Wednesday, September 30, 2020



The US military's appearance on the airfield in Malta this week, especially some unexplained aspects, reminds me of an earlier American operation launched abroad to bring justice to a corrupt national leader. 

Remember Operation Just Cause ? Between December 1989 and late January 1990, it was the United States invasion of the Republic of Panama, for the purpose of arresting General Manuel Noriega, who had become involved in drug trafficking, and become the military dictator of Panama. Noriega had thought he was safe from the long arm of American justice, so long as he remained in his native country. it cost him nearly 20 years in an American prison.


                                                     US Marshals bring back Noriega for trial    

Assuming that there will be a change of President in January 2021, no criminal accused of being connected to Russian oligarchs or shadow figures facilitating financial assistance to persons connected to organized crime and terrorist networks around the world will be immune from American prosecution. Joseph Muscat's dream of being granted immunity for his money laundering crimes by the US Department of Defense will never come true.

Nevertheless, the rumors, fanned by a news blackout of the SOFA talks with the Prime Minister,  and the failure of the Opposition to be read into the proceedings by PM Abela, popular suspicion of a backroom deal have emerged. 

Observers in Malta point to the public opponents of SOFA on Constitutional and historic Neutrality grounds, led by the Foreign Minister and Deputy PM, on one side, and Abela and Muscat as his advisor on the other side, taking the US side. The Abela faction is steamrolling over everyone to sign off on the deal, as RA and JM get immunity, while others n the PL are indicted. No public acknowledgement of the arrangement is ever made to Parliament, according to those who are advancing this interpretation of events. They cite the unusual and unexpected emergence of SOFA as an issue as further evidence of some dark deal.

All that I can say about this theory is that the Department of Defense and the Department of Justice work separately, and barring some major issue of National Defense, where JM  makes an extraordinary contribution,  I cannot see it. But what if I am not aware of all the facts ? 

Therefore, I will keep an open mind, and see what the future brings.





A Statement by criminal investigators from the Principality of Andorra has confirmed that this tiny country is also engaged in an active investigation of the reported money laundering operations involving former Malta Prime Minister Joseph Muscat and other present or former members of the Government of Malta. Agencies of the Andorran criminal justice system have issued a warning, regarding the massive Banca Privada d'Andorra (BPA) scandal, that they are conducting an active investigation of alleged money laundering, targeting individuals from the Republic of Malta, and that they will not shelve or discontinue their investigations, due to the existence of parallel investigations in other jurisdictions.

BPA has had a long and dark history of facilitating money laundering. Compliance officers may recall that, on March 10, 2015, the Financial Crimes Enforcement Network (FinCEN) published a Notice of Finding, declaring the €7bn Banca Privada d'Andorra to be A Foreign Financial Institution of Primary Concern. The agency disclosed that "The activity involved the proceeds of organized criminals in Russia and China, foreign corruption, and other criminal activity." In 2018, a judge in Andorra charged 28 individuals, including two former Venezuelan Deputy Ministers, with corruption, in connection with the BPA scandal.


Andorra, while being literally in the heart of Europe, is not a Member of the European Union, but is a favorite destination for illicit funds. It is one of those very few non-EU jurisdictions that have adopted the Euro as its official currency, with EU approval, an act which is often cited as a factor in attracting money launderers seeking to clean criminal proceeds acquired inside the Eurozone.



Andorran investigators have asserted that they possess more than sufficient evidence to sustain convictions for money laundering, and other associated crimes, as they have identified the funds as having come from unlawful sources. Andorra joins four other jurisdictions, three in the EU, that have pending investigations in the case known as MaltaGate. Former Malta PM Joseph Muscat is known to be the primary target of at least three of them.

Tuesday, September 29, 2020




A Chinese national XUEYONG WU a/k/a "Antonio" who pled guilty to money laundering in US District Court in the Eastern District of Virginia, was sentenced to five years, and ordered to forfeit $4.2m. Wu moved drug profits earned in the US to Mexico's cartels, through what was described as a series of complex financial transactions. Compliance officers in the Northern Virginia, District of Colombia, Maryland area may want to check their client records to see whether Wu held accounts there.




  Notwithstanding the fact that we cannot ascertain how there is any truth to the story, many in Malta continue to believe that their country's Prime Minister, Robert Abela, is about to make an agreement  that would allow US military forces access to Malta, in exchange for an American promise not to prosecute former Prime Minister Joseph Muscat in the US on money laundering, terrorist financing and corruption charges. Now that the American Secretary of State has arrived, the chatter has increased exponentially about the subject.

Nothing could be further from the truth; Any such agreement, even if its could be consummated, would involve the Departments of Justice and of State, neither of whom would most likely entertain immunity from prosecution for an individual known to be not only a paragon of corruption, but a supporter of the principal Iran sanctions evasion scheme, which is a global crime that the United States will not ignore.


Moreover, Prime Minister Abela has failed to publicly deny that such a scheme is even under consideration by his office, which is an abject leadership failure, just when Malta wants assurance that their country's principal bad actor will finally face justice. To complicate things, the fact that Abela is believed to have been implicated in much of Muscat's criminality, by virtue of his prior service as "legal advisor," and often being present in conferences where group decisions that involved corrupt activities were made. Abela, who was Muscat's backoffice choice to succeed him, is said to be following his predecessor's directives to the letter.

Abela's silence is clearly disturbing his supporters, and leaving important questions unanswered. Who is getting immunity, and for what ?


You've got to hand it to the Iranian businessman, Ali Sadr Hasheminejad, given a reprieve from a long  prison term of money laundering, when the US Attorney chose to request dismissal, for Brady violations. Now that he is neither in prison, nor facing deportation, he has gone on a public relations offensive. His objective: to recast himself publicly as a victim of a false prosecution, actually exonorated by his dismissal, which did nothing of the sort. He simply got a pass ; he was not cleared of his many crimes.

His attorneys, who obviously have signed on to this characterization of their client as a victim, wasted no time publicly airing his "exonoration' status, by giving statements to the press, making him out to be some sort of victim.  While we do not know whether the dismissal was genuinely for major Discovery violations, a secret deal with the Government, or a bit of both, we do know we was convicted by a jury, meaning found guilty to the exclusion of any reasonable doubt.


                                                                  Are you kidding me ??

 What really bothers me is this claim of exhonoration. He actually had the temerity to allow himself to be placed in the "National Registry of Exonorations," a University of Michigan Law School project that lists individuals cleared through DNA evidence.  The site even asks "Did DNA evidence contribute to the exonoration ?" of course, for Sadr the answer is a resounding No. Readers who want to see this legal obscenity may access it here.

There are other websites, all obviously created to give the reader the illusion that Ali Sadr was wrongly accused, and later freed, and exonorated from any guilt. The only saving grace here is that it is extremely difficult, verging on impossible, to permanently seal a District Court file, so all the pleadings of the US Attorney's Office detailing his guilt will remain available to any intrepid researcher with PACER access. Our blog articles, we hope, will also endure, so a young compliance officer in 2025 will properly act as a gatekeeper, and block the door of his bank to this financial criminal.


Monday, September 28, 2020




Malta's most important unanswered question for 2020: For reasons that cannot be explained, person or persons within the Malta Police Force and/or the Ministry for Home Affairs, National Security and Law Enforcement have consistently declined to follow up on repeated offers from a foreign state (not the United States), to accept and review existing electronic surveillance, connecting former and current high-ranking Malta government officials in the violent death of Daphne Caruana Galizia.

 It is fair to ask why, and who, are the security forces protecting. Professional journalists, and the people residing in the Republic of Malta must join together, and pressure the Government of Malta to provide honest and coherent answers. To do anything less is unacceptable.


                                                          Sadr                                Schembri


If you were wondering, after having read our recent article, Why are People in Malta placing favorable information about Sadr and Pilatus Bank Online ? which detailed a totally false narrative, designed to "rehabilitate" Sadr and Pilatus Bank for anyone searching for information, it gets worse. 

GPS searches of the aliases who posted favorable information about Sadr on Wikipedia come back to real estate owned or controlled, in Los Angeles, West Hollywood and Malibu, California and Bethesda Maryland, by Sadr himself, and members of his associates & family, including his sister, Pegah Sadr, and Shokouh Azad.  They clearly altered the truth.

We sincerely hope that readers of Wikipedia understand that the entry, as creatively composed by an individual with a history of money laundering, is substantially less than truthful, and they must ignore it for all purposes, including compliance and risk assessment.




 Information received from our sources has confirmed that the "Valletta Three," individuals in the present Malta government, have, in their testimony to US law enforcement, implicated Robert Abela, who served as Legal Advisor to resigned Prime Minister Joseph Muscat January 2020. Mr. Abela also happens to be the current Prime Minister of Malta, and is said to be little more than a figurehead, obeying each and every order given to him by Muscat, who is reportedly governing from the shadows.

Additionally, according to a source with first-hand knowledge of the investigation, Abela has either been directed, by US investigators, or will be directed shortly, that he must immediately take the following steps, to avoid indictment:

(1) Grant Maria Efimova, the former Pilatus Bank staff member, Whistleblower status, so that she may travel to Malta to give sworn, and public, testimony, regarding Pilatus and Muscat's role in a number of money laundering operations. It is assumed that her testimony will be properly preserved for evidentiary purposes for admission in future American proceedings.

(2) Cancel Efimova's Malta arrest warrant forthwith. Legal scholars have noted that this warrant represents the first time that an EU Member State (Greece) refused to honor an arrest warrant of a sister State.

(3) Take steps to insure her personal safety while in Malta, employing such security as will guarantee her physical and mental well-being during her visit, including the employment of a detail that replaces police protection, given her previous experience with corrupt local law enforcement, who previously acted under improper political influence. 

While many in Malta may doubt that Abela will willingly agree to these actions, his alternative, to be named as a co-conspirator with others already implicated, may leave him no choice to avoid indictment and trial in a US courtroom. Previous American cases, brought against sitting foreign national leaders, such as Panama's General Noriega (20 years), and Turks & Caicos Prime Minister (8 year) leave no doubt that Abela is exposed to prosecution in the US, for acts committed prior to his appointment.

This is a classic Hobson's Choice, meaning no choice at all. If Abela wishes to avoid being dragged headfirst into the Pilatus Bank money laundering case, he must comply. My the way, for those who will claim that Abela's "legal advice" is protected under attorney-client privilege, the Crime or Fraud exception applies. Lawyers involved in criminal activity with their clients cannot claim privilege to save themselves.


Sunday, September 27, 2020



According to a well-placed source in the United Kingdom, the Toronto-based journalist Melanious Alfonse, who most observers of the Caribbean scene consider to be a paid asset and propagandist for a number of CBI consultancies, has set up an organized attack, employing untruths and baseless charges, against the sitting Prime Minister of St. Lucia, Allen Chastanet. Alfonse operates what purports to be a Caribbean news website, but much of the content is skewed in favor of his sponsors, and is often misleading regarding the benefits of Citizenship by Investment (CBI) passport sales programs operated in the East Caribbean States, by touting the jurisdictions that offer them, often with a rosy picture that is often unrealistic.

Alphonse's actions against the St. Lucia PM, which is being run jointly with the St. Lucia Labour Party, involves the publication of what most objective observers would classify as bogus content, or fake news. 

It has also been reported that Alfonse is also linked to questionable fundraising efforts from dodgy financial criminals holding Caribbean CBI passports, and located in the United Arab Emirates, and Eastern European states, on behalf of the St. Lucia Labour Party. We are seeking to obtain more information on this subject, and shall report back to our readers with further details.



   I have been inundated with readers who have heard a rumor to the effect that the disgraced ex-PM Joseph Muscat is being granted immunity from American prosecution for his alleged money laundering and other financial crimes. The story is going around is that the US Secretary of Defense, currently negotiating a Status of Forces (SOF) agreement to allow the US Navy to be based at Malta's maritime facilities, which were formerly a base of British naval operations during the colonial period and that Sec. Esper will give Muscat immunity exchange for a long-term agreement.

Nothing could be further from the truth; The Department of Defense, as  a matter of policy, does not have the legal power to immunize any targets of the US Department of Justice. My sources within US Government in law enforcement absolutely deny that any such arrangement has even been proposed, let alone be approved and implemented.  They go on to say that such a pipe dream is not only untrue, it is unthinkable. Furthermore, there is no information regarding such efforts being made by the present Prime Minister, and he would be wise to issue a public denial forthwith, lest he get drawn into this fiction.There is no factual basis for this rumor.

The US investigation into money laundering, corruption and Providing Material Support to a Designated Terrorist Organization continues to its conclusion.

Saturday, September 26, 2020


If you read our previous article, Ali Sadr engages in "Truth Control"about himself and Money Laundering Pilatus Bank, you know that the Wikipedia entries for both the Iranian money launderer, Ali Sadr Hasheminejad, and the bank he owns, Pilatus Bank, take major liberties with the truth, and seek to portray Sadr as some sort of innocent businessman who triumphed over bogus criminal charges. It is all about what is referred to as Reputation Management, or how to put your best face forward, while you lie through your teeth to your readers.

We assume that you were sufficiently angered by the sugarcoated articles, which intentionally manipulate the reader while playing fast and loose with the truth, to look closely as who in Malta is being paid to perpetrate this charade. Yes, we believe that they are being compensated for their participation in a PR campaign to restore Sadr's and the defunct bank's images."


        The article BEFORE it was altered to include deceiving but favorable information.


Contributors" (a/k/a trolls) to Wikipedia generally employ aliases, lest alert readers access their identities on the site, and hold them to account for their lies and sins of omission. One very sharp reader forgot one time only, to anonymize his edits and postings, and his name is CHRIS PORTELLI. His identity was confirmed through his long listings of contribution to Wikipedia pages. So who is paying him, some government official in Turkey or Iran, a sheikh in Qatar, or Sadr himself, looking to clean up his tarnished images so he can operate again on the global arena, showing positive media coverage, and claiming that his New York case was purely political. How many times this guy, using an alias, altered the truth we cannot say, but we know he edited many, many football pages and sites, so it is presumed that he has manipulated many a Wikipedia page for his masters. 

               The article AFTER it was altered to enter favorable information.

 We are taking particular offense to the addition of a sentence to the Pilatus Bank website, stating that a magistrate had found no money laundering or misconduct at Pilatus. Obviously it is intended to mislead a casual reader into believing that the bank was no guilty of money laundering. Look at how the edits were dropped in, giving the reader the impression that Pilatus was innocent.

The people of Malta should take personal offense to the fact that Mr. Portelli edited Daphne's Wikipedia  biography page, which was most certainly done without her family's or her attorney's permission. Her bio should be locked, unless new information of note surfaces, that will result in justice for Daphne.

Given that Sadr's money laundering through his Pilatus Bank, from Venezuela, and ultimately into Iranian hands, violated several local laws in Malta, these trolls frankly belong behind bars.  Who will put them there ?


  " Who controls the Past controls the Future; Who controls the Present controls the Past" George Orwell, 1984.

 Someone is trying very hard to change the truth about the Iranian sanctions evader and money launderer, Ali Sadr Hasheminejad, and Malta's Pilatus Bank, his personal full-time money laundering operation which flourished, to the damage and detriment of both the European Union and the United States, for several years due to rampant corruption inside Malta's government.

 Although we know that a jury convicted Sadr of multiple Federal felonies, the trial judge later dismissed all charges, after the US Attorney's Office in Manhattan confessed to what it alleges were repeated, though unintentional, errors that violated Brady vs. Maryland, his Wikipedia page boldly but inaccurately states:

"Ali Sadr Hasheminejad, also known as Ali Sadr, is an American-educated businessman and entrepreneur. In 2018, he fought federal(sic) charges brought against him for violating US sanctions against Iran in connection to(sic) a construction project of low-income housing in Venezuela in 2010. After a two year long legal battle, Sadr was exonerated and all charges against him were 'dismissed with prejudice" due to prosecutorial misconduct. Wikipedia.

Is there anything completely true in this Wikipedia entry ?  Let us analyze it:

(1) Sadr is an Iranian national  who is a lawful permanent resident, a status acquired through a prior marriage to an Iranian-American lawyer. He is NOT a citizen, though the article tries to humanize him by indicating that he is American-educated. How is that relevant here, except to mislead the reader ?

(2) Sadr was convicted, yet the article plays fast and loose with the truth, making him out to be someone innocent, but charged with crimes, who ultimately prevailed in court, due to misconduct. His guilt is cleverly sidestepped.

 (3) That "low-income housing" was classic money laundering tradecraft. It allowed criminal elements to divert millions from Venezuela into the hands of sanctioned Iran, through Switzerland, using Sadr's St Kitts CBI passport to cast him as a non-Iranian. This was no humanitarian venture, to be sure.

(4) I would venture that whoever wrote this paragraph was not a native English speaker, and not an attorney. Look at the failure to capitalize "Federal" and the grammatical and syntax errors in the text.

Now let's move on to the Wikipedia page of Pilatus Bank:

Give me a break, Sadr; an obviously corrupt magistrate judge in Malta "determined' that Assassinated whistleblower Daphne Caruana Galizia's claims of money laundering were untrue. this is also an exercise in what we can only refer to as Truth Control, a poor effort at disinformation and misinformation, intended to mislead the casual Internet user. What I fear is that in the future a young compliance officer, or  businessman in a hurry, will rely upon the Wikipedia page in dealing with Sadr, after a quick due diligence check, and end up a crime victim, or charged with sanctions violations or worse, a co-conspirator, in a criminal case.  

 Perhaps it might be wise for someone to publish to the Internet sufficient documents from the case, complete with meta tags, to insure that any search of the Web turns up the truth, and not someone's misleading version of the facts, cleverly designed to cast Sadr as a victim of a wrongful prosecution, and not a convicted money launderer, whose verdict was set aside on purely procedural grounds, and not because he was innocent. had his convicted stood, he would have served many years in Federal Prison, and  then deported to his native Iran.   



Friday, September 25, 2020




Apparently, it has been impossible for law enforcement in the EU to prevent all leaks to media, as there have been a couple of very telling comments which have just been contributed by additional sources. We have, hopefully, cleverly concealed any identifiers which will provide clues as to who made these statements. Even with the identities redacted, it is important information.

First of all, a number of Heads of State and Parliamentarians (think MEP) in the EU, who admit that they may have previously been a bit naïve in their dealings with Malta's disgraced former leader, Joseph Muscat, during his tenure as Prime Minister, and while he was reportedly engaged with global criminal organizations, have now stepped forward, and are cooperating with criminal investigators.

Second, As least two former elected EU officials have provided financial records to European law enforcement agencies, which tie Joseph Muscat to money laundering operations involving a number of Eastern Europeans, Iranians, and dodgy individuals who generally do their illicit business in the shadows.

Now that our new sources are apparently not afraid to come forward, in the aftermath of the Schembri and associates arrests and the omnibus asset freeze order, we anticipate that there will be more information forthcoming, albeit through unofficial channels. 

We trust that, after Malta's Home Affairs Minister, Byron Camilleri, declined to comment on our report of the presence in Malta of a number of Special Agents of the Federal Bureau of Investigation, as a part of a special money laundering investigation, due to policy that prohibits admission or denial of the existence of an active investigation, this matter has been put to rest. That fact has since been further corroborated by your blogger's associates by the witness statement of an American expat living in Malta, whose prior work experience more than qualifies him to identify US law enforcement agents engaged in field operations.

Thursday, September 24, 2020


 Our information on the progress of Italy's investigation of the Malta money launderers indicates that it is moving faster than those being conducted in two other EU Member States. Our sources have advised that international arrest warrants will be issued against the principal targets, to aid in their apprehension and extradition from abroad. Whether there are any sealed indictments in Italy we cannot say.

One additional, and very important, piece of information, is that at least two of the suspects are "Present or former Heads of State in the Caribbean." We know that the investigation touches specifically upon senior officials from both the Commonwealth of Dominica, and Grenada, and our best educated guess is that one or more of the suspects named are from those two East Caribbean States, both of whom offer CBI products. Remember that the CEO of Malta's rogue money laundering Pilatus Bank had a Dominica CBI passport. Alternatively, it is possible, given that Ali Sadr himself acquired and regularly employed a CBI passport from the Federation of St Kitts & Nevis while moving money in Europe, that one of the leaders could be from St. Kitts. Leaders from St Lucia and Antigua appear to be a lesser possibility, but should not be totally discarded.   


We regret that there is no information regarding the other suspects; it is likely that they are Italians and Maltese nationals or residents. It will indeed be likely that some of the targets may find themselves wanted in more than one jurisdiction, and after serving sentences in one country, they may find themselves extradited to another to serve time there. General Noriega served time in three countries for his crimes, and justice requires no less, given the levels of corruption and money laundering that we have seen in Malta.







The Unita di Informazione Finanziaria per l'Italia Italy's Financial Intelligence Unit (FIU) has opened a criminal probe into the activities of the disgraced former Prime Minister of Malta, JOSEPH MUSCAT, and his Maltese criminal associates, involving financial transactions that they have conducted inside Italy. Investigative reporters in Malta have long suspected that Muscat has had a close relationship with elements of traditional Italian organized crime, commonly known as the Mafia, in Sicily.

Muscat's longtime Chief of Staff, KEITH SCHEMBRI, was recently arrested on suspicion of money laundering and corruption. While he had not yet been charged with a crime, it is believed that such charges are imminent. Other individuals were also arrested at that time, and hundreds of companies and other entities were named in a freeze order designed to seize criminal proceeds  held by those businesses. Schembri is known to have traveled to Milan a couple of days before his arrest in Malta.

We do not ordinarily disclose the identity of law enforcement and regulatory that agencies involved in pending investigations, but in this case, we have been permitted to name the specific agency involved by our sources. We hope that additional information will be released shortly. 



Wednesday, September 23, 2020



 A quick look at the docket in the Matthias Krull case has yielded some additional clues which may help fill in the blanks regarding the pending Malta money laundering investigation. Yes, I know we just discussed the very recent court order freeing him from restrictions, and giving him an unusual additional six months to surrender, but this material came in since that order was entered.

Right after Mr. Krull was given a reprieve from entering prison, to commence his sentence, an unopposed motion To travel was granted. At the same time, a sealed document was filed with the Court; that is the fifth such filing in his case, which is generally a good indication he is cooperating against one or more targets. Remember, Krull has a ten (10) year sentence to serve; at all costs, he needs the Government to file a Rule 35 motion to reduce his sentence, so he simply must testify, whether before the Grand Jury, or at trial, to get his sentence lowered.

All the indicators point to Krull, whose laundering of millions of PDVSA Venezuelan capital 'diverted" to  Malta and elsewhere, and into his clients' control, being a principal witness against the Malta defendants. We shall continue to monitor all developments as they occur.



 Either Ali Sadr Hasheminejad had his case dismissed due to an excessive number of egregious Brady violations, for which the District Judge wants the guilty parties' heads, OR an extremely favorable covert deal with senior SDNY prosecutors, including one who handles terrorism cases, has been struck, and the "controversy" is just a cover, OR perhaps a little of both. Take your pick, for the puzzle has not yet been solved.

It just gets curiouser and curiouser; here is the latest piece of the puzzle. If the SDNY is so manipulative and sneaky (which I doubt) about Brady tricks, why does it land on this particular case, which is perhaps the most important Iran oil-for-gold sanctions evasion case filed ? Is the judge being overbearing here, or is there more than meets the eye ? Are there National Security Issues here that we are not cleared to know about ?

 Weeks after we first looked askance at the US Attorney's resolution of the case, we are still clueless, but the quest for truth goes on; Perhaps when we see the next major indictment in the Southern District, and you find Sadr's fingerprints on it, we might get a hint about what he really did contribute.

Stay tuned.


Malta's regulator of its Citizenship by Investment (CBI) passport sales program, known as the Individual Investor Programme Agency, has suspended the license of BT INTERNATIONAL LIMITED, d/b/a NEXIA BT until further notice. BT purchased Panamanian shell companies for Maltese PEPs, and was exposed in the "Panama Papers."  The company's partners, BRIAN TONNA and KARL CINI, were taken into custody in Malta in the KEITH SCHEMBRI money laundering investigation, and there is no indication that they have bonded out, or been released. Under local law, they must be charged with a crime within 48 hours or released.

Here is a screenshot of the Notice.




Apparently the three arrests which occurred in Malta this week have had an effect; according to a reliable source, an additional Maltese resident has approached American investigators, offering to cooperate, in exchange for favorable treatment from the US Department of Justice in the cases now known collectively as MaltaGate. His or her nationality is not known.

We imagine that many individuals in Malta who have been involved in dodgy financial transactions that could be found to constitute Conspiracy to Commit Money Laundering under the American criminal code became short of breath upon learning that Keith Schembri, the former Chief of State to ex-Prime Minister Joseph Muscat, was taken into custody, and subject to formal interrogation. They believe that they are also potential targets, irrespective of the level of their participation, and rightly fear extradition to an American courtroom where they could receive a sentence of decades of imprisonment. Those stakes would give anyone pause, especially targets whose attorneys have been candid about their chances of obtaining an acquittal, given the facts and evidence.

Given that attorneys for the earliest cooperators generally obtain the most favorable outcome for their clients in a complex criminal case, we can expect the list to grow, especially since sources have confirmed that local proceedings will not deter the ultimate filing of charges by the United States. 






Tuesday, September 22, 2020



 The public shock over the local arrest of Keith Schembri, the former Chief of Staff in the Office of the Prime Minister, will have absolutely no effect upon the progress of the unfolding multiple American law enforcement investigations into money laundering, terrorist financing, corruption, and the Citizenship by Investment (CBI) program, in the Republic of Malta, according to a senior source who has consistently and reliably provided details of the investigations, which have accelerated during the past thirty days. While he states that the arrests may serve as a distraction, or a bone thrown to MONEYVAL, they will not deter the American cases in any manner.

Given that ex-COF Shembri, said to be until very recently the most powerful man in Malta, even eclipsing the former Prime Minister, Joseph Musca, was released on bond, and not charged, after local law enforcement has had four and one-half years to collect evidence of his obvious guilt, means that Malta's justice system still cannot be trusted to follow the Rule of Law, and avoid its heritage of abject corruption, according to a different American source. The source explained that, while any Maltese politician convicted and actually serving a prison sentence might escape extradition, that there will remain a large number of suspects who will still face justice inside American courtrooms in New York or Miami. This also does not effect any proceedings that may be brought in EU criminal courts, where at least three investigations are known to be active.

The Schembri arrest and, two related arrests, which are believed to have resulted from the effects of the placement of serious pressure upon Malta's Police, will have no effect upon the US cases. Given that Malta's criminal justice system  has a reputation for a total lack of the application of swift justice, or any justice at all, for that matter, your blogger does not expect that Keith Schembri will be charged with criminal activity, or if he is eventually charged, that he will ever serve one day in prison in Malta for his crimes. He can well afford to buy his way out of trouble. Malta's criminal justice system is broken, and cannot be easily repaired, give the undue influence of the political party currently in power,  their illicit wealth, and their unknown, but very powerful, foreign benefactors.



The posture of the US investigations remains unchanged, and any thoughts by the public that a couple of arrests by local authorities have had the effect of supplanting them is not realistic. The show will go on; the only question is when, MP Muscat and Labour Party associates, in case you are asking.




 The news about Schembri's arrest, while welcomed here, has to be treated with cynicism. Will he actually be charged, and if so, will his case go to trial in a relatively short period of time, and will be actually be sentenced and serve prison time ? I need to know that this activity is not just for MONEYVAL's benefit, and that it will dissipate in November. Please tell me the case is real. Little things bother me,; the failure to name one of the daughters in the freze order, Schembri's eleventh-hour flight to Milan, the four year delay in the arrest. It goes on and on.

I am reminded of the Maltese citizen who was sentenced to prison time; the court allowed him to attend university, on the campus, each day, while he was incarcerated, as a sort of school release program. Is that the functional equivalent of sitting in a prison cell, only sleeping there, as in a halfway house ? I doubt it.  Will Schembri be released each day, due to his power, wealth and influence ?

Listen, I may be totally wrong here, and if I am, I will apologize, but I do not see this arrest as solving Malta's long corruption and money laundering nightmare. Only arrests from a jurisdiction that is not susceptible to corruption, such as the United States or the UK, will make me happy, for those countries do not accept bribes to fix court cases.

Just so we are clear, the Schembri case will NOT affect, in any way, the American investigations currently underway. I have it on good authority that they are proceeding with all deliberate speed. Govern yourselves accordingly.




This blog shall continue to report on the financial criminals who are hell bent on making Americans homeless. If you have not previously read our coverage of Fay Servicing , you are invited to visit our prior article here:

We, every day, are learning even more about how vulnerable American homeowners, particularly Seniors, are to dishonest mortgage companies. Most states have laws against filing false documents with the courts; there is even a Federal Statute on point. See 8 United States Code §1324(c) - Penalties for Document Fraud. Falsifying documents is a criminal offense when it involves the alteration, correction, modification, delivery or possession of a document when conducted for an unlawful purpose. While it is considered a white-collar crime, it is known by different names, depending upon the state. It may also be included a part of other collateral crimes. The falsification of documents is a felony under state law.  

Allow us to explain. Let's say your unethical mortgage company has decided it no longer wishes to wait for the balance of your 30-year mortgage, which you have been faithfully paying on time for the past 20 or 25 years.

The First Step in the fraudulent plan to steal your home, and deprive you of your life's largest asset, begins with illegal practices at a company such as Wells Fargo  Mortgage, where the firm actually took action against borrowers, notwithstanding that they always made all their payments on time, only to learn later that the company was using illegal tactics and methods to increase its revenue, and even foreclose upon their homes, by committing fraud and unconscionable acts. One recent article that deserves your attention is here: sure-pay-his-

The Second Step: Once the lender has created a fraudulent dispute on the target homeowner's mortgage account, the mortgage in question is bundled up with others, and sold to an unscrupulous third party debt collector. In this case, it was Fay Servicing, described by observers as a racketeer-influenced corrupt organization (RICO), notoriously known for having a staff that lies to its customers, frequently deceives them, fabricates bogus loan documents, and pads mortgage accounts with all types of excessive and fraudulent fees, thereby forcing the homeowners into bankruptcy court, to protect their homes from foreclosure.

In Step Three,  the homeowner is granted a Stay by the Bankruptcy Judge, with an affordable payment plan, created by the Court and the Trustee. Two senior Fay Servicing officers, President Kimberly Bingham and Vice President Ryan Finnigan have been reportedly instructing their employees to file a false Proof of Claim, in the Chapter 11 or Chapter 13 filing, asserting an higher number of the principal loan balance. This forces the homeowner to a higher, and unaffordable, payment, and where the case is later dismissed, making the property vulnerable to the illegal foreclosure scam without allowing the borrowers any workout options to save their homes.

We note that this practice is a violation of 18 U.S.C. 152(4). Fay Servicing, its executives, employees and debt collection attorneys, who are fully aware of their filing of false Proofs of Claim, continue to file the same fraudulent documents with local courts, to pursue their unlawful foreclosures. Cloaking themselves under the name Wilmington Trust, N.A., as Trustee for MFRA Trust, the victims may never know who actually holds their note and mortgage. Readers are directed to review the multiple state and Federal decisions holding that MFRA foreclosures were based upon fraudulent and untrustworthy documents and filings; a number of those cases, including appellate decision, denied foreclosure.

Moving on to Step Four;  Fay Servicing, knowing very well that the homeowners targeted by their fraud are on financial life support, its attorneys finish the job by quickly foreclosing on the victims' homes, often while they are lying critically ill in hospital beds.Deceptive Mortgage Servicing Company Fay Servicing Exploits and Cheats Borrowers. 

Whereas, most individuals who commit Document Fraud are charged with a felony, as it is a crime to knowingly file, register, or record a false or fraudulent document with the courts of any public office within any state, Fay Servicing has consistently and repeatedly broken state or Federal law. with impunity, and just successfully foreclosed upon your home. 

The final insult: those same attorneys who just unlawfully foreclosed upon your home, will quickly contact you, their victim, via a proxy and unscrupulous business name, set up within the dark operation of their law firm, to begin offering the already ripped-off, stressed-out and depressed homeowner post-foreclosure assistance, at an exorbitant fee. In truth and in fact, the crooks have no genuine intention of helping the homeowner that they just scammed; it is only another ploy to trick and threaten the homeowner into surrendering their home, while enriching their pockets by double-dipping the gullible homeowner after they have stolen his home.

Somehow, Fay Sentencing, through all its unethical and dishonest conduct, seems to have operated above the law, while making hardworking borrowers homeless. We sincerely hope that the various state Attorneys General, the executive Office for US Trustees, and other law enforcement agencies take action to terminate these illegal activities. 


For Further reading:

Meet Fay Servicing's Foreclosure Pit Bull in Florida 

deceptive Mortgage Servicing Company Fay Servicing Exploits and Cheats Borrowers






Monday, September 21, 2020


                                                                   Matthias Krull

A reader asked me today if there was any documentary proof, meaning from a court file, that there are open cases pending against the present and former Malta government officials, in a matter we have named Maltagate. While any criminal indictments will be filed under seal, and disclosure of any information strictly prohibited, there are a number of clues to be uncovered, if you know what to look for. It often means sifting through related, or even seemingly unrelated, cases to extract some gems of information that will fill in one or more of the blanks.

 Remember MATTHIAS KRULL ? He's the dirty German-Swiss banker operating in the Republic of Panama who pled guilty to a money laundering charge two years ago, and began cooperating with law enforcement, to reduce his ultimate sentence. He moved $1.2bn in embezzled PDVSA money out of Venezuela, through many countries, including Malta.  He's been under house arrest ever since; we reported that he acquired a residence in Miami recently, and we wondered why the change from his home further north in Florida, since he was scheduled to surrender in September.

Now we know why; when I checked with the Bureau of Prisons to learn where he was serving his sentence, and his Release Date, I found that he was NOT in BOP custody. A check of the Court file revealed the Order that appears below. He was not only given additional freedom, a delay until March 7, 2021 to report to prison, he was released from House Arrest (Home Confinement) as well as Electronic Monitoring of his movements. This is, trust me, an early Christmas present; instead of cooling his heels in some county jail, awaiting his turn to testify before a grand jury or at trial, he remains out on bond, in his new Miami residence. This is clearly preferential, and even special, treatment. This is not done every day; must be for a significant case.

Given that he can now be readily available to Miami Federal prosecutors, I would say that this is a very good indicator that they have plans for him in any Maltagate case opened in Miami, if not also the lead case, in the Southern District of New York. It is further evidence of his role in a major criminal case . We know that this small piece of evidence may not convince everyone, but there are sufficient indicia like this one to support the conclusion that the probable targets had better finish up their efforts to acquire US criminal defense attorneys post haste.





                                               KEITH SCHEMBRI and JOSEPH MUSCAT

If you are a compliance officer anywhere in the world, but particularly in the European Union, and the British Virgin Islands, please pay close attention to the 18-page document attached below. It lists all the companies named in a freeze, attachment and garnishment order entered by Judge Edwina Grima, at the Attorney General's request. There are many corporations, banks, and other entities which have 24 hours to comply. Are you banking any of these individuals or companies ? You are advised to consult with your counsel immediately, especially if you have any pending transfer or withdrawal orders from your clients.

Suspected of money laundering is KEITH SCHEMBRI, the ex-Chief of Staff to the former Prime Minister, JOSEPH MUSCAT, who is himself a target of US law enforcement, and a Person of Interest in several EU countries. Yes, I know the Order is in Maltese, but you can certainly read the names and check your records forthwith. You are strongly advised to do so. 

Whether this asset freeze is the beginning of a major Maltese money laundering enforcement campaign, or merely an astute political move, to superficially deflect the international pressure which Malta's government is definitely feeling of late, remains an open question. Will there be subsequent enforcement actions ? Only time will tell. October is fast approaching, and that means only one thing: MONEYVAL.