IS LISTED FOR TRIAL IN HASHEMINENEJAD/PILATUS BANK MONEY LAUNDERING CASE

CHRISTIAN KALIN

In a recent court filing, in the money laundering and sanctions case against the Iranian businessman (and Pilatus Bank CEO) Ali Sadr Hasheminenejad, the United States Attorneys' Office notified the Court that one of the individuals who will be named at trial is CHRISTIAN KALIN, of Henley and Partners Group, the international CBI consultancy which obtained Sadr a St Kitts & Nevis passport and citizenship, around the time that Sadr's Pilatus Bank received its banking license in Malta, in January, 2014.

According to published reports, Sadr used his St Kitts CBI passport to acquire two shell companies, Stratus International Contracting, which is known to have been formed in Turkey, and Clarity Trade and Finance, incorporated in Switzerland. The United States has alleged that Sadr moved more than $115m through the American financial structure, from a dodgy Venezuelan housing project. Ultimately, the funds went to a British Virgin Islands corporation reportedly incorporated by Sadr, and thereafter to Iranian nationals and entities.

There are a number of known connections between Henley, Kalin and Sadr & Pilatus Bank, going back several years, but Henley has repeatedly denied that a close relationship exists or existed. Sadr's dark background, and that of his wealthy father, both of whom are closely linked to Iran's Ministry of Intelligence and Security, raising the question of whether Pilatus Bank was an Iranian government asset. therefore, St Kitts is guilty of an abject failure to conduct an effective due diligence investigation on Sadr, before granting him his SKN passport. Other family members of Sadr also obtained St Kitts passports, and many reside in the United States, which is disturbing.

This case simply confirms that the East Caribbean states, intoxicated by the huge fees they receive for CBI passports, and totally dependent upon those fees to prop up government budget burdened by top-heavy, and often unnecessary, official staff, taking down hefty salaries, ignore the red flags, and accept any wealthy applicants with US Dollars.

MOST WANTED JIHADI TERRORISTS PLAYING CARDS

HERE'S ONE BLACKLIST YOU CAN SAFELY IGNORE

DO NOT bother to even consider accessing the United Nations Human Rights Council "Blacklist" of over 100 companies doing business in the West Bank and Jerusalem, for bona fide compliance purposes. The list is part of the Palestinian-led Boycott, Divestment and Sanctions movement, an Anti-Semitic and anti- Zionist effort to target israel through what Palestinians regard as "illegal" settlements. The United States now regards these settlements as legitimate, and there is no legal reason for compliance officers to take any action against the companies named. 

HOW MANY NORTH KOREAN AGENTS HOLD DOMINICA AND GRENADA CBI PASSPORTS ?

Although the CBI consultancies, which sponsor dozens of online articles each week, extolling the "many virtues" of the Citizenship by Investment (CBI/CIP) passports they are vending on behalf of the five East Caribbean states that offer them, claim that individuals from internationally sanctioned countries are not eligible to apply, in truth and in fact they may qualify, and receive, CBI passports.

If you carefully review all the official materials, you know that both the Commonwealth of Dominica, and Grenada allow citizens of the Democratic Peoples' Republic of Korea (DPRK), more commonly known in the West as North Korea, to apply for, and purchase CBI passports and citizenship, provided: (1) They are no longer residents of the DPRK, (2) They have not business relationships with the DPRK, and (3) They have no assets in the DPRK.

Given that all North Korean nationals engaged in international travel must have approval from their government, which is an absolute dictatorship, we wonder just how any North Koreans could properly qualify under the above-mentioned terms and conditions for application. The very few who manage to escape that hellhole are without any funds to buy a second passport. Who are the real purchasers likely to be ?

The North Korean buyers of CBI passports are going to be agents of the DPRK government, whether they be oil sanctions evaders, purchasers of luxury goods for the privileged elite, individuals engaged in espionage, distributors of the "Supernote," North Korea's Counterfeit US$100 note, or some other government-sponsored mission or operation. Such individuals will easily be able to fake their overseas addresses, and lack of contact or assets in or with North Korea.

While the identities of such individuals are not known, one North Korean agent, with a valid Dominica CBI passport, is known to be shipping sanctioned goods into the DPRK from his base in Hong Kong. How many others are out there, performing similar tasks ? If they need logistical support in the field, the 900-man Chinese embassy in Dominica, which is a Chinese listening post upon the US, is available to assist them. Very few people in the Caribbean can accurately determine that an Asian visitor is a North Korean, rather than Chinese, national.

Until, and unless, the East Caribbean states terminate the ability of North Korean agents to
obtain CBI passports and citizenship, the DPRK is free to operate on a global scale, using their Caribbean identity documents, by concealing their true nationality. CBI passports are especially useful in the developing world, where their visa-free status facilitates sanctions evasion operations, as well as espionage. Dominica and Grenada must change their regulations to eliminate this loophole, so that citizens from outlaw states cannot avail themselves of the CBI programs.

SAUDI ARABIA'S 47 MOST WANTED TERRORISTS

WIDESPREAD USE OF ALIASES BY CBI PASSPORT HOLDERS FORCES COMPLIANCE INTO USING FACIAL RECOGNITION SOFTWARE FOR ACCURATE CUSTOMER IDENTIFICATION

If you were paying attention to my recent article about the German Bitcoin fraudster, Arthur Gehl, now referred to in media as "The Most Hated Man in Europe." you might have noticed that he disclosed that his Grenada Citizenship by Investment (CBI) passport is NOT under his legal name, but an alias. This little nasty detail which has been repeated thousands of times on CBI passports issued by those nations looking for a quick buck, and notably careless about who they sell passports to, is the reason that traditional Customer Identification Procedures where the target's name is the principal reference, are not obsolete, as well as not being considered Banking Best Practices by regulators.

Compliance officers can no longer rely upon CBI passport information as accurate, due to a number of factors:

(1) Corruption; illicit payments guarantee that an alias, and not the applicant's reel name, ends up in the treasured and coveted travel document.

(2) Transliteration of names into the English language, with Roman characters, Foreign languages, with different alphabets and equivalent letters, are rarely close enough to the original to be picked up in a search of databases.

(3) What if the applicant's personal information, from official sources in his home country, is already an alias ? Corruption at the front end of any application makes accurate identification impossible.

This means that compliance must access facial recognition technology to positively identify its targets; There is no effective alternative. Note that the program you use must have access to an extensive image library, and that the images simply must be of passport photograph quality. Using solely social media or internet photos will often result in false positives, or the inability to identify your target. Choose your facial recognition platform carefully for that reason. Do you know which are effective, and which are to be avoided ?

We have the CBI programs in the East Caribbean and the European Union to thank for this situation. The lure of easy money, which got the participating countries on board in the first place, also is responsible for the rampant corruption, which causes the program staff to accept knowingly accept  aliases, or invent them for applicants, or alter records. The days when one can go to sanctions lists, and commerical-off-the-shelf databases of  high-risk individuals and entities are long gone; use facial recognition software now to identify your customers.  

APOLOGISTS IGNORE CAYMAN ISLANDS' LACK OF LAW ENFORCEMENT ACTION AGAINST FINANCIAL CRIMINALS

The recent article, written by the Public Relations staff at Cayman Finance, in response to the classification issued by the Tax Justice Network Financial Secrecy Index, naming Cayman as the Most Secretive Jurisdiction in 2020, completely disregards the fact that Cayman law enforcement and regulatory agencies have a long and deplorable history of failing to bring financial criminals operating in the Caymans to justice. Specifically, the last eleven major financial frauds perpetrated there did not result in a single arrest or indictment of the fraudsters, or of any significant recovery of the lost investment capital by local law enforcement or the courts.

Regular readers of this blog will recall that we extensively covered the theft of hundreds of millions of dollars of funds, owned by elderly Canadian retirees and pensioners. The fraudsters, Cayman residents who used an offshore Canadian bank and an unlicensed investment company to accomplish their criminal goals, are well known in the media as the Cayman Gang of Four. None of them were ever arrested for those crimes by the Royal Cayman Islands Police Service, nor sanctioned by the Cayman Islands Monetary Authority. Additionally, CIMA improperly disclosed information submitted by victims to one of the fraudsters, who was personal friend of one of the regulators.

It appears that the fear of negative publicity, which could drive away new foreign investors, trumps the Rule of Law in the Cayman Islands. Criminal investigations, while often initiated there, do not result in criminal charges against fraudsters, especially if they are Cayman professionals or residents. Foreign investors should avoid the Cayman Islands for, should they become a victim of financial crime, there will be no assistance rendered to them by the authorities.

   

SWISS REGULATOR HITS AML AND RISK MANAGEMENT FAILINGS AT JULIUS BAER

FINMA, the Swiss Financial Market Supervisory Authority, has cited JULIUS BAER for major AML shortcomings. Readers interested in PDVSA and FIFA money laundering and corruption issues will want to read the Press Release. You can access it here.

ALIREZA MONFARED, DOMINICA'S MOST INFAMOUS DIPLOMAT, OWES IRAN $1.3bn FOR EMBEZZLED FUNDS

Alireza Monfared and Dominica PM Roosevelt Skerrit

According to the latest information out of Iran, Alireza Monfared, the Iranian oil sanctions evader who bought a million dollar diplomatic passport from the Prime Minister of Dominica, Roosevelt Skerrit, and drew a 20-year prison sentence for embezzling illegal oil sales proceeds, still has not paid the $1.3bn Restitution that the court in Iran ordered paid forthwith.

In addition to massive theft of Iranian government profits, Monfared defrauded Malaysian businesses, defaulted on payment of his debts there, and used his Dominica diplomatic passport to evade a Malaysian arrest warrant, notwithstanding that he was no more a legitimate diplomat than you or I.

If Monfared, one of many career criminals who covertly purchased a diplomatic passport from Dominica's senior leader, fail to come up with the money he stole, he may find himself in the same situation as his partner,  Babak Zanjani, who faces a previously imposed death sentence, unless he himself pays back €2bn in oil profits. Billions of dollars generated by an organization led by Reza Zarrab, Zanjani and Monfared were diverted by the trio, and others, and are missing, believed to be hidden in the world's tax havens.

So long as the Commonwealth of Dominica sells its patrimony by accepting cash from career criminals for diplomatic passports, the reputation of those countries will continue to suffer; North American and EU banks will expand their de-risking policies, due to the existence of the proceeds of corruption, bribes and kickbacks, Country Risk for Dominica will remain elevated, with no relief in sight. It is on the way to becoming, like Haiti, a failed state, so long as corruption is the order of the day.   

WILL LEBANON'S FINANCIAL CRISIS EMPOWER HEZBOLLAH ?

The value of the Lebanese Pound* or Lira, which has been pegged to 1500 to $1USD, has been in free fall of late, due to the country's financial crisis. Black market currency traders are selling Dollars for as many as 2550, and the sale of greenbacks by Beirut banks have been severely restricted.

Given that Hezbollah has ready access to US currency, both from its Iranian sponsors** as well as criminal proceeds from its broad-based campaign of criminal activity, which includes, but is not limited to, Western Hemisphere drug trafficking, it is in a position to exact a cost from any Lebanese faction that is des[erate for Greenbacks. Let us hope it does not choose to take advantage of Lebanon's financial nightmare to increase its hold over the country.

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* Patterned after the original pre-1914 Ottoman Turkish Lisa, it was designated the Pound during time of the Second World War when, after the fall of its sponsor, France, the currency was pegged to British Pound Sterling. Symbols for Lebanese Pound are LL and LBP.

** Long-time readers of this blog will recall that we detailed how Hezbollah obtained US Dollars after the last Israeli-Hezbollah conflict; through deliveries, via private business jets, from Venezuela's Chavez regime. The cash was flown from Venezuela to a destination in the north of Syria, and they trucked into the Hezbollah stronghold in the south of Beirut.

CBI ELIGIBILITY FOR IRANIAN NATIONALS IN DOMINICA AND GRENADA REMAINS A CLEAR AND PRESENT DANGER REGARDING SANCTIONS EXPOSURE BY GLOBAL BANKS

While the five East Caribbean states that offer Citizenship by Investment (CBI/CIP) passports openly trumpet the statement that their programs are not available to Iranian nationals, a little-known loophole does indeed exist that allows Iranians to apply for, and to receive, those prized CBI pasports in Dominica and Grenada. Unfortunately, this "exception" is broad enough to drive a truck through, should you be an Iranian intelligence agent assigned to engage in espionage overseas, or merely a career white-collar criminal running a government-approved sanctions evasion program, acquiring parts for Iran's illegal WMD and ballistic missile programs, or selling Iranian oil, in violation of US and international sanctions.

How can this be true, you ask ? Well, provided that Iranian nationals meet these requirements, Dominica and Grenada will take their CBI appications:

(1) The applicant must have resided outside the Islamic Republic of Iran, for an extended period, typically ten years.

(2) Have no "substantial assets" in Iran.

(3) Are not performing, nor have not performed, any business activities with Iran.

Taking them one at a time, any respectable intelligence agent, money launderer, or white-collar criminal worth his salt, can easily provide "evidence" on long-term residence outside Iran, simply deny that he has any assets within Iran (though the term 'substantial' appears open to abuse), or any business with Iran, then or now.

Given that the Financial Action Task Force (FATF) has recently named Iran to its Blacklist, a category previously only occupied by North Korea, the potential punishment that could, and will be, visited upon a bank in North America or within the European Union, or the UK, for allowing a "Caribbean national" with a CBI passport to provide financial assistance to illicit Iranian operations, is now increased. it may be that ANY Dominica or Grenada passport holder, not born there, nor an obvious West Indian due to race, accent & slang, must be denied access to any banking services.

Western banks that do not want to be made an example of by US law enforcement or regulatory agencies must now, regretfully, take sufficiently strong steps to ensure that no Iranian agents, armed with CBI passports, penetrate their Customer Identification defenses. To do any less will invite fines, civil penalties, and that all-important Reputation Damage, which drives customers to your competition. Take your Gatekeeper responsibilities seriously,

ARE YOU BANKING ANY OF THESE WANTED IRANIAN HACKERS ?

CONTROVERSIAL COMMONWEALTH SECRETARY-GENERAL PATRICIA SCOTLAND MAY NOT SERVE ANOTHER TERM

Scotland

UK attorney, Baroness Patricia Scotland of Asthal,  the beleaguered Secretary-General of the Commonwealth of Nations,whose term of office is now at an end, may lose her office, due to rampant allegations of conflict of interest, out-of-control spending, and other misconduct.  Several Commonwealth members have withheld funding to express their dissatisfaction with her professional conduct, and a candidate from Kenya has been mentioned as a qualified replacement.

Her dark role in the acquisition, in London of a Dominica diplomatic passport, by Nigeria's former Minister of Transportation, Diezani, Alison-Madueke, when Madueke was implicated in a multi-million theft from government funds, remains an unresolved issue currently under investigation. She allegedly instructed Dominica PM Roosevelt Skerrit to hand-deliver it to London; thereafter Madueke improperly attempted to assert diplomatic immunity when UK law enforcement officers sought to arrest her for corruption in Nigeria. It is not known who, if any, received direct or indirect illegal compensation for the sale of passport.

Alison-Madueke

Scotland, who was improperly nominated for the job from the Commonwealth of Dominica, although she left her native country at the age of two for the UK, defeated frontrunner, the diplomat Sir Ronald Sanders of Antigua, who was thought to be more qualified. After taking office, Scotland, her excessive spending habits, using official Commonwealth funds, especially for her residence, have been the subject of major UK media attention.

Additionally, the Secretary' General award of a lucrative £250,000 contract to a fellow Labour Party member alleged to be insolvent, without competitive bids, has drawn attention to Scotland's reputed mismanagement of her office.

PM Roosevelt Skerrit

Scotland's role, together with Skerrit, in the Madueke diplomatic passport scandal, focused global attention upon a covert program in Dominica, which issues diplomatic passports to foreign white-collar and career criminals, in violation of the Vienna Convention, adopted by the UN, without any oversight or control. 

ALI SADR HASHEMI NEJAD TRIAL SET FOR MARCH 2, 2020 AFTER MOTIONS RESOLVED

The Federal criminal case against the Iranian national who owned and operated Malta's dodgy Pilatus Bank, Ai Sadr Hashemi Nejad, has now been set by the Court to begin on March 2, 2020, A large number of defense Motions in Limine, seeking to stop the introduction of information that the defense asserted was prejudicial to their client, were recently denied. These motions required resolution prior to trial.

The Government is therefore free to introduce evidence and testimony that would appear to be seriously damaging to the defendant. The Court's rulings,entered on February 14, 2020, that were favorable to the Government:

(1) Statements of co-conspirators will be admissible.
(2) Most emails and attachments may come into evidence.
(3) Communications establishing Sadr's knowledge of US and international sanctions will be admitted.
(4) Evidence of purchase of a St Kitts citizenship will be admissible.
(5) Description of the housing project in Venezuela as "low-income."
(6) Evidence of  the revocation of an OFAC "U-Turn license."

"Shell" and "front company" may not be used in Opening Argument, nor references to the the Joint Comprehensive Plan of Action (JCPOA) regarding Iran. Sadr may offer evidence about the lack of risk of harm to the banks.

The Court has not yet ruled on whether it will admit testimony on whether the purchase of a St Kitts CBI citizenship "may be used to evade sanctions. " Heshemi Nejad, and others, allegedly used their SKN passports to conceal their nationality and citizenship abroad, and to acquire shell companies.

FRENCH "FAKE DEFENSE MINISTER" IMPERSONATION EMPLOYED TRADE-BASED MONEY LAUNDERING TO CLEAN PROCEEDS OF CRIMES

Gilbert Chikli, the career fraudster/leader of a French gang that defrauded wealthy individuals of a reported €73m, by impersonating the Minister of Defense, and asking for ransom money to free purported kidnap victims in Syria, used trade-based money laundering techniques to clean the criminal proceeds.

Chikli, who donned a mask, and sat in a room decorated to appear to be the Ministry of Defense office,  and claiming to be Minister Le Drian, contacted victims via Skype, asking for ransom money that, he declared, France could not be seen paying directly, appealing to the patriotism of the wealthy victims. Many of them bought into the story; more than €50 has not been recovered.

The case, which is currently on trial in Paris, with seven defendants, is of great public interest. we have reported upon the story in two prior articles. Compliance officers please note that Chikli, in an unguarded moment with a journalist, revealed how he launders the proceeds of his crimes: trade-based money laundering.

His technique:

(1) Send the proceeds of his fraud to China and/or Hong Kong.
(2) Purchase 20 tons of steel.
(3) Bribe the vendor to give him a receipt for 100 tons.
(4) Send funds corresponding to what profits on 100 tons of sales would be to Israel, together with the bogus receipt.
(5) The money is thereby laundered.

Chikli is not the only white collar criminal using China for trade-based money laundering; compliance officers would be well advised to closely examine any bank client who abruptly engages in large-scale international trade of goods with companies in China, as the transactions may be a front for trade-based money laundering.

Other fraudsters employ a variant known as Chinese Flying Money. The illustration below can be used to explain how it is employed. Compliance officers who encounter either of these techniques are urged to seek out competent financial crime advisers to assist them in deciphering the puzzle.

DANIEL ANDREAS SAN DIEGO - FBI MOST WANTED - DOMESTIC TERRORIST/BOMBER

GERMAN €100m CRYPTO CURRENCY FRAUDSTER HAS GRENADA CBI PASSPORT, PLANS TO EVADE JUSTICE THERE

Arthur Gehl

This is ARTHUR GEHL, Germany's €100m crypto currency fraudster, who promised his victims 250% return on their money. Gehl and his wife ROXANA are reportedly planning on leaving the European Union, and securing refuge from the law in Grenada, where the couple reportedly have obtained Grenada passports, secured through the Citizenship by Investment (CBI/CIP) program.

The CBI passports are said to be in the names of aliases, not the Gehl's true names. Given the legal obstacles which European (and American) law enforcement agencies have experienced, when seeking to extradite criminals who are East Caribbean CBI passport holders, the Grenada extradition process will be lengthy, and frustrating, as local attorneys, closely linked to Government, generally handle these types of cases, and delays that take years are not uncommon dilatory tactics.

Roxana Gehl

Will Gehl cheat justice by fleeing to Grenada, and hiding behind lengthy procedural delays ? We cannot say, but perhaps it would be best for his victims if he was arrested in Europe, rather than give him the opportunity to hide behind his Grenada passport. Otherwise, it may be years, if ever, before he sees the inside of German, or American, courtroom.

GUILTY PLEA IN NEW YORK FROM GERMAN NATIONAL EXPOSED IN PANAMA PAPERS SCANDAL

Panama Attorney Ramses Owens

HARALD JOACHIM VON DER GOLTZ, a wealthy German national that formerly resided in the United States, has entered a guilty plea to multiple counts, including money laundering, in US District court in New York, in a case that was exposed by the disclosures published in Panama Papers. Von Der Goltz formed opaque offshore shell companies, in Panama and the British Virgin Islands (BVI), using the services of Panama attorney RAMSES OWENS, then a partner at Mossack Fonseca & Co., which rendered advice to its dodgy clients, facilitating money laundering, tax evasion, placing the proceeds of corruption, and a number of other criminal acts. the Mossack firm was brought down by the Panama Papers disclosures, and the name partners charged with criminal conduct.

Von Der Goltz, who reportedly also held dual citizenship in Guatemala, was formerly a resident of Key Biscayne, Florida. he pled guilty to:
(1) Conspiracy to Commit Tax Evasion.
(2) Wire Fraud.
(3) Money Laundering Conspiracy.
(4) Willful Failure to File required reports.
(5) Making False Statements.

Readers who wish further details on this case may access the Superseding Indictment against Von Der Goltz, and others here. The case Number is 18-Cr-693 (SDNY).

SUIT BY HEIRS OF AMERICAN KILLED BY HAMAS DETAILS CLOSE RELATIONSHIP BETWEEN TURKEY'S BANKS AND TERRORISTS

Although not covered by major media in the United States, there is a civil suit pending, in US District Court for the Eastern District of NewYork,* that accurately describes the incestuous relationship between Turkey's banks and the global terrorist organization, Hamas. Although Turkey has done to great length in the press to make it appear that it has banned Hamas from operating within its territory, this action spells out, chapter and verse, all the ways that Turkey's KUVEYT TURK BANK facilitates Hamas' global terrorist operations.

The action was brought by the minor children of US citizen Ettam Henken, who were orphaned when Hamas gunmen killed him and his wife on a highway in the Palestinian Territory. He was unarmed, and the murders were particularly heinous, as they occurred in full view of the children.

The suit lays out the literally hundreds of ways Kuveyt bank, which services Hamas' key organizations, major donors and its leadership, facilitates the entity's terrorist agenda abroad. The Court has jurisdiction, due to the correspondent accounts that the bank maintains at (quoting the Complaint at 2):

(1) Citibank NA.
(2) HSBC Bank NA.
(3) Standard Chartered Bank.
(4) Bank of New York Mellon.

Suit was filed last September, and it appears that none of the above-mentioned banks has closed their correspondent accounts with Kuveyt. Compliance officers at those banks would do well to review their client's account history forthwith. Compliance officers who access Country Risk may want to
update their calculation of Country Risk for Turkey, based upon the Complaint.

The Complaint, which contains a detailed history of the Hamas organization, including the US history of the Holy Land Foundation, a Hamas front, its extensive European fundraising efforts, with special attention to Turkey, and specifics regarding how Kuveyt Bank aids Hamas. Readers who wish to review the complete text of the Complaint may access it here.
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*Estate of Eitam Henken et al vs. Kiveyt Turk Katilim Bankasi A.S., Case No.: 19-cv-5394 (EDNY).

UNLICENSED, UNDERGROUND MSB IN SAN DIEGO THAT SERVICED CHINESE NATIONALS PLEAD GUILTY

The two Las Vegas operators of a US-based unlicensed money service business, which existed completely underground, have agreed to enter plead of guilty in US District Court in San Diego. What makes the case unique is the fact that it serviced Chinese nationals who sought to circumvent China's strict currency restrictions,  which limit exchange to $50,000 annually The customers received US Dollars here, and paid for them with Yuan (Chinese currency) back in the Peoples' Republic, using banking applications on their cellular telephones from casinos the USA. The US Attorney's Office noted that it was the first case filed against an unlawful underground financial institution serving Chinese nationals evading Chinese. currency controls

While the typical clients were Chinese gamblers playing in the United States, Chinese intelligence agents, and others engaged in espionage for China, could have very easily financed intelligence-gathering activities through the underground MSB. The US Attorney also voiced a concern that their illegal MSB could potentially aid narcotics traffickers.

The defendants, BING HAN and LEI ZHANG, who pled to Operating an Unlicensed Money Transmitting Business, face as maximum of five years in Federal Prison, and a $250,000 fine. the case numbers are 20-CR-369 and 370 (SDCA).

  

HEDGE FUND MANAGER SENTENCED TO 140 MONTHS FOR $11m FRAUD

A career criminal running a fraudulent hedge fund in New York that stole $11.2 from investors was sentenced recently to one hundred and forty months in Federal Prison. Nicolas Joseph Genovese, who ran Willow Creek Investments LP, claimed to be from a wealthy family, had a Dartmouth MBA, alleged substantial experience as a portfolio manager at Goldman Sachs and Bear Stearns, and purportedly managed $4bn in family assets.

In truth and in fact, Genovese had none of these qualifications, and he had several prior felony convictions for fraud-related offenses. He lost $8m of the victims' money trading on the stock market, and spent the rest while maintaining a high-end life style, including withdrawing $263,000 from various ATMs, and a Bentley with a chauffeur. He spun a fantastic story to investors who sought their money back, about the need for "the stars to be aligned" before he could make refunds.

In addition to the 140 months, the defendant was sentenced to three years of Supervised Release and $11.2 Restitution. If you want to learn more about this case, read the SEC civil lawsuit against him here. The style of the case is Securities & Exchange Commission vs.Nicolas Genovese, Willow Creek Investments LP and Willow Creek Advisers LLC., Case No: 18CV942 (SDNY).

DEPUTY ATTORNEY GENERAL ASSIGNS ALL UKRAINE CASES TO EDNY

The Deputy Attorney General of the United States has directed that, effective immediately, all Ukraine-related investigations are assigned to the Eastern District of New York, which has total command and control over all investigations, and indictments. The Memorandum, which is captioned "Law Enforcement Sensitive, " but which is an unclassified document, appears to remove prosecutorial authority from a DOJ attorneys and law enforcement heads. It is dated January 17, but apparently it was leaked to the media today.

FLORIDA BUSINESSMAN RECEIVES 40 MONTHS FOR ATTEMPTING TO EXPORT A GAS TURBINE TO IRAN

James Meharg 

A US District Judge in the Northern District of Florida has sentenced a Pensacola executive to forty months in Federal Prison for attempting to export a large Solar Mars gas turbine, and parts and components, to Iran. James Meharg* was convicted of violations of the Iranian Transactions and Sanctions Regulations, and Federal Criminal law,  when he conspired to export and deliver a turbine core engine to Iran.

The defendant's plan was to route the turbine through Sharjah, UAE using falsified documents. The eqipment was later to be diverted to Iran. he received $250,000, in funds laundered through a front company in Dubai. The true end-user was an Iranian energy company, the Iran Oilfield Supply Kish Company.

Readers who require more detail may access the Factual Basis for Guilty Plea here. Meharg pled to Conspiracy, making False Statements, and Money Laundering. he could have received a maximum of 50 years for those offenses.

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*United States vs. Meharg, Case No.: 19cr71/MCR (NDFL).

LEROY KING, ANTIGUA'S FORMER FINANCIAL REGULATOR, PLEADS GUILTY IN STANFORD INTERNATIONAL BANK PONZI SCHEME

Leroy King, the former CEO of the Financial Services Regulatory Commission (FSRC) of Antigua, has entered a plea of guilty in US District Court, ending the final chapter in the Stanford International Bank Limited Ponzi scheme scandal. He is the last defendant to be sentenced in the case. King fought extradition from his native Antigua for more than a decade, a case that seriously weakened Antigua's reputation and standing in the global community as a Rule of Law state. The US Attorney in Texas acknowledged the assistance of the Government of Antigua in the case.

The defendant pled guilty to relatively minor charges; he was facing a potential life sentence, given his age, due to the severity of the counts in the indictment. He entered a guilty plea to:

(1) Conspiracy to Obstruct Justice.
(2) Obstruction of Justice.

According to reports, King is a dual citizen of Antigua & Barbuda, and the United States. He reportedly received bribes from Allen Stanford in excess of a half million dollars, plus other perks and benefits. He actively obstructed an ongoing investigation of the bank that was conducted by the Securities & Exchange Commission.

King will be sentenced on April 24, 2020. The maximum sentence for the two counts is ten years plus a substantial fine. It is not known whether the size of the $7bn Ponzi scheme perpetrated by Stanford will be an aggravating factor in his sentence. While Stanford is serving a 110-year sentence, the other defendants only received sentences ranging from three to twenty years.

MEET THE DISGRACED KONRAD MIZZI, PANAMA PAPERS POSTER BOY FOR CORRUPTION IN MALTA

This is Malta's former Minister of Energy/Minister of Tourism, Konrad Mizzi, involved up to his neck in a corrupt scheme, together with the similarly disgraced Ex-Prime Minister and his former Chief of Staff, Keith Schembri, who all benefitted from kickbacks paid in connection with the new Electrogas Powerstation project, though Mizzi was reportedly enriched the most, due to his Energy portfolio.

Ex-PM Joseph Muscat

Illicit payments made to Mizzi's Panama offshore company, and revealed in the Panama Papers, of €5000 per day. A number of pending criminal investigations against him have been reported, but no charges filed to date. Why has the Malta Police Force Economic Crimes Unit failed to act ? Official corruption has been alleged, but the ECU is NOT being investigated for its negligence. All three of the scoundrels belong in prison.

PEOPLES' LIBERATION ARMY (PLA) HACKERS WANTED IN USA FOR ECONOMIC ESPIONAGE

CARIBBEAN BANKS FEAR DE-RISKING, BUT FAIL TO TAKE THE NECESSARY REMEDIAL STEPS TO END IT

What the banking industry refers to as de-risking, the process by which onshore banks in North America and the European Union terminate their correspondent relationships with overseas banks deemed to be high-risk, and which result in relatively small income to them, is regarded as a serious problem in the Caribbean. Many North American banks have summarily closed out their Caribbean correspondent accounts, and more are believed to be under consideration.

Why are Caribbean banks targeted ? We can offer some of the reasons cited by compliance officers at major North American financial institutions:

(1) AML/CFT compliance programs that do not meet minimal onshore banking best practices standards.
(2) Compliance staff whose training, education and experience are deemed to be inferior to that of onshore banks.
(3) Leftover, and still worrisome, connections to the laundering of the proceeds of narcotics sales.
(4) Rampant corruption by senior government officials at all five of the East Caribbean states ( St Kitts & Nevis, Antigua & Barbuda Dominica, St Lucia & Grenada).
(5) The flow of suspicious Citizenship by Investment (CBI/CIP) application money through Caribbean banks.
(6) The failure of Caribbean banks to acquire, and periodically update, the latest hardware and software technology necessary for effective AML/CFT.
(7) Continued, and probably excessive, local bank secrecy laws and regulations, which interfere with onshore law enforcement investigations, as well as bank inquiries from abroad.

Until, and unless, Caribbean banks adopt some serious reforms to alleviate the above issues, onshore banks will continue to practice de-risking, until most or all of the correspondent relationships are terminated, which will force Caribbean banks to use third party banks abroad, or non-bank financial institutions, doubling or tripling the costs to their customers of onshore transactions, and incurring substantial delays in the process. Unless these issues are resolved, a number of Caribbean banks may soon find themselves without any direct correspondent relationships at all.

MOHAMED IBRAHIM, EGYPTIAN AL-QAEDA AGENT LIVING IN BRAZIL WANTED BY US

READ THE NEW MONEYVAL REPORT ON GIBRALTAR

The Fifth Round Mutual Evaluation Report on the British Overseas Territory of Gibraltar was just released. readers who wish to review the complete text of the 251-page document may access it here.

DOMINICA'S PRIME MINISTER THREATENED INTERNATIONAL MEDIA FOR EXPOSING THE COUNTRY'S DIPLOMATIC PASSPORT SALES SCANDAL

When one of the world's largest and best-known investigative media outlets recently exposed the sordid truth about the massive illegal sales of diplomatic passports by Dominica's senior officials, the country's prime minister threatened a suit for libel. Given that Dominica's court system is notoriously corrupt, and ignores the Rule of Law, it is required to follow and is especially sensitive to the demands of senior government officials. Any libel suit brought in Dominica against foreign media would most likely result in a swift judgment, irrespective of the facts or the law.

 Roosevelt Skerrit, the PM of the Commonwealth of Dominica, openly and publicly threatened Aljazeera, after the news network's investigative reporters filed stories detailing how white-collar criminals have easily purchased prized diplomatic passports in Dominica, and gone on to commit major criminal acts, using the passports to shield them from arrest, as well as customs inspection of their illicit possessions, when they appear at international ports of entry. The sale of those passports to dodgy foreign nationals, who thereafter do not perform any diplomatic functions or duties, is a violation of the United Nation's Vienna Convention on Diplomacy. They are to be considered void as a matter of law, which a number of law enforcement agencies have done, when arresting the holders.

Skerrit, who is suspected of actually profiting from cash sales, for millions of dollars each, of diplomatic passports, alleged that Aljazeera was working on behalf of his country's opposition party, and its leader, though he offered no evidence in support of that claim, which has no basis in fact. Skerrit further alleged that the stories were part of an attempt to "destabilize" Dominica. The network's presentation actually showed how the dark world of Dominica's diplomatic passport sales operates, by having a journalist pose as an interested purchaser. Attacking the messenger, which is a favorite tactic of corrupt politicians exposed by media in the Caribbean, rather than responding on the merits of the issues, operates as additional confirmation of the truth presented.

So long as Dominica engages in the illegal sales of its diplomatic passports, transnational crime will continue to be facilitated by those individuals, and criminal organizations, who covertly purchase them from senior officials.

 

CYPRUS TO REVOKE BILLION DOLLAR MALAYSIAN FRAUDSTER JHO LOW'S CBI PASSPORT

Jho Low Cyprus passport

The Republic of Cyprus has announced that, among the twenty-six CBI passport holders it intends to revoke is that of the Malaysian fraudster, Jho Low, currently a fugitive from justice in his native Malaysia, having allegedly stolen $4.5bn from the 1MDB Malaysia Development Berhad, a sovereign wealth fund. Jho, who led a flashy global lifestyle with Hollywood celebrities, is believed to be in hiding in China; he faces a probable life sentence in Malaysia, where he is considered the number one fugitive.

We have previously covered this case in depth, due to the fact that Jho Low holds a St Kitts & Nevis CBI passport, and there are concerns that he will eventually attempt to relocate there permanently, as most legal authorities have stated that Kittitian citizens are rarely extradited to face criminal charges abroad. His SKN passport was reportedly revoked by the authorities, but whether proper procedures were followed by government have not been established. The passport may still be valid.

VICENTE VALLS, FUGITIVE MONEY LAUNDERER WANTED IN SOUTHERN DISTRICT OF FLORIDA