Kenneth Rijock

Kenneth Rijock

Tuesday, June 30, 2020

US SUPREME COURT DENIES CERTIORARI TO NG LAP SENG IN UN BRIBERY CASE




The US Supreme Court petition of Dominica's most notorious diplomat, the convicted Chinese billionaire Ng Lap Seng, has been denied, closing the final chapter in Seng's efforts to avoid serving the rest of his Federal Prison sentence for bribing United Nations officials, so that they would approve his plans to build a conference center in Macau, for annual UN events.

Seng's District Court conviction and sentence was affirmed on appeal to the Second Circuit, and his Certiorari petition was his last chance to obtain a reversal or new trial. Any subsequent actions that he may file in the future are in the nature of prisoner's petitions, and  acceptance of the case is totally discretionary with the court where he chooses to file them, In essence, his bribery conviction is final, with little or no chance of a favorable outcome in any future legal effort.

Seng's case raised compliance officer awareness of an underground, sordid diplomatic passport pay-to-play industry in the East Caribbean States, whereby white collar criminals can purchase, for what is generally a huge sum, a Dominica diplomatic passport. Seng, who has become the Poster Boy for Caribbean corruption, due to this case, must now serve the balance of his sentence, after which he will be deported to China. The reputation damage to Dominica will, however, be permanent.

TO AVOID ENDING UP ON THE MONEYVAL "GREY LIST," MALTA MUST ABOLISH ITS SHELL COMPANIES



With all the rumors percolating throughout Malta, concerning whether MONEYVAL will soon place the Republic on its money laundering "Grey List," perhaps the country's leaders should consider a reform that might get favorable regulatory attention: abolishing Malta's tax haven shell company laws.

The shell (offshore) companies formed in Malta have attracted the wrong kind of crowd, such as the cryptocurrency and online gambling industries, which bring with them their share of money laundering and corruption exposure. Legitimate EU businessmen flock to Valletta due to the irresistible lure of only a five (5% ) effective income tax rate, after rebates, and remember that sharp operators can desgnate the cash flow as royalties, interest and dividends, and pair it up with a non-resident founder, resulting in a 0% rate.



Resident nominee directors of shell companies, who are supposed to possess spotless backgrounds, often have dark or unacceptable work histories, including termination of directorships for cause, as well as participation in prior company misconduct, can usually be found still on the job, with such character flaws, as the regulators rarely if ever  are known to complain, let alone intervene, on the grounds of reputation shortcomings. Fit and Proper Person qualification passed ? Doubtful.

The requirement that detailed time records be kept, and maintained, by directors, also seems to be generally ignored. Time dedication is not only an MFSA requirement for directors, it is also mandated by the European Central Bank (ECB). We want to know how a director holding a portfolio of one hundred companies can truthfully and accurately keep time records. There aren't enough hours in a day to justify the time records recorded by many Maltese directors of shell companies, but nobody seems to be calling them out on it. Read the MFSA Personal Questionaire template form for specific information here.

Perhaps an illustration might make it easier to understand: Director ARMIN ECKERMANN, who was reportedly fired from Fimbank; worked at and was a director at Pilatus Bank, which was closed by regulators, and previously worked at West LB, which was liquidated with debts listed at €65bn. How Herr Eckermann is able to hold any position in the financial services industry at this time. simply cannot be explained, given MFSA regulations.  Consider him as a representative sample of many of the other Maltese directors of shell companies. Finally, he appears to be the only staff member at €2bn Banco Finantia. Exactly what are his duties there, other than signing checks ?



Now do you see why the EU is so critical of Malta's shell companies.






RECHERCHE´- SAMUEL SALMAN EL REDA - HEZBOLLAH TERRORISTE


IS MALTA TRYING TO RUN OUT THE CLOCK ON CRIMINAL INDICTMENTS OF PILATUS BANK OFFICERS & DIRECTORS ?



Complaints, from individuals living in Malta to the effect that the winding up of affairs of Pilatus Bank by the Competent Person appears to to be deliberately slow-walked have surfaced in local media. While the hefty fees being charged are obviously an incentive to drag out the proceedings for years, in order to maximize income, there may be a more sinister reason why we are not seeing any movement against Pilatus' former offices and directors: to run out the clock on criminal prosecutions.

As the years pass since Pilatus Bank lost its license, there is a strong possibility that the Statute of Limitations will eventually prevent ANY criminal charges being filed, especially against former or present Maltese government officials. The bank was an obvious money laundering machine for Politically Exposed Persons (PEPs), but none of its officers and directors appear to be under serious criminal investigation. In truth and in fact, Malta is imminently poised to hit a European money laundering "Grey List," due at least in part to the fact that violators do not seem to arrested for money laundering in Malta if they are well connected.

Frankly, unless those who operated, and supervised, the bank are held to account for their money laundering sins and transgressions, Malta will soon be seen as a Banana Republic sitting in the midst of the European Union, which could have serious consequences when it comes to the ability of Malta's banks in retaining correspondent banking privileges with US banks. As we have repeatedly warned, unless serious action, including the filing of criminal cases for money laundering, is taken, Malta may be destined to be regarded as the new Cayman Islands, considered an offshore financial center where the Rule of Law is seldom observed.  

Monday, June 29, 2020

FRAUD ALLEGED AT SWISS BANK; THE BANK HAS A REPRESENTATIVE OFFICE IN MIAMI


An alert from Europe, regarding a Swiss bank that maintains a representative office on Brickell Avenue in Miami, has been brought to our attention. Geneva's Banque Syz SA (Bank Syz), has reportedly been subject to fraud, involving an independant asset manager for which it acted as custodian agent. The asset manager has been identified as Compass Finance, which allegedly invested clients' complete portfolio on options. There is no additional confirmed information available at this time.


Sunday, June 28, 2020

BENEFICIARY IN ALEX SAAB MORAN-BRUCE BAGLEY MONEY LAUNDERING CASE IDENTIFIED




Reports regarding the money laundering case against former UM Professor Bruce Bagley has identified the intermediary whom Bagley transferred the laundered cash to. He is known to be "fixer", or individual who assisted US law enforcement secure plea deals with narcotics traffickers for a fee: JORGE LUIS HERNANDEZ VLLAZON, a Colombian national whose street name was "Boliche." A former drug trafficker and ex-paramilitary, he is not the kind of individual you want to meet at night in a dark alley.


Hernández, who is from Valledupar, and operated most recently out of Miami, reportedly was a Cooperating Individual (CI) for the DEA, and also offered his services, for a price, to attorneys seking clients who wanted to make a favorable plea agreement with the US Department of Justice, which often occur out of the view of the public, so that law enforcement may obtain critical evidence on other targets or Persons of Interest. His efforts occured mainly in a shadowy world that law enforcement prefers to remain confidential, for valid reasons.

Hernández appears to have been a client of Bagley in some sort of consulting arrangement, though Bagley, who is an expert on Latin American narcotics crime, is not an attorney. Bagley acted as the conduit through which Saab could move the proceeds of corruption to Hernández. One report says that Saab employed Hernández to secure a plea deal with a low prison sentence. Given that the money transferred by Bagley constituted criminal proceds, obtained through corruption, Bagley committed money laundering offenses. He received fees for his services. Didn't he, as a known expert witness in the field, know he was committing a crime ?

Bruce Bagley has entered a plea of guilty, and his sentencing date has been scheduled for later this year. Meanwhile, Hernández, the Fixer, has fled Miami and his current whereabouts are unknown. Individuals who engage with people who are themselves working in the grey area between law enforcement and criminals can, if not careful, be trapped in the spider web.
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CHINESE SPY IN THE UNITED STATES USED CAYMAN ISLANDS COMPANY

Hao Zhang
A Chinese national, HAO ZHANG, a/k/a Zhang Hao, was found guilty by a California jury of stealing dual-purpose trade secrets which have military applications, from two American companies, one of which employed him. The stolen technology, which involved semiconductors and optoelectronics systems for communications devices, patented by Avago, of San Jose, and Skyworks, of Woburn Massachusetts, were intended to benefit an instrumentaility of the Chinese Government, state-controlled Tianjin University (TJU), which is owned by the Peoples' Republic of China. China's mobile telephone exports have long been suspected of covertly containing software that allows China to monitor and extract information from devices shipped to Western countries.

The charges he was convicted of:
(1) Economic Espionage.
(2) Theft of Trade Secrets.
(3) Conspiracy to conduct Economic Espionage.
(4) Conspiracy to steal Trade Secrets.

 Most interesting was the fact that the defendant formed a Cayman Islands company, NOVANA, to handle the anticipated profits of the criminal espionage operation. Compare and contrast this with our recent article detailing how a legitimate Asian company was reincorporating itself in Switzerland, due to the problems it encountered with the world's banks when they noticed that the Cayman Islands was the domicile of the company, and declined to conduct any trading.



Sentencing has been set for August 31, 2020. A long prison sentence as well as a signfiicant fine is authorized by Federal law for these violations.


Saturday, June 27, 2020

CONVICTED LOBBYIST JACK ABRAMOFF CHARGED AGAIN, THIS TIME WITH LAW ENACTED DUE TO HIS PRIOR CASE






If you were working in Washington in 2007, you may recall the passage of the Lobbying Disclosure Act, which was passed in the aftermath of one of the major corruption cases of our generation, the Jack Abranoff case. Abramoff,  a Washington lobbyist who took clearly excessive fees from Native American Tribe clients seeking to open casinos on tribal lands, and paid bribes to Congressmen for favors, was the poster boy for influence poeddling and corruption in the Capitol. In fact, he is the reason that the Lobbying Disclosure Act was passed, after he pled guilty to lobbying violations and criminal conspiracy. A number of US Government officials were also charged and convicted.

While he was very public regarding his purported rehabilitation after 2010, post-prison, Mr. Abramoff has now been charged with violating the very Federal law that was created in response to his prior crimes. In fact, he is believed to be the very first individual charged under the law. Those readers who understand the principle of Karma are most likely nodding their heads, for this is a case where the offender's prior misconduct actually resulted in the enactment of a new statute which he later violated.

Abramoff acted as a lobbyist for the marijuana industry, while failing to register, as required by law. He also promoted claims that he knew were false, for the fraudulent cryptocurrency firm, AML Bitcoin. He faces five years in Federal Prison, and he also has the Securities & Exchange Commission after him as well.

 Obviously, he didn't learn from his earlier mistakes. Has he forgotten what it was like to spend almost four years in Federal Prison ?

 

IDENTIFYING THE FINANCIAL INSTITUTIONS THAT ASSISTED PILATUS BANK



One of banking's dark secrets is that some of the world's most powerful financial institutions earn a tidy sum by allowing dodgy banks to have correspondent accounts, which affords them access to the American financial structure, and the ability to obtain sorely needed US Dollars. Malta's now-shuttered (and Iranian owmed and controlled) Pilatus Bank had a number of ways, both directly and indirectly, to enter the American banking system, due to the assistance and support it received from US, as well as European, banks.

How this entry was readily granted is a bit of a mystery, because it only took a superficial inquiry to determine that Pilatus Bank was owned and operated by Iranian nationals, in a time when Iran was subject to massive American, and even international, sanctions. Even primitive due diligence would have uncovered this sordid fact, which seriously raises risk levels for any bank subject to US regulatory agencies, whether directly or through correspondent relationships.

Although the identity of these facilitating banks was made public over the last few years (since Pilatus lost its license), looking at them all at once gives us a clearer picture of a "don't ask, don't tell' culture where profits trump compliance. Should the real reason for those correspondent accounts not have been known; to evade US sanctions ? After all, the bank's owner held a St Kitts CBI passport, and its CEO one from Dominica. Does that not tell you what was really going on at Pilatus ?

Taken directly from published information, here are the banks that assisted Pilatus Bank in accessing the New York banking structure. It is presented for risk management purposes only.



(1) BANK OF VALLETTA: Pilatus had an account there. BOV had correspondent accounts at US banks, giving Pilatus ready access when needed.



(2) ING BANK BELGIUM and BANCO POPULARE DI SONDRIO: Pilatus conveniently had accounts there.



(3) JP MORGAN and  WELLS FARG: These were the direct corespondent relationships that Pilatus had with American banks.



(4) DEUTSCHE BANK: One of the world's most prominent financial instiitutions, Pilatus had an account there, making indirect access to the US financial structure through its facilities possible. We note that Deutsche Bank also had a correspondent relationshiop with another Maltese bank, FIMBank. Remember the connections between both banks through ARMIN ECKERMANN ? We will tie that up in a subsequent article.


Director at both Pilatus and FIMBank


Compliance officers who regularly assess Country Risk, are also aware that there is an unofficial, but quite important, parallel assessment that is generally calculated. which I call it Bank Risk: the risk level that banks unofficially assign to other banks known to be involved in high-risk activities. Holding correspondent accounts for a known offshore Iranian-owned bank certainly qualifies as a high risk activity. Keep this article in mind for future reference, if your bank conducts business with any of the above financial institutions.


    

Friday, June 26, 2020

FBI SEEKING INFORMATION ON INDIVIDUALS VANDALIZING FEDERAL FACILITIES


COURT GIVES ROGER STONE AN ADDITIONAL TWO WEEKS TO SURRENDER, PUTS HIM ON HOUSE ARREST

Readers who wanted to know whether ROGER STONE was surrendering on schedule on June 30, please be advised that the Court gave him an additional two weeks of freedom, before he must begin his sentence. He was, however, ordered to submit to House Arrest (Home Confinement) with monitoring.

Rumors continue to fly about to the effect that that he will receive a Presidential Pardon before he ever serves a day in Federal Prison.


PENNSYLVANIA CHECK CASHING STORE OWNER DRAWS 14 YEAR SENTENCE FOR MONEY LAUNDERING




A Pennsylvania white collar criminal who was the leader and organizer of a crew that fraudulently obtained $7.7m in Federal tax refunds, and then processed them through his three check cashing businesses, which were fronts used solely to hide criminal activities, was sentenced to 169 months' imprisonment in US District Court in Scranton. Jonathan Jacome, age 30, executed a plea agreement to one count of Money Laundering Conspiracy.

The defendant admitted in his plea agreement that he has engaged in:
(1) Theft of Public Money.
(2) Wire Fraud.
(3) Bank Fraud.
(4) Money Laundering.

Jacome's sentence included an Order of Restitution for the amount stolen, and he must forfeit real property purchased with the proceeds of his crimes. If you were wondering about the length of his sentence, the defendant, and others, presented false testimony to a Federal Grand Jury, and he therefore received an enhancement to his Guidelines Sentence calculation for Obstruction of Justice.

It is sentences like this that serve as an effective deterrence to others. Generally, most money laundering cases result in shorter sentences, which sends the wrong signal to individuals who regularly have an opportunity to engage in money laundering. Only if they know that the potential sentence which a court could mete out to them could be severe will they be effectively deterred. 

Thursday, June 25, 2020

THE KING OF DOMINICA IS MOVING TO A NEW PALACE



What you are seeing above is a mansion truly fit for a king, or he who would be king in these troubled times; located in Dominca's exclusive Morne Daniel district, it will be the new home of Dominica's Prime Minister Roosevelt Skerrit, if we believe our most reliable sources.

Fit for a king, or a pretender to the throne.
According to insiders, the Cabinet has authorized that the mansion be rented, at the royal rate of EC$32,000 a month, from Montreal Management, for the use of Roosevelt Skerrit. That's allmost twelve thousand US Dollars. Extravagant, you say ?  This rubber-stamp approval is said to be a state secret, not available to the public.

Another insider, who is in a position to know, has confirmed that the tue owner of the property is actually Roosevelt Skerrit himself. He has set up the fiction of a rental in order to justify the expenditure of a large sum every month, which one can only image where it will end up.

Rumors abound in Dominca's capital, Roseau that there's a lot of diplomatic passport cash floating around that needs to be cleaned before it can see the light of day. Can you say money laundering in patois ? 

OFAC SANCTIONS STEEL, ALUMINUM AND IRON COMPANIES IN IRAN'S METALS SECTOR



In addition to designating four companies in Iran's metals industry, note that one Germany-based and three UAE-based sales agents are also sanctioned. If you think that any of your bank clients might possibly trade, directly or indirectly, with the Iranian metals sector, you should review the Treasury information here.

COURT ORDERS THAT ROGER STONE, SEEKING A DELAY TO SURRENDER, DISCLOSE INFORMATION


Roger Stone's infamous Richard Milhous Nixon tatoo
As we have previously reported, ROGER STONE, was convicted and sentenced to 40 months in Federal Prison on a number of charges, in a case where improper influence regarding sentencing has been alleged. Stone is seeking to delay his June 30, 2020 Self Surrender date, claimng that the combination of BOP failure to protect him from the Coronavirus, and his purported failing health makes him a candidate for a fatal outcome, should he be incarcerated.

The Court has responded, seeking evidence from Stone:

"MINUTE ORDER as to ROGER J. STONE, JR.. It is ORDERED that the defendant shall inform the court whether his date to report to the Bureau of Prisons has been previously extended by BOP and if so, when and for how long, ans whether he made a request to BOP for an extension to June30, and if so, what the response was and what reasons, if any, were provided to BOP.

It is FURTHER ORDERED that defendant shall provide any correspondence with BOP memorializing those requests and decisions. Any records containing personal medical information may be filed under seal. Defendant's submission is due by 12:00 noon on June 26, 2020.

SO ORDERED. signed ny Judge Amy Berman Jackson on 6/25/20." 

Wednesday, June 24, 2020

GROUNDBREAKING LAWSUIT IN LEBANON CHARGES HEZBOLLAH WITH TAX AND CUSTOMS EVASION AND MONEY LAUNDERING

Hezbollah is beng brought to court in Lebanon, in a case of first impression.


In a new lawsuit that appears to be the first of its kind in Lebanon, the global terrorist organization Hezbollah (Party of God) has been accused of tax and customs evasion, and money laundering. Attorney Majd Harb, who is handling the case, which has reportedly been filed through the Financial Public Prosecutor's Office, alleges that Hezbollah is depriving the Lebanese State of hundeds of millions of dollars of revenue annually, which is sorely needed  to retire debt.



US and France-educated Attorney Majd Harb

Though Hezbollah's annual budget is remored by some to be the equivalent of one billion US dollars, the terrorist organization pays no taxes. One source asserts that Lebanese evade taxes on total domestic income of $5bn. Hezbollah pays no taxes on salaries and pensions of employees and members, nor does it pay customs duties on its goods when entering Lebanon, and it receives massive amounts of covert untaxed financial aid from Iran, investing a portion, which gives rise to the money laundering charges.

The lawsuit appears to be an attempt to increase revenue for the Government of Lebanon, which is  literally drowning in $80m in debt, and unable to meet its international obligations as they come due.






FORMER CLICO CHAIRMAN LEROY PARRIS CHARGED IN BARBADOS WITH MONEY LAUNDERING, OTHER CRIMES



Leroy Parris, in custody, en route to Magistrate's Court today.


Leroy Parris, the former Chairman of the failed CLICO Barbados insurance company, appeared in Magistrate's Court today, and was granted bond in the amount of Bds$1.5m. The defendant stands accused of stealing Bds$3,333,000 from CLICO, by having the funds, represented to be legal fees,  ultimately diverted to his personal use and possession.

The specific charges:

(1) Money Laundering.
(2) Conspiracy to Defraud the Crown and the Commissioner of Revenue of public revenue,
by failing to submit tax returns, or account to the Commissioner for taxes on his income (tax evasion).
(3) Theft of Bds$3,333,000, belonging to CLICO International Life Insurance Limited.
(4) Conspiracy to Defraud CLICO by inducing the company to pay out the funds to a law firm.

Dominica Diplomatic Passport
Parris was ordered to surrender his travel documents, and to report to the police twice a week. This may expose the circumstnces surrounding precisely how he managed to acquire a Dominica Diplomtic Passport, listing him as " Ambassador at Large," Dominica has not as yet explained how Parris qualified to acquire his Dominica passport, as he performs no known diplomatic or other services for the Government of Dominica, and in truth and in fact, he is known to be a close associate of Dominica's dodgy Prime Minister, Roosevelt Skerrit. Parris allegedly has assisted with covertly providing Skerrit's election campaigns with funds, which appears to be a major violation of Dominican law.

Parris' next court appearance has been scheduled for November 19, 2020.

RALPH SANDERS, CALIFORNIA'S TRIPLE THREAT ; FRAUDSTER, PREDATOR & PEDOPHILE

The Face of the Enemy

In many states, individuals with felony convictions may seal or expunge their criminal records after all their conditions of release have been complied with. However, in states like California, a convicted criminal cannot erase his records from public access, nor delete their fingerprints from the FBIs National Crime Information Center (NCIC), or the states' criminal justice databases, especially if any of his convictions are for child molestation or any other sex crimes.

The convicted fraudster, predator, blackmailer & pedophile, RALPH SANDERS, also known as Rafael Sanders, Rafeal Sanders, or more recently, RAFAEL S, has been trying to conceal his extensive criminal record by resorting to a number of cloaking methods. Sanders is a three-time convicted felon and career criminal, and has been featured on this blog multiple times.

Sanders was able to deceive the San Leandro (California) Chrysler-Dodge-Jeep automobile dealership into hiring him, due to his use of a clean alias. He also fooled the owners and managers of the San Francisco City Cats, a junior basketball team, which hired him as its marketing director. The Cats later discovered that he was semi-literate, unable to perform his duties, and has a lengthy criminal history, including three prison sentences for Forgery, Burglary and Battery, all served in Caifornia state prisons, and prison sentences in a number of states.



After we reported on June 8, 2020 on his multiple frauds, he relocated to yet another Northern California city, and continued to target  professional businesswomen, all of whom hold important and well-paying jobs. He attracted several of his latest victims by passing himself off as a retired Sacramento Kings professional basketball star, and a current coach for the Golden State Warriors. After he defrauded them out of a substantial sum of money, he threatened and intimidated them, making repeated telephone calls and text messages, and posting false statements about them to the Internet, including publishing bogus stories to the dodgy Rip off Report website. He is a classic predator, and quite dangerous when exposed and cornered.

 He then notified his victims that he would not remove the bogus statements from the Web unless they paid him, which constitutes blackmail and extortion in the State of California.

This ignorant and illiterate fraudster also has created a bogus blog to falsely accuse and harshly attack this blogger and others, for accurately reporting the facts, and alerting the public at large about the threats that he poses, giving Sanders much needed exposure. The fraudster also created a false narrative, without an iota of proof, and committed identity theft by using an unauthorized business name in his profile. The owners of the legitimate business have been alerted to his fraudulent use of their names and businesses.

To combat the negative publicity that has appeared online against him in the past, Sanders appeals to the naive, and alleges that the author is merely a deranged individual solely responsible for the Internet postings. In truth and in fact, he has long been under criminal investigation by law enforcement, due to the many complaints received from his female victims.



Sanders continues to feel the heat, and the ever-present threat of being exposed to his victims, due to the widespread dissemination of his method of operation. Numerous victims have now stepped forward, to file complaints with law enforcement, which is actively investigating his ongoing crime spree. The public in California should be alerted to his methods, and remain on guard. He has a history of stalking his victims first, then dispatching street thugs to their homes and businesses after they complain to the law, in the hope that they can be intimidated into silence, not testify against him, and terminate their cooperation with the authorities.

Watch out for this guy, Californians. If you encounter him, do not engage in conversation, notify your local law enforcement, or the FBI,  immediately. Do not give him your name, or any other personal information, lest he later seek you out, and makes you his latest victim.




FORMER PROSECUTOR TO DELIVER SCATHING INDICTMENT OF TRUMP'S POLITICAL INTERFERENCE WITH ROGER STONE SENTENCING



In prepared remarks scheduled to be delivered later today, before a committee of the US Congrss, AUSA Adam Zelinsky has detailed the complete story of the undue influence the Trump Administration imposed upon the Roger Stone sentencing. It is extremely disturbing; the Opening Statement is widely available online, and has been summarized in the media, or you may wish to watch the proceeding live.

if you cannot find it, and you require a copy, send me email at miamicompliance@gmail.com and I will pop it over to you.

THE SHAPE OF THNGS TO COME ? PUBLICLY-TRADED CAYMAN ISLANDS COMPANY REDOMICILES TO SWITZERLAND TO ESCAPE EFFECT OF TAX HAVEN STIGMA ON SALES




A major Asian company, whose shares are publicly-traded, has announced that it is redomiciling (reincorporating) itself in Switzerland. The company's June 18, 2020 Annual General Meeting Announcement, made from Zurich, disclosed that its current Cayman Islands domicile is creating problems in the international financial community, and potentially hurting both sales and its global image.

Read this extract from its recent message to its shareholders, which appears to have been carefully drafted to extol the benefits of reincorporation (emphasis added) versus the disadvantages of Cayman:

"We are particularly pleased that the special resolutions to approve redomiliciation to Switzerland were passed. The current Cayman Islands domicile has become a compliance red flag for most banks and trading intermediaries outside Switzerland, which have prohibited outright or made it very difficult to trade shares in companies incorporated in the Cayman Islands. The Board of Directors  believes the share price weakened, as investors are not able to easly but or sell shares in [XYZ Corporation] , ans a redomicile should create greater liquidity for [XYZs] shares. "

If publicly-traded companies incorporated in the Cayman Islands find their domicile constitutes a "Compliance red flag" is that not a signal to the global compliance community at large that, by definition, ANY Cayman Islands company should now, for risk management purposes, be regarded, for all purposes, as possessing Elevated Risk ? Compliance officers whose portfolio include the annual assessment of Country Risk kindly take note.



Tuesday, June 23, 2020

ROGER STONE SEEKS YET ANOTHER POSTPONEMENT OF HIS PRISON SENTENCE



Roger Stone, convicted and sentenced to 40 months in Federal Prison, is asking the Court to delay his surrender until September. He is asserting that the Coronavirus could prove fatal to him if he is incarcerated, given his age and health status.

He admite that FCI Jessup, where he is to begin serving his sentence has zero Coronavirus infections, but he states that the Buerau of Prisons cannot comply with current CDC Guidelines for safety, and that therefore he should be able to delay the start of his sentence until it is safe. We await the Court's rulng on his Unopposed Motion, which stands a good chance of being granted, due to the current situation within the BOP.




LEROY PARRIS, FORMER CHAIRMAN OF CLICO BARBADOS, ARRESTED FOR FRAUD; HOLDS DOMINICA DIPLOMATIC PASSPORT

The Smoking Gun

Leroy Parris, the former Chairman of CLICO International Insurance Company, was arrested by Barbados Police in connection with a fraud investigation involving a company Bds$3.3m payment for legal fees that was diverted to another company, and then allegedly into Parris' control.

Parris, who has been linked to illegal campaign contributions paid to the Dominica election campaign of PM Roosevelt Skerrit, is a known associate of Skerrit. Parris holds a Dominica diplomatic passport that lists him as "Ambassador at Large, " though he performs absolutely no duties for the Commonwealth of Dominica, He is the latest in a long list of wealthy foreign white-collar criminals who obtaned a Dominica Diplomatic Passport, for cash under the table, for the sole purpose of outwitting local law enforcement, and customs and immigration officers abroad, and for status and prestige. He performs no services as a diplomat, and his title of "Ambassador at Large" is fabricated and of no legal force and effect.



Most Dominica diplomatic passport holders, who are foreign nationals using their identity document to evade customs searches at international borders, or to claim diplomatic immunity to avoid arrest or detention, perform no true diplomatic functions whatsoever for Dominica. They employ their diplomatic passports to smuggle cash, jewelry and financial instruments past customs officers at ports of entry, and not for the legitimate purposes for which the passports were intended. If they can, they use them to evade arrest on criminal charges, or to use an alias.





Parris is only the latest to be arrested ; He will not be the last. It has been estimated that over one hundred Dominica diplomatic passport holders have been arrested abroad on felony charges.





NIGERIAN FRAUDSTERS SANCTIONED FOR $6m TAKEN IN ROMANCE SCAMS AND BUSINESS EMAIL COMPROMISE



The Office of Foreign Assets Control (OFAC) has designated six Nigerian nationals, pursuant to Executive Orders (EO)13694 & 13757, for cyber-enabled activities, relating to Romance Scams and Business Email Compromise (BEC). Here are the named individuals:


WAS USA AT SDNY FIRED BY TRUMP PRIMARILY TO KILL HALKBANK SANCTIONS CASE FOR ERDOGAN ?



I direct your attention to the latest public disclosures regarding the new book out by former Trump National Security Adviser John Bolton, regarding the Halkbank case. Bolton asserts that Trump and Turkish President Recep Erdogan discussed the Halkbank case several times, with Erdogan seeking a settlement for Halkbank, a state-owned bank deeply mired in Iran sanctions evasion activity. Halkbank, it seems, is the personal piggy-bank for Erdogan, according to reliable reports. It is not KnOwn whether Trump personal attorney Rudolph Giuliani is invlved, but he is known to be under investigation by SDNY.

Trump allegedly told Erdogan that he was going to have the"Obama people" removed from SDNY, and replaced with his own loyalists, and that they would "take care of this." United States Attorney Berman was not an Obama appointee, by the way, he was actually appointed by the District Judges, when Trump was unable gain approval for any of his candidates. (Trump's recent chosen replacement for Berman was never been a criminal prosecutor). I cannot remember any other American President stating to anyone that he intended to interfere with a pending Federal criminal case since Richard Nixon, who resigned to avoid who would have been a successful Impeachment proceeding.

Most troubling is John Bolton's statement that there were other Trump sins and transgressions that took place while Bolton was the Adviser for National Security, and it is concerning that pehaps other significant money laundering prosecutions may also have been, or are currently on the President's list of cases to dispose of, as a favor to a foreign power, and Bolton's pasages detailing them was stricken from his book for national security reasons. After all, the current administration has been repeatedly accused for over-classifying information, for the sole reason of protecting the President, or his appointees, from embarrasment or worse.

Are there any major money laundering cases currently withering on the vine, without any logical or legal reason ? If so, someone needs to take a hard look at why. Has there been a change of prosecutors, in favor of one who is a political appointee, or a known close associate of the US Attorney General ? Remember, this is what happened in the Michael Flynn case.




Monday, June 22, 2020

RECHERCHE -TALAL HAMIYAH & FU'AD SHUKR - HEZBOLLAH


UK LAWYERS GROUP SAYS BRITISH AUTHORITIES ARE INVESTIGATING PWC FOR IGNORING CHARITIES' LINKS TO TERRORIST ORGANIZATIONS




The British NGO UK Lawyers for Israel is reporting that PwC (Price Waterhouse Coopers) is under investigation by British authorities for its audits of the Union of Agricultural Work Committees (UAWC) and Defence for Children International (DCI-P), which had links to the Popular Front for the Liberation of Palestine (PFLP) a designated terrorist organization, and that those links were ignored by PwC.



Apparently, PwC breached the OECD Guidelines for Multinational Enterprises on Responsible Business  practices, by delibeately ignoring the link between the charities and the PFLP. According to the allegations, PwC was required to mitigate the impact of these terrorist links in its audits. The charities allegedly employed members of the PFLP, supported the members, finded the PFLP; some of the members of the UAWC were arrested on terrorism charges in Israel.  

Readers who wish to review the details can find them at the NGOs website. The URL is in the illustration at the beginning of the article.

Saturday, June 20, 2020

CHART SHOWS NEW ENTITIES AND INDIVIDUALS LISTED IN ALEX SAAB MORAN'S OIL SANCTIONS EVASION NETWORK

The Department of the Treasury has published a chart showing the relationship between the individuals and entities that are part of Alex Saab Moran's extensive criminal network, which evades US sanctions on Venezuelan oil through covert sales abroad, employing entities in Mexico, the United States, the United Kingdom, and Singapore.


NEW LAWSUIT CLAIMS THAT QATAR FINANCES HAMAS AND PALESTINIAN ISLAMIC JIHAD THROUGH ENTITIES CONTROLLED BY QATAR'S ROYAL FAMILY




A new wrongful death suit, filed in US District Court in New York, charges that Qatar secretly sought to evade US sanctions, by using organizations owned and controlled by the country's Royal Family, to funnel money to Hamas and Palestinian Islamic Jihad, both Specially Designated Global Terrorist (SDGT) organizations. The Plaintiffs are fifty-one relatives of American citizens injured by these two sanctioned organizations, in Israel or the West Bank (Judea and Samaria) and the heirs of ten of those killed in terrorist attacks, between 2014 and 2016. One of the victims was Taylor Force, a former US Army Captain, a graduate of West Point, and a veteran of both Afghanistan and Iraq. The Taylor Force Act is named for him.

The instruments through which Qatar accomplished the terrorist financing were:

(1) QATAR CHARITY; The organization's board Chairman is HAMAD BIN NASSER AL-THANI, a member of the Royal Family. Formerly known as the Qatar Charitable Society, it was accused of laundering money for Osama bin Laden.



(2) QATAR NARIONAL BANK which maintained an account of HUSAN BADRAM, a prominent Hamas military leader, and the known organizer of several fatal terorist bombings in Israel.



(3) MASRAF AL-RAYAN BANK, which is accused of converting Qatar Charity funds to US Dolars, through a bank in New York, and making them available to the terrorists through local Charity branch offices, via the Bank of Palestinae and the Islamic Bank in Ramallah.




The plaintiffs assert that Qatar gave more than $50m to Hamas in recent years. The defendants have not yet been served in the case; a Status Conference has been scheduled for July 22, 2020. The style of the case is Force vs. Qatar Charity, Case No.: 20-02578 (EDNY).