MIAMI $20m FRAUDSTER VICTOR WOLF - BELIEVED TO BE LIVING IN MOSCOW WITH WIFE NATALIA

READ HALKBANK LETTER OF AUTHORIZATION FOR ITS NEW COUNSEL

This letter details the terms and conditions set down by the bank to authorize its new counsel, who will attending the arraignment, to act on its behalf. Note well that the bank is reserving "all of its relevant rights and defenses without waiving any of them."It also states that counsel is authorized to enter a not guilty plea.

BANKS IN BEIRUT STOP EXCHANGING LOCAL CURRENCY FOR US DOLLARS

Financial institutions in Beirut have temporarily ceased exchanging Lebanese currency for US Dollars for customers. The Lebanese Pound has seriously declined of late, and many Beirut residents now routinely exchange their local cash for Dollars. The banks say they will resume making US currency available on April 12, when the international airport, closed due to the Coronavirus, is scheduled to reopen.  

SENTENCING JUDGE DENIES TRUMP ATTORNEY MICHAEL COHEN A RULE 35 SENTENCE REDUCTION

The District Judge who presided over the case of Trump "Fixer" and attorney, Michael Cohen has denied the defendant's Rule 34(b) motion to reduce or modify his three-year sentence for a number of financial crimes to one year, or alternatively, to release him to Home Confinement.  Cohen's attorney alluded to the dangers posed to his client by the Corinavirus, while making arguments that did not persuade the Court.

The Court's reasoning:
(1) Only the Government is authorized to file a Rule 35(b) Motion to Reduce Sentence, which is evident to anyone who has practiced criminal law in Federal Court.
(2) The Government's own failure to file Rule 35(b) Motion speaks volumes.
(3) The defendant made false statements in pre-sentencing filings.
(4) Allegations of Governmental Bad Faith are not grounds under Rule 35.
(5) The defendant is "manifestly ineligible" for Compassionate Release, and he has not exhausted his administrative remedies.

HALKBANK CHANGES ATTORNEYS IN ADVANCE OF THE ARRAIGNMENT

The government-owned Turkish bank TURKIYE HALK BANKASI AS, trading as HALKBANK, has changed attorneys. King & Spalding LLP, the firm which sought, unsuccessfully, to shield its client from the Court's jurisdiction, has been replaced with Williams & Connolly, which will attend the upcoming arraignment.

L'AFA LANCE UN PROJET DE CARTOGRAPHIE MONDIALE DE AUTHORITES ANTICORRUPTION

Global Mapping of Anti-Corruption Authorities. This is a project of the French Anti-Corruption Agency Agence Francaise Anticorruption (AFA) A factsheet can be found here.

ABDULLAH AL-RIMI - WANTED FOR USS COLE BOMBING

WILL THE CORONAVIRUS KILL THE EAST CARIBBEAN CBI PASSPORT INDUSTRY, WHICH WILL DESTROY THE ECONOMIES OF THOSE ISLANDS ?

Given that the countries of the world will be dealing with the Coronavirus for many months, if not years, until a cure and vaccine are developed, tested, distributed and consumed, it is expected that international travel, for business or pleasure, will be limited absolute necessity, due to the dangers that it presents. Why expose yourself and your family to being infected, due to travel to areas which may contain higher risks of infection than you have at home ?

Unfortunately for the five East Caribbean states that have Citizenship by Investment (CBI/CIP) programs, they have become far too dependent upon the fees they collect from applicants; much of it goes to pay their top-heavy salaries of civil servants, many of whom are placed, due to local politics, in lucrative positions, though their duties, and contributions, are minimal.

 Without CBI funding, the East Caribbean states will be forced to conduct mass layoffs, and firings of government staff. This may plunge their fragile domestic economies into chaos, as unemployed government officials will not be able to afford to purchase goods from the service economies that serve them. Most of the consumer items are imported, and without paying customers, local retail will collapse. Food and energy shortages will soon follow, remittances from abroad, already declining, will not save them.

Will the CBI programs be the cause of the failures of the economies of the East Caribbean states ? We cannot say, but we will be watching.


  

INDICTMENT AGAINST NICOLAS MADURO AND OTHERS IN GOVERNMENT

Due to the level of interest, we are showing below the introductory pages from the Superseding Indictment against Venezuelan President Nicolas Maduro.

OSONDU VICTOR IGWILO - NIGERIAN ADVANCE FEE SCAMMER WANTED IN USA

WILL THE OFFICERS AND DIRECTORS OF MALTA'S PILATUS BANK NOW BE CHARGED ?

Pilatus Bank CEO Hamid Reza Ghambari

In the aftermath of the guilty verdict against Pilatus Bank owner and Director Ali Sadr Hasheminejad in the United States, we have been wondering why the Republic of Malta has neither investigated nor charged any of the principal Officers and Directors of the bank with criminal conduct, especially regarding money laundering and corruption. Since this has not occurred,  Malta's reputation as a jurisdiction within the European Union will further deteriorate. It is fast acquiring status as Europe's emerging "banana republic," where corruption and disrespect for the Rule of Law have become commonplace.

In the event that neither Malta nor the United States fails to bring the Pilatus players to justice, we name them here for the benefit of compliance officers at financial institutions in the European Union (EU), who will want to consider whether to label them as high-risk, due to their potential exposure to civil, as well as criminal liability for Pilatus Bank's actions, as the legal principle "directors must direct" is confers strict liability upon all directors.

(1)  Chief Executive Officer HAMID REZA GHANBARI, who has a CBI passport from the Commonwealth of Dominica. ( photo above)

(2) COO, Secretary and Director  LUIS FELIPE RIVERA, listed as an American citizen.

Luis Felipe Rivera

(3) Director MUSTAFA CETINEL, a citizen of the Republic of Turkey.

(4) Owner and Director SEYED ALI SADR HASHEMINEJAD, who holds a St Kitts & Nevis CBI Passport.

Seyed Ali Sadr Hasheminejad

(5) Director and ex-CEO ROBERT LEWIS KLNGENSMITH, listed as an American citizen.

Robert Klingensmith

(6) Director CLAUDE-ANNE SANT FOURNIER, a citizen of Malta.

Claude-Anne Sant Fournier

(7)  Former Director JOHANNES HELMUT BAUER, a citizen of Germany.

(8) Former Director ARMIN ECKERMANN, a citizen of Germany.

Armin Eckermann

(9) Former Director JOSEPH JERRY LIOW-YUNE-JOY, a citizen of the United Kingdom.

(10) Former Director PHILIP MERCIECA, a citizen of Malta.

Philip Mercieca

RAISE COUNTRY RISK ON GUINEA, AFTER GOVERNMENT PLOY TO EXTEND PRESIDENTIAL TENURE ENDS IN VIOLENCE

Reports from Conakry indicate at least ten protestors dead at the hands of government forces, after a referendum which effectively extends the President Alpha Conde's ability to remain in office for a third term spawned widespread protests. Government shut down access to the Internet, and declared a State of Emergency. Whether there will be intervention by French military forces is not known. Prior mass protests in the country resulted in 31 dead.

Under the circumstances, compliance officers who assess Country Risk should increase it for Guinea at this time. 

CORONAVIRUS EMERGENCY: A PERFECT STORM FOR MONEY LAUNDERERS

If you are a fan of heist movies, you probably have seen the 1970 film Kelly's Heroes, a story about a group of soldiers in the US Army in 1944 in France who go AWOL to rob a shutered bank behind the German lines that is storing millions of dollars in gold ingots. Based upon a true story, it illustrates the old maxim "The best time to rob a bank is in the middle of a war."

Maney launderers working for international narcotics cartels are most likely working overtime this month, as they are fully aware that compliance officers at international banks in North America and in the European Union have their hands full with the stay-at-home orders from Government, personal fear about catching the Coronavirus, or their families catching it, and performing their duties at the bank. There have been requests to defer, for ninety days, any and all compliance with the Bank Secrecy Act, and all other AML/CFT regulations and obligations.

In short, individuals who are working in the financial community, who are preoccupied with mortal danger, as well as the practical difficulties they now encounter in operating a compliance division at anywhere near an effective level, are under siege, and money launderers, who are always looking for vulnerabilities and systemic weaknesses, are most certainly driving a financial truck, loaded with the proceeds of crime, right through the bank's front, and back, doors.

Look for online transfers of funds, payments that ordinarily would be quickly spotted as inconsistent with a trade or business, payments for phantom deliveries of goods that are most likely trade-based money laundering, and similar transfers that an alert, and physically present, compliance officer might interdict, if he or she was on duty. Money launderers thrive amidst chaos; expect them to be hard at work in the current emergency situation, plying their dark trade, and in your bank.

WILL ALI SADR HASHEMINEJAD FLEE THE US PRIOR TO SENTENCING, OR IS HE COOPERATING ?

If you read carefully, you might have noticed that Ali Sadr Hasheminejad, the recently-convicted Iranian sanctions evader, and money launderer, remains free pending his sentencing, but in addition to Home Confinement (House Arrest), Sadr was ordered to have a GPS tracking device attached to his person, to follow his every movement, and to assure the Court that he will not flee the jurisdiction, to cheat justice, prior to his upcoming sentencing date.

Unfortunately, a number of high-profile defendants encumbered with GPS equipment have disconnected the device and fled the United States., and given  Sadr's reputed wealth, and probable sentence ( up to 85 years potentially), he might decide not to wait around to receive his sentence.

There is one strange issue, though; a number of sealed documents filed in the court file,  since the trial  ended, could mean that he has made the decision to cooperate with the authorities. Has he executed a Plea Agreement, which is now under seal ? We cannot say, but we will be watching for any indications that  a deal is in the works.

SENIOR LEADERS OF VENEZUELA ARE ALL WANTED MEN IN USA

JUDGE IN HALKBANK CASE ORDERS LAW FIRM TO PROVE IT REPRESENTS THE BANK BEFORE THE ARRAIGNMENT

It appears that the District Judge in the money laundering and sanction evasion case against the Turkish state-owned bank, Halkbank, intends to insure that there is no way that the bank can later contest the outcome by asserting that counsel was not authorized to represent it. The Court issued an
order requiring bank counsel to provide written evidence that the law firm is authorized to represent it at the Arraignment, A copy of the Order appears below. Obviously,  having seen the prior tactics employed by counsel, the Court is taking no chances.

NIGERIAN BANKER WANTED FOR THEFT

HALKBANK IS UNABLE TO STOP THE $20bn SANCTIONS EVASION CASE FROM MOVING FORWARD

Despite the best efforts of a major American law firm, the money laundering and sanctions evasion criminal case against Turkiye Halk Bankesi, more commonly known as Halkbank, the Turkish state-owned bank, has been set for arraignment on March 31, 2020, before US District Judge Richard Berman, who presided over the connected cases against Reza Zarrab and Mehmet Atilla. Some legal observers have accused the bank of acting in bad faith in its actions to date, while others blame it on a zealous defense by the attorneys defending the bank.

Counsel for the bank first attempted to file a Special Appearance on behalf of the bank, asserting a lack of jurisdiction, but the fact that the bank participated in a US Department of Agriculture program ended that effort; it was denied the ability to file a Special or Limited Appearance.

Next, the bank sought to stay the proceedings through a Petition Writ of Mandamus, which the Second Circuit Court of Appeal denied. The decision can be found below. It appears that the wheels of justice are turning in the case, notwithstanding the bank's dilatory efforts, moving it forward, notwithstanding the zeal of its attorneys.

IRANIAN HACKERS WANTED BY FEDERAL BUREAU OF INVESTIGATION

LISTEN TO ORAL ARGUMENT IN WAKED FORFEITURE APPEAL

While we await a ruling in the US Attorney's appeal from an order denying entry of a forfeiture judgment against the convicted Panamanian money launderer, Nidal Waked Hatum, here is the 35-minute tape of Oral Argument before the Eleventh Judicial Circuit Court of Appeals. You may download the recording here , as an MP3 file.

COURT CANCELS HEARING FOR BRUCE BAGLEY GUILTY PLEA

The trial judge in United States vs. Bruce Bagley cancelled the March 20, 2020 hearing in which the defendant was expected to enter a guilty plea to the pending money laundering charges. It is not known whether the schedule change was made due to court procedures surrounding the Coronavirus, or for some other reason. The District Court for the Southern District of New York has NOT issued a blanket suspension of court proceedings.

WARNING: YOUR NEW BANK CLIENT FROM TURKEY MAY JUST BE A CBI PASSPORT HOLDER FROM THE MIDDLE EAST

You have a new affluent bank client from Turkey; he speaks fluent English, which is fortunate, because none of the staff at your bank speaks Turkish. Do you know whether or not he is holding a Citizenship by Investment (CBI) passport, and is really from a high-risk jurisdiction elsewhere in the Middle East ?

Reports from Turkey state that there are 5111 foreign nationals who are new recipients of Turkish passports since the government eased the requirements two years ago, with 1382 applications known to be completed, and awaiting their passports, and an estimated 9000 applications in processing.

Given that a large percentage of applicants are from the Middle East, the prudent thing for compliance officers to do, if they have any client holding a Turkish passport that is less than two years old is to initiate Enhanced Due Diligence upon the customer. Where was he born ? is there more than one correct spelling of his name ? Was the name transliterated from Arabic ? He may be an OFAC-sanctioned individual, under a similar name, in his home country.

Treat Turkish passports as you would any passport presented to you from St Kitts, Antigua, Dominica or Grenada, if you wish to avoid that nasty letter from regulatory authorities two years hence. 

DMITRY DOKUCHAEV - RUSSIAN FSB OFFICER - FUNDED HACKERS TARGETING USA

FRANCE RELEASES IRANIAN SANCTIONS EVADER WANTED BY U.S TO TEHRAN, IN EXCHANGE FOR FRENCH ACADEMIC ACCUSED OF ESPIONAGE

Jabal Rohallahnejad

The Government of France has released Jabal Rohallahnejad, an Iranian engineer previously ordered extradited to the US to face a major sanctions evasion indictment, in a prisoner swap for a French academic held in Iran on espionage charges. This action could have a serious effect upon the relationship between France and the United States, given the importance which the United States attached to the Rohallahenjad extradition.

Rohallahnejad is an engineer whose specialty is fiber optics; he spent ten years studying and working in China, and there are several research papers available on the Internet written by him in the field. He was arrested by French authorities upon arrival in Nice a year ago; he alleged that he was to meet a local company regarding a groundwater project in the Persian Gulf. A request was filed by the United States, for his extradition, based upon a pending criminal indictment in Case No.: 19-cr-00073, in US District Court for the District of Columbia.

In truth and in fact, he is an employee of Aerospace Industries Organization of Iran, and he had been seeking parts for industrial microwave and anti-drone systems which, with modifications, could be used for making "ultra-precise weapons", meaning anti-missile systems and systems that could take control of drones. Iran seeks Western counter-drone technology for the purpose of intercepting US drones in the field.

Aerospace Industries Organization of Iran

Rohallahnejad sought to export sensitive high-powered American technology to Iran, for military use. at a cost of €900,000, between June 2016 and April 2018. His client was RAYAN ROSHD AFZAR COMPANY, an OFAC-sanctioned state-owned Iranian entity that manufactures components for the drone program of the Islamic Revolutionary Guard Corps (IRGC). He had arrived in France, via Moscow, on the authority of a work visa that he had obtained.

Rayan Roshd Afzar

The purported destination of the equipment was the United Arab Emirates. The UAE and Turkey are known to be transshipment hubs and staging grounds for Iranian front companies and smuggling networks seeking Western counter-drone technology.  It has been alleged that Rohallahnejad planned to use a Chinese alias as part of the deception.

The five-count indictment pending against the defendant carries with it a maximum sentence of sixty years in Federal Prison. La Cour de Cassation (Court of Cassation), the appellate court of last resort in France, ordered extradition on March 11, 2020; the 1996 Bilateral Treaty between France and the US requires that the Prime Minister must approve all extraditions.

In what many are referring to as a "prisoner exchange," France sent Rohallahenejad to Iran, and Iran simultaneously released a French academic who had been in custody on espionage charges, deemed political by France. Whether this case has damaged Franco-American relations remains to be seen.

READ THE NEW MONETARY AUTHORITY OF SINGAPORE AML/CFT GUIDELINES

MAS issued new AML/CFT guidelines on March 16, 2020. Readers who have an interest may review the complete text here. 

GU CHINHUI, PEOPLES' LIBERATION ARMY COMPUTER HACKER, STOLE NUCLEAR PLANT NFORMATION

SENTENCING DATE ANNOUNCED FOR ALI SADR HASHEMINEJAD

The District Judge in the Ali Sadr case has set his Sentencing Date for August 17, 2020 ay 1:00 PM. The fact that this date is five months from now may be due to the Court's recognition that there will be significant delays, due to the impact of the Coronavirus upon the Southern District schedule.The Court also gave the defendant a month to file post-trial motions, which may be due to a two-week moratorium on all but emergency matters, and First Appearances in new criminal cases.

Due to his conviction on multiple counts, we shall wait to see whether Malta's law enforcement and regulatory agencies, which have been strangely silent during the past two years, now take any action against Ali Sadr. The European Union, which has been extremely vocal about corruption and money laundering in Malta, may seize upon the conviction of Ali Sadr, who holds four CBI passports issued by St Kitts & Nevis, to further  pressure Malta to abandon its dodgy CBI program.

ROMANIAN HACKER WANTED BY FBI FOR MONEY LAUNDERING AND OTHER OFFENSES

TWO SENATORS VIOLATE THE STOCK ACT BY SELLING OFF THEIR STOCK USING INSIDER INFORMATION FROM CLASSIFIED BRIEFINGS

Senators Burr & Loeffler

Two US Senators have been found to have sold off much of their holdings in publicly-traded securities, in advance of public knowledge of the extent of the upcoming dangers to the economy presented by the Coronavirus. Insider Trading, the illegal use of insider non-public information to gain a financial advantage has a counterpart in the US congress; its is known as the STOCK Act, for "Stop Trading on Congressional Knowledge Act." Passed in 2012, it prohibits members of Congress to trade securities, based upon knowledge that they acquire by virtue of their positions. There have been calls for his resignation.

One of the Senators actually gave a special talk, alerting members of a private organization to the dangers, based upon his inside knowledge, gained in classified briefings of the Intelligence Committee.The two Senators who have ben accused of violating the STOCK Act curiously sat next to one another during the Impeachment trial.