Monday, August 31, 2020


For those who were surprised last year by the sudden death of the British journalist Barry Randall, the editor of the Caribbean News Now website, details have leaked out of the continuing investigation in what has been referred to as a homicide, with disturbing allegations. we have heard reports that he was poisoned with a low dose of the radioactive element Polonium, which caused organ failure and his eventual death.

Regular readers of the website, which regularly exposed corruption among the five East Caribbean States that maintain Citizenship by Investment (CBI/CIP) programs, are aware that Mr. Randall quite often directed his investigative efforts towards one jurisdiction in particular, which he considered the worst offender. The perpetrators, who are believed have been from Eastern Europe, gave the victim a fatal dose when he traveled to that region, lured in by a bogus promise of important information about CBI corruption; they were allegedly employed by the leader of the country that Randall singled out for special attention, due to the rampant corruption that pervades a nation he rules with an iron hand, employing a troop of armed paramilitary police. That nation was highlighted in two groundbreaking investigative programs aired by major media recently.

The investigation, which we understand is taking place on both sides of the Atlantic, is ongoing.      


Krull and anti-US pro-PDVSA banner

Hidden in the court file of MATTHIAS KRULL, the former Julius Baer banker who will start his ten-year sentence for money laundering in September, is an order sealing certain documents for a period of one year. Given Krull's involvement in moving dirty money out of Venezuela, through Malta, Switzerland and elsewhere, and the need for absolute secrecy in advance of new indictments, it is a distinct possibility that the Krull case is Ground Zero for the Malta indictments. Can you say Portmann Capital ?

The other day, Krull received approval to relocate to Miami.While this might seem trivial to the uninitiated observer, should the US Attorney want to place him in that residence, while he spends months testifying before a Grand Jury in the Southern District of Florida, it would reduce his level of stress, if he is living at home, and not in the Federal Detention Center downtown. They do want to take good care of their star witness.

Why, you might ask, are there documents sealed for 365 days in Krull's court file, unless they involve his cooperation against others ? Remember, his only method of sentence reduction now is pursuant to Rule 35(b), which only the US Attorney can utilize, and which requires Substantial Assistance, resulting in new indictments or locating major criminal assets for forfeiture.

Truthfully, adding Malta defendants to a case involving millions illegally obtained in Venezuela may just be a sideshow for the Main Event, the eventual indictment of Venezuelan and Iranian nationals, as part of America's "Take no Prisoners" policy against  those dictatorships, but try telling that to the country's former Prime Minister and his ex-Chief of Staff.

Remember this: Krull must take heads in order to have his 10-yr sentence reduced. What did you thing he would be doing, serving  his entire sentence, without trying to better his situation ? Expect to see indictments before the Presidential Election, because in 2020 America, politics trumps justice, and let the casualties fall where they may, Malta's criminal elite as incidental, perimeter players in the laundering drama, but don't tell them that; They might be offended.

Sunday, August 30, 2020


 Consider this painting of the Great Siege of Malta, 1565, where the Turks tried, and failed, to capture the city. Perhaps they will succeed in 2020.Turkish influence in Malta, which once prized its neutral status, but whose government now is dominated by Turkey, acting on behalf of the Islamic Republic of Iran. have the Turks finally won ?

Friday, August 28, 2020


Saab's Antigua diplomatic passport

Attorneys for the fugitive  money launderer ALEX NAIN SAAB MORAN, who on July 31 was ordered extradited by Cape Verde's Barlavento Court of Appeal, are throwing everything but the kitchen sink at the Supreme Court of Justice, to convince the STJ to reverse the lower court's ruling.

The arguments they are asserting:

(1) Due to the COVID-19 virus, Saab's health is in danger all the time that he remains in custody. he should be released forthwith.

(2) Saab faces a possible Life Sentence if convicted in the United States, and the Republic of Cape Verde appears to oppose the extradition of individuals who might have such a sentence imposed upon them. In a 2017 extradition case against an Iranian and a Pakistani, who were looking at possible life for money laundering and narcotics trafficking, the STJ reversed the lower court ruling, and declined to extradite them to the United States.

(3) Saab, a Colombian national, had diplomatic immunity by virtue of his Venezuelan diplomatic passport. This argument fails, as the Vienna Convention on Diplomatic Relations only confers immunity in transit to an assignment where the diplomat will be presenting his credentials to be accredited at his destination. Saab's argument has not basis in law, and his dodgy " diplomatic appointment" by Venezuela, and supposed Venezuelan nationality, is not based on fact.

One of Saab's two Dominica offshore banks; he has one in Antigua also

Some commentators are asserting that Saab's attorneys simply trying to 'run out the clock" and obtain a delay until the American election, after which they believe that the likely incoming Democratic Administration will back off on extradition. Saab's lawyers forget that Saab has been indicted, has been sanctioned by OFAC, and is a major target of the Department of Justice. They should not expect any change in American policy towards him. 


The trial judge in the Ali Sadr Hasheminajad case has entered an order noting that the Government's application for a nolle prosequi as to co-defendant BAHRAM KARIMI remains pending. The Court has required the US Attorney to take the following actions:

(1) Inform the Court whether it seeks dismissal of the indictment against Karimi, pursuant to Rule 48, as it did with Sadr.

(2) Indicate whether the dismissal is with, or without, prejudice, and to provide justification or authority for its request.

(3) Submit a proposed order for the Court's review.

Karimi, who was charged in January with Bank Fraud, Conspiracy to commit Bank Fraud, and Lying to Federal Investigators, resides in Canada, and has apparently never been taken into custody, though he has been interviewed there. If the Acting US Attorney adopts the same position as her office did with Sadr, that its Brady violations were so egregious that Karimi's case should be dismissed, to satisfy the ends of justice, then do we know that her office is taking such a radical action due to what amounts to prosecutorial misconduct ?

On the other hand, if Sadr's dismissal was due to what amounted to a reward for his rendering of extraordinary Substantial Assistance, Karimi may not get get to walk away from his charges. We shall see how this all plays out. Meanwhile, the people of Malta are seeing that justice was not served regarding Ali Sadr, who laundered millions through his Malta-based Pilatus Bank, and will be watching to see if Karimi also gets a pass for his crimes.


Let's say you are a compliance officer at a major international bank in the City, London's financial district; an individual purporting to be a wealthy business owner from Malta is seeking to open what promises to be a lucrative account relationship. Your due diligence investigation, which includes accessing Malta's online e-Courts database, fails to show that he has any any criminal convictions or civil judgments, and you do not identify him as a government official or Politically Exposed Person (PEP) from web searches, so you approve him.

Big mistake, for not only is he a mid-level government employee, he has a record of two prior felony convictions in Malta, one for embezzlement of state funds,and one for falsification of documents. It seems that this individual had his attorney in Valletta  remove those convictions from the online database, meaning that there is no public access, unless you are an attorney, and then only for very restricted legal research and case law purposes. No overseas bank compliance officer has the time, or money, to engage a law firm in Malta, to search records for every Maltese who comes in the bank's door, looking for services. Besides, look at the language above; Is the lawyer even allowed to disclose what he or she has learned ?

Essentially, those convictions are not to be published, and are considered prohibited individual personal data, under the the European Union's General Data protection Regulations (GDPR). This does directly conflict with the legal requirement that court judgments are always to be accessible to the public.While there is a Right to be Forgotten in the EU, it does not mean that court judgments are to be deleted, and their existence purged from public records. There is NO Right of Erasure under the EU, notwithstanding that some leaders in Malta have created it, literally under the table.

Apparently the culprits are some board, whose members have curiously not been identified, operating under the Ministry of Justice, which review attorneys' requests, and orders court judgments forever deleted from the online database. Can anyone out there in Malta say Star Chamber ?

The Court of the Star Chamber
Going back to our compliance officer in the City, he fails to find the two criminal convictions; as for the failure to identify the customer as a PEP, lower- and even mid-level government employees are often not listed on any government database. Staff attorneys, assistants to directors and deputy secretaries of government agencies generally do not appear on rosters or lists that are publicly available, and since many of them have access to government funds, they cannot be identified as PEPs.

The City compliance officer, who failed to identify his new customer as a PEP, or as a felon, passed him s low risk, only to find out two years later that he moved a large amount of money, believed to be bribes and kickbacks received for approving a lucrative government contract, as well as funds embezzled from government accounts, through the bank, after which he was arrested and indicted.

As you can see, unless Malta not only abolishes this policy of allowing the deletion of criminal records, and restores those which have been removed, no e-Court searches can be trusted to be accurate and complete, and all searches of Malta court records are therefore suspect. Does this mean that all Maltese are now high-risk when seeking service at the world's banks ?

Thursday, August 27, 2020


JEFFREY WEBB, the Caymanian soccer executive,Vice President of FIFA, who pled guilty in 2015 to Money Laundering Conspiracy, Racketeering and Wire Fraud, in the massive FIFA corruption scandal, has had his sentencing rescheduled for a record eleventh time. A note on the docket indicated that the authority for what was referred to as the adjournment of the sentencing was a letter to the Court regarding the defendant's continuing cooperation with law enforcement.

The defendant has been under house arrest (Home Confinement) for five years. His new sentencing date is now set for March 22, 2021. Sone observers has questioned the wisdom of allowing Webb to avoid incarceration, in what appear to be luxurious surroundings in the United States, with his family, while many of his convicted FIFA co-defendants have been serving time for their crimes. They argue that his counsel could request the US Attorney to file a Rule 35(b) motion to reduce his sentence, which is generally how defendants cut their prison sentences.

Here though, Webb has enjoyed his freedom for five years after pleading guilty, and we have just not seen the level of cooperation thus far to justify such a favorable arrangement. Where are the major defendants who were charged due solely to Webb's Substantial Assistance ? let us not forget that Webb has evaded arrest and conviction in his native Cayman Islands, in yet another criminal case, in which his co-defendant drew seven years, due to these delays in his US case. Clearly, justice has not been served.



The Leroy King case, pending in US District Court in Texas has disturbed many of Antigua's politicians in recent weeks. Anxious media sources in Antigua were able to learn from the US Department of Justice that the sentencing of former financial services head Leroy King has been rescheduled for November 24, 2020. Rumors swirling around Antigua to the effect that King's sentencing was abruptly cancelled on July 30, after he decided to belatedly cooperate with law enforcement, and give evidence of criminal acts committed by senior members of prior and present governments have unsettled the country, resulting in multiple queries made in the United States about who might be named. Details of pending investigations are, or course, restricted, and no names have been leaked to the press.

The matter became even more mysterious after the July sentencing was apparently cancelled and rescheduled without a publicly accessible order being issued. If there is a sealed document or order resettingthe sentencing hearing, the press and the public do not have access to it; repeated searches of the docket for the case has failed to turn up any information. The last filing available was the April rescheduling of the hearing to July. This has reportedly been the source of political tension in Antigua, among a number of senior officials,who fear that they may be on a sealed indictment, which will only be unsealed upon their arrest.

King, who received hundreds of thousands of dollars for blocking American investigations into Stanford International Bank, which was revealed to be a massive billion dollar Ponzi scheme, with worthless certificates of deposit issued by the Antigua bank, is believed to have first-hand knowledge of bribes, kickbacks and other unlawful compensation paid out to prominent Antiguan politicians and government officials. The fact that his previously rescheduled sentencing was moved off several months, rather than thirty days, has raised  expectations that he is cooperating, and seeking a short sentence as a result.

Wednesday, August 26, 2020


This is ABDULSALAM KAJMAN, a Vice President of the Presidential Council of Libya. He has taken a number of unpublicized business jet visits to Malta this year, to meet privately with Maltese leaders, as well as with Turkish government officials who want a quiet nonpublic place to conduct their mutual business, which is Turkey's military and financial support for the Government of National Accord (GNA) in the Libyan Civil War. Turkey's program has the financial backing of the Government of Iran which, with Qatar, also backs the GNA. We have previously reported extensively on the Iran-Qatar-Turkey Axis supporting the Government of National Accord, which controls only a small portion of Western Libya, but is recognized by the United Nations.

 Kajman is believed to control substantial bank accounts in Malta, but whether they are on behalf of the GNA, or are his individual accounts, is not known;  There are Turkish banks with branches or subsidiaries in Malta. We are attaching his diplomatic passport courtesy Customs Malta/Malta Immigration.

Justice and Construction Party

Vice President Kajman is a member of Libya's JUSTICE AND CONSTRUCTION PARTY (JCP) which was founded in 2012 as the political party of the Libyan branch of the Muslim Brotherhood, a radical Islamist party banned in Egypt and declared a terrorist organization there. The United States is considering sanctioning the original organization, which is formally known as The Society of the Muslim Brothers.  The Palestinian terrorist organization Hamas also sprang from the Muslim Brotherhood. Turkey recently the Hamas senior leadership in Istanbul, which was strongly condemned by the United States, as some of those attending are not only sanctioned, but wanted for terrorist acts against Americans.

Muslim Brotherhood

A number of the members of the Justice and Construction Party were named, in 2017, by the Libyan House of Representatives, as terrorists with links to Qatar, a purported supporter of terrorism, which the party denied and considered defamatory. The JCP has also been linked to political assassinations and War crimes in Libya. It supports the imposition of Sharia Law in Libya.

Why Malta, in an era when proven terrorist financing can be fatal to a country's banking industry, not to mention poisoning its relationships with the US and the EU, has chosen to throw in its lot with a known international terrorist organization, the Muslim Brotherhood, and to provide material support, in coordination with nations who are State Supporters of Terrorism, is a mystery. The Members of the European Union have suffered greatly from terrorist acts, and Malta is clearly supporting a group that is known to have committed such Crimes against Humanity, as well as War Crimes. The consequences of this dangerous national policy may manifest themselves as OFAC violations or designations, FinCEN Advisories, or worse. Nobody in Valletta seems to be paying attention; perhaps
Iran is paying them too much money to feel real fear yet.

Tuesday, August 25, 2020


US District Judge Richard Berman (SDNY) has denied defendant HALKBANK's Motion for Recusal, holding that it is barred on the grounds of waiver and estoppel and that it has no substantive merit. The Court, you may recall, denied REZA ZARRAB's similar motion in a related case.

The 31-page Opinion and Order discussed the legal standards to establish a basis for recusal, and covered these points:

(A) Halkbank's experts have overstepped and their Declarations are excluded.
(B) the Twelve Comments challenged by Halkbank - individually or collectively - do not begin to overcome the Presumption of Impartiality and cannot support Recusal.

The Court noted that most of the 1000 page plus filing consisted of material in the Turkish language,but without any translation, and that this section was excluded.


Sergeant Reno Mifsud,  on Most Wanted list

 In the news from Malta today is the story about the arrest of Maltese national Nazzareno Mifsud,  who is also a US citizen. Sergeant Mifsud, formerly of Fort Sill, Oklahoma, and who has been AWOL from the United States Army for decades, happens to be on the US military's Most Wanted List, charged with Child Molestation and escape, since 1987, when he jumped bond and fled to Malta to avoid prosecution for this crimes. So why is the United States just now seeking his extradition after 33 years ? Could it possibly be related to the potential extradition of a number of present or former Maltese leaders, and others, to the United States, on money laundering and RICO (Racketeering) charges ?

A close look at Mifsud's extradition documents shows that they were issued back in 2017. Since we know that Malta's current treaty with the United States has permitted extradition since 2006, we can see no reason why the U.S. waited until now to enforce it, unless there is another agenda; to ascertain whether Malta's notoriously ineffective and politically influenced courts will indeed allow extradition in a timely manner.

Why is this so important, you ask ? because it could be a dress rehearsal for something much bigger, a major American Federal criminal indictment of those responsible for the movement of hundreds of millions of dollars of dirty money, much if it from Venezuela, through the notorious Pilatus Bank. Potential defendants include senior government officials, regulators, Politically Exposed Persons (PEPs), and the usual Maltese financial crime suspects.

So let's watch the Mifsud case carefully, to learn just how long it will take before the Sergeant is extradited, to face charges in Oklahoma. Then we will be able to determine when some of Malta's most guilty will be retaining American criminal defense attorneys, against the day when they also must face the proverbial "Knock of the Door," and start a long journey towards their ultimate destiny.


Monday, August 24, 2020


He's simply the most wanted fugitive in India, with a twenty five million dollar ($25m) price on his head, a designated terrorist and terrorist financier, mobster and drug trafficker, and he, yes he, DAWOOD IBRAHIM KASKAR, a career criminal almost from birth, has a Dominica Citizenship by Investment (CBI/CIP) passport. Of course, he's currently in hiding in Pakistan, according to media sources in South Asia, but should he make it to the Commonwealth of Dominica, he could certainly claim he was a victim of a political vendetta, and fight extradition, like MEHUL CHOKSI in nearby Antigua & Barbuda, for years and years. Ibrahim is classified as a terrorist by the United States, but he might cheat justice indefinitely, due to that valuable CBI passport. Who issued it to him ?

This is an open question to Mr. Anthony Astaphan, who professes to know all about the "great due diligence" performed upon CBI applicants in Dominica:  How on earth did this career criminal ever qualify for a CBI passport ? There's no way any compliance officer would have given him even a second look, UNLESS he or she was bribed, or some other illegal consideration was passed out to allow such a passport to be issued and validated. Thus man is a wanted terrorist; has Dominica simply lost its mind due to greed and avarice ?

After this, we believe that all holders of Dominica CBI passports must be reexamined, and enhanced due diligence performed upon each and every one of them, with revocation of all whose criminal records, or pending investigations, or ongoing fraud cases, disqualify them.



Michelle Roll, a bulk cash courier for a Colombian drug cartel, and who was arrested with over $220,000 in cash, all reortedly in one hundred dollar bills, was sentenced recently to Time Served, three years of Supervised Release, and 200 hours of Community Service. The charge was Conspiracy to Commit Money Laundering. Here's the problem: she bonded out after only a few days in jail, meaning that she will not serve one day in the Federal Prison System as an inmate. Is this a deterrent to others ? We seriously doubt it.

Her Guidelines Sentence was 37 to 46 months, according to court watchers who attended the sentencing. Obviously, since she was charged via an Information, and not indictment, she cooperated, but this was certainly not her first foray into crime, just the one in which she was caught. The defendant is a college graduate with a degree in psychology, who was reportedly working in food delivery.  Was this just a cover for her true occupation ?

The Court seemed more focused upon the Notice of Forfeiture against the cash seized from her; to set a hearing to adjudicate any right, title and interest she may have to it, and to request any other claimants to file against it.

When Federal Judges fail to incarcerate bulk cash smugglers that are caught in the act, more line up to take their place. Unfortunately, I do not have a photo of the defendant, for we will certainly see her again.


Multiple visits, to Malta, by the Turkish Foreign Minister and senior government officials from  Libya's Iran-backed Government of National Accord (GNA), continue to verify that Malta has thrown in its lot with Iran, and its front man, Turkey, in what appears to be an alliance backing a civil war that Malta has no business getting into. Somebody in Malta's government seems to have forgotten that there are not only international sanctions in place against Iran, but they affect anyone or nation that is working with Iran, and its allies, as it supports the GNA military machine with its wealth, goods and services.

These points need to be made to the public in Valletta:
(1)  Some banks operating in Malta are most likely moving funds for Iran, both indirectly and indirectly. It is not known how these banks are interacting with Malta's other commercial banks, but the risks that such contacts entail are serious. Do Malta's successful banks really want to risk OFAC designation, or being named & shamed as international sanctions violators ? The result would be insolvency, for any bank in Malta that was banned from the US Dollar financial structure would rapidly lose not only the ability of its clients to transact business with US companies, but bank customers would most likely flee the bank in droves, to find one that could deal with the US markets. Next question: what are Turkish-owned banks doing in Malta with EU banking licenses ?

(2) Turkish freighters, hauling cargo for Iran, especially to Libya, are often seen flying Maltese flags of convenience. What's going to happen if any are found to be transporting arms to the GNA, originating in Iran ? If Maltese ship registrations become high-profile items, what will that do to legitimate maltese maritime commerce on the high seas ? Will they be boarded on suspicion they are carrying Iranian weapons to Venezuela  or North Korea ?

(3) Maltese aviation charter companies, who are presently involved in the lucrative  air freight and passenger market into and out of Libya, are assisting and shielding Iranian actors, including GNA leaders, from prying eyes, not to mention quietly ferrying diplomats on secret missions in direct support of repeated Iranian diplomatic, political and military objectives.

(4) Malta is taking air freight shipments of unknown materiel from Qatar, another GNA supporter. Whether they are weapons of Iranian origin we cannot say, but this will certainly be a point to certainly be raised by the United States, in any sanctions designation upon Malta. What was in those shipments ?

Unless and until Malta distances itself from the Libyan Civil War, and the GNA supporters, it will slowly be pulled into Iran's orbit, to its detriment, as the only EU country supporting the world's most powerful State Sponsor of Terrorism. Maybe we will even see Yassir Arafat's widow, who still resides in Malta, as the country's next leader, or head of the Central Bank, as it slides into the Iran-Turkey-Qatar Axis.

Just another Malta "celebrity"

Sunday, August 23, 2020

Saturday, August 22, 2020


Details have emerged regarding the methods that Turkish government-owned Halkbank used to assist Iran in the illegal sale of billions of dollars of oil, as the District Court entered an order last month unsealing the court file in the suit against the bank, and making it available for review by the public. The order appears below.

To summarize the 77-page Complaint:

(1) The case is a civil suit, filed by 876 individuals, who are either direct victims of Middle East terrorism, or their surviving relatives and family members. The terrorist acts, which took place in Africa,  Lebanon, Israel and Iraq, were carried out with the material support and funding of Iran, the world's primary State Sponsor of Terrorism.

(2) The victims have acquired final judgments against the Islamic Republic of Iran in excess of ten billion dollars. These judgments were secured over the years by plaintiffs, in a number of civil suits brought in the United States. They have all been duly registered with the US District Court for the Southern District of New York (SDNY).

(3) To avoid paying the judgments, Iran has disguised its involvement in United States financial markets through complex arrangements with Halkbank, which has a number of Iranian customers and clients, fronting for the Government of Iran. Iran has been able to circumvent the US sanctions regime through Halkbank's actions, which are a fraud upon creditors, and the United States financial structure.

(4) Iran, with Halkbank's assistance fraudulently conveyed its assets to third parties, for its ultimate benefit. Halkbank benefitted financially from the covert arrangement allegedly receiving over $100m.

(5) The money fraudulently transferred by Halkbank was otherwise due to the plaintiffs. Iran and Halkbank used the Gold Export Scheme and the Fake Food Scheme to achieve the transfers.

The Claims for Relief against Halkbank,  some of which rely upon New York State creditor laws:

(A) Rescission and Turnover of Fraudulent Conveyances.
(B) Turnover. of sufficient funds to pay the judgments, from Iranian funds held by Halkbank.
(C  Turnover pursuant to the Terrorism Risk Insurance Act.
(D) Enjoin Halkbank from transferring any assets of Iran.
(E)  Punitive damages and attorneys fees and costs.



There is a sealed civil lawsuit pending in US District Court in Manhattan against government-owned Halkbank of Turkey. The fact that such a case exists was discovered by an alert SDNY court watcher, working for Inner City Press, who observed a request from plaintiffs' counsel for additional time to effectuate service of process upon the defendant, pursuant to the Hague Convention. The request was reportedly granted.

Apparently the plaintiffs are victims, and surviving family members, of individuals who were killed and injured in the US Embassy bombings, Beirut bombings, Jerusalem bombings, and two attacks on US military serving in Iraq. It is alleged that Halkbank works "arm in arm" with Iran, a State Sponsor of Terrorism. Iran provided material support to the terrorist organizations that committed the acts cited.

Halkbank acquired PAMUK BANK T.A.S. in 2004, a Turkish bank that had a large number of Iranian clients when it was absorbed into Halkbank. When more detailed information is available, we shall report it here on this blog.

Friday, August 21, 2020


Most Americans are under the impression that fraudulent financial activities have always been perpetrated by Wall Street heavyweights, such as Michael Milken, the "Junk Bond King," Ivan Boesky, and Bernard Madoff. Hard working American homeowners should know now that white-collar criminals at some of the country's biggest banks and mortgage companies have targeted the most vulnerable, so that they can make fast money easily, and escape any liabilities or penalties.

Illegal practices at Wells Fargo Mortgage, where the company actually took action against borrowers who made their monthly payments on time, only to learn later that the bank was using illegal tactics to increase its revenue, or foreclose upon homes, included fraud and unconscionable acts. One of the unspeakable acts was Wells Fargo claiming that the borrowers had requested that payments be "paused" (called Forbearance) under the authority of the CARES ACT, due to COVID-19, when they had not taken any such action, and which threatened court-approved repayment plans of borrowers.

Typically, a bank that is engaging in this type of fraudulent activity to maximize profit must first create some kind of illusion, such as that your monthly payments are not being received or posted. Then the borrower receives a notice that his or her mortgage is in default. In truth and in fact, the bank has cashed out your monthly payments, and posted your money in a different, and hidden, account.

At that point, the bank has your money, which you believe has been applied to your mortgage account for years; unfortunately, your account is about to unravel. It is about to be sold, assigned or transferred to a third-party debt collector, a financial alligator, in this case Fay Servicing LLC, which will by any lawful means seek to collect the balance and foreclose on your lifetime investment, your home.

The King Alligator, who is the creator and founder of Fay Servicing is Ed Fay. He is supported by the company's COO,  Andy Liang, by President Kimberly Bingham, and Vice President Ryan Finnigan. You will find the company has fielded an impressive social media presence online, which seeks to convey a friendly corporate image that is not supported by the truth; Barracudas swim in these waters. Fay Servicing is responsible for making more Americans homeless than than any California wildfire, according to first-hand statements from its victims, some of whom are elderly grandmothers.

The company attempts to convince online viewers of its benevolent corporate culture:
 " Founded in early 2008 to address challenges created by the growing housing crisis, our company is committed to providing innovative servicing solutions for both performing and non-performing mortgages. Until recently, the existing traditional mortgage servicers were adequately able to handle the mortgages under their care. The functioning premise of their servicing models was a high volume, low delinquency approach. However in the last two years, due to many factors, residential mortgages have been experiencing unprecedented levels of delinquency. As a direct result, many servicers quickly found themselves overwhelmed and unable to effective manage the resulting complications."

"We conducted an exhaustive analysis of the existing mortgage servicing industry and gained valuable insight into the shortcomings of current mortgage servicers. Realizing that even adapting an existing approach was wrought with immense challenges including legacy portfolio issues and unproductive corporate cultures, we decided to build a new model from the ground up, the focus of which would be to benefit both the homeowners and the lenders."

In reality, Fay Servicing, knowing very well that the targeted homeowners of their scam are on financial life support, thanks to its attorneys and law firms, which finish the job by quickly foreclosing upon their homes, while the borrowers are lying critically ill in hospital beds. See  Deceptive Mortgage Servicing Company Fay Servicing Exploits and Cheats Borrowers. See also Meet Fay Servicing's Foreclosure Pit Bull in California.

MFI-Miami, the mortgage fraud investigation firm, has issued a pointed warning on Fay Servicing:
"Homeowners need to request their complete mortgage transaction histories from Fay Servicing and review them. If there is missing information or something doesn't look right, they need to contact a lawyer or properly trained mortgage expert immediately... There is a definite pattern of impropriety going on here."

As widely reported, the Consumer Financial Protection Board has fined Fay Servicing $1.15m for its illegal boiler room foreclosure operation, and a number of state Attorney Generals have initiated investigations against Fay for bringing unlawful foreclosures upon senior citizens during COVID-19. While Americans fear threats from abroad, the real threat is much closer to home. Outlaw mortgage servicers like Fay Servicing are more like Ali Baba and his Forty Thieves than a mortgage company. Govern yourselves accordingly, America.



The Government of Grenada, under fire after a CBI developer who was allowed to accumulate  investment capital outside the country, and allegedly stole EC$ 52.4m, without building out the project, has changed its regulations requiring that such funds be held in local commercial banks within Grenada. Additionally, the CBI unit will determine how many passport applications are needed to constrict a project, and will thereafter limit the number that a developer may sell, and when he must complete construction, before seeking additional applications for a new phase.

While not specifically named by the officials, the failed project referred to is the Grenada Sustainable Aquaculture (GSA) Project, which was owned and operated by the Iraqi national, SOREN DAWODY. Dawody is presently believed to have fled with the estimated USD$20m, and is known to be living a luxurious lifestyle in Dubai, United Arab Emirates (UAE) with the money, and his extended family. Investors in the GSA project have blamed the government of Prime Minister Keith Mitchell, who allowed the developer, who had no prior experience in aquaculture, to direct that their funds sent to the UAE and Singapore.

If Dawody will ever be subject to criminal charges in Grenada remains an open question. Grenada has avoided the issue for the past two years, leaving investors wondering aloud whether bribes or kickbacks were paid to allow Dawody to divert all the investment money abroad, and whether he obtained approval for his project without any relevant experience or education through corruption.


The arrest of Malta's former Consul General for Shanghai, Aldo Cutajar, and his wife, Isabel, on money laundering charges this week looked like yet another play by the beleaguered country's leaders to show financial crime arrests, ahead of a probable MONEYVAL adverse October action, but it was much more than that. Cutajar, the brother of Civil Service leader Mario Cutajar, is this week's Malta poster boy for corruption; police found €500,000 in cash in his home and records of an additional €400,000 existing in a Dubai, UAE bank account.

Many observers believe that, in truth and in fact, the money came from bribes paid to Cutajar from consultants participating in Malta's lucrative Individual Investor Programme (IIP), the country's Citizenship by Investment scheme. The sordid, back street nature of the relationship between large CBI consultants and local government officials in Malta, replete with the payment of large bribes & kickbacks, has poisoned the public's view of the entire CBI process, and frankly I do not blame them one bit. Malta's reputation for seedy corruption was bad enough, but the IIP drove it over the edge, making Malta the center of attention in the EU, and not for the right things.

Let me humbly suggest that the time has come for Malta's senior officials to exhibit some real leadership, and follow the European Union recommendation to cancel the IIP altogether. While greedy politicians anxious for those bribes and perks may oppose such a move, true reform on a national level will not occur so long as they are mesmerized by the lure of easy money, paid silently under the table. Cancel the bloody program, Malta, to show the EU that you are serious about cleaning up your mess. CBI programs should exist only in those countries that can cleanly administer them, for the benefit of the applicants, not for dirty politicians' pockets.

Thursday, August 20, 2020


In an article appearing in The American Lawyer,  the two defense attorneys for the Iranian sanctions evader ALI SADR HASHEMINEJAD state that the reason his case was dismissed, after a guilty verdict was handed down at trial, was solely because the US Attorney's Office improperly withheld exculpatory evidence available prior to trial. In an effort to show all sides of the issue, we are publishing the interview below, in its entirety.

We do, however, believe that there are other reasons why the Government chose to dismiss the case, and that they should be fully investigated. Were the Discovery "errors" actually intentional, and if so, who ordered that the case be deliberately sabotaged ? Given the extraordinary number of strange dismissals linked to partisan political goals we have seen in 2020, these questions deserve answers.

Please read the article and make your own decision.

Wednesday, August 19, 2020


A recent report, made public by Malta's Financial Intelligence Analysis Unit (FAIU), which disclosed that there have been a number of cases where Maltese financial and credit institutions were used to facilitate the funding of terrorist organizations, is disturbing, given the recent movement, by Malta's senior government officials, toward a close relationship with Turkey. We have previously covered, in depth,the widespread use of Malta, by Turkey, to fund the GNA faction in the present civil war in Libya.

The FIAU has noted, in a risk assessment said to use data obtained from its records, that Malta's banks and non-bank financial institutions (NBFI) are considered vulnerable to terrorist financing, based upon the evidence of previous abuse by individuals either linked to terrorist organizations, to radical Islamic movements, or to charities that are suspected as fronts for terrorist financing and funding, according to a report discussed with local media. Hamas, the Palestinian islamic Jihad, and Hezbollah, are all believed to have supporters among Malta's Palestinian expat population but Hamas is in a unique situation that favors it.

Given that Turkey openly provides a safe refuge for Hamas terrorists seeking to attack Israel, has even given twelve of those terrorists Turkish citizenship and passports, and Hamas is engaged in a constant fundraising program, targeting Palestinians living outside the Territories, it is reasonable to expect that local Palestinians in Malta have been providing financial support to Hamas, through funding, and the provision of goods and services, and sending the cash to Istanbul, where it can be delivered to Hamas' leadership. We wonder how many of those bulk cash seizures at MIA were have reported upon were Euros destined for Hamas.

 Palestinian terrorists know that Malta has a long history of sympathy for, and providing official government support to, Palestinian aspirations, including territorial designs upon Israel, and are most certainly engaged in fundraising. Any material and financial support given by expats located in Malta will allow Hamas to conduct violent operations in Israel, and abroad, and in any event qualifies as terrorist financing.

If the police in Malta, as the FIAU information states, know who the terrorist financiers are, why haven't they been arrested yet ? It is because Malta's leaders know that would alienate a sizable portion of the voting population, and perhaps drive them from office. Again, partisan politics trumps justice in Malta.