Saturday, September 25, 2021


MFSA Supervisor Catherine Galea

Compliance officers at financial institutions in the European Union, meet Malta Financial Services Authority Banking Supervisor Catherine Galea, a 20-year veteran of that agency, who was entrusted with carrying out an Enhanced Due Diligence (EDD) investigation of ALI SADR HASHEMI NEJAD, in connection with the banking license application of PILATUS BANK. How do we know this information ? It seems that the Compilation of Evidence, against defendants  Pilatus Bank, and its Money Laundering Reporting Officer (MLRO) CLAUDE ANN SANT FOURNIER, in a money laundering case, has begun, and Ms. Galea,, on behalf of the MFSA, is testifying as to the EDD she conducted on Ali Sadr.

As was reported today in the Maltese media, in assessing Ali Sadr's risk profile, Ms. Galea stated that she found Sadr to be born in Iran, but in truth and in fact a citizen of Saint Kitts & Nevis. This incredible finding of fact proves just how ineffective her EDD investigation actually was, for even a rudimentary check of Sadr would find that he was indeed a citizen of the Islamic Republic of Iran (a high-risk country), and his wealthy father was a well-known businessman there.

 Sadr's SKN passport was acquired through the Kittitian Citizenship by Investment (CBI) programme, and he was neither a resident of St. Kitts, nor did he ever live there, and his economic "citizenship" was a cruel joke played upon the compliance officers of the world, because it allowed him to pretend that he was from a low-risk jurisdiction.

Of course, Ms. Galea, who lives in such a  country where citizenship and passport are yours if you pass enough money over the counter in Valletta, no matter who you may be, she knew very well that his citizenship was a legal fiction, and that he was an Iranian national, making him an unacceptable high-risk for a banking license within the European Union, given the international sanctions in place against Iran.



Yet, she passed Sadr, and indeed the Pilatus Bank license application was fast-tracked and ultimately granted. The rest is history; the bank went on to move millions for corrupt Asian PEPS, Latin American fraudsters and asset diversion specialists, Colombian money launderers, and all the usual suspects involved in global financial crime. Don't forget cleaning bribe and kickback money also.

So, since it all started with Ms. Galea, the gatekeeper who left the gate wide open, and therefore committed compliance malpractice, should she not also be held accountable for her sins ?  Having served as a compliance officer, conducting EDD on international investors, I can testify that there's no question this was a massive compliance failure. who is going to do something about it ?

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