Friday, December 31, 2021



Mugshot  by COSIMO

              Give me time to realize my crime                                                                                                                       Let me love and steal                                                                                                                                         I have danced inside your eyes                                                                                                                          How can I be real

            Boy George "Do you Really Want to Hurt me ?" 

Buckle up, Malta, for you are in for a rough time in 2022. If you thought you could ride out the FATF Greylisting, the UK high-risk designation, and the Swiss NGO AML report, things will get worse shortly. 

Expect JM to, at long last, be held accountable for his many sins, with blind justice administered from afar. Given the rampant corruption amongst Labour's leadership, many of their corrupt sitting ministers will soon rue the day they followed PL policies into a life of crime.

What you have seen is just the tip of the iceberg, my friends. I warned all of you a long time ago; Don't awaken the Sleeping Giant with your offshore financial centre money laundering of Venezuelan and Iranian sanctions proceeds.

 A man reaps what he sows. The one who sows to please his sinful nature, from that nature will reap destruction. The one who sows to please the Spirit, from the Spirit will reap eternal life.  Let us not become weary in doing good, for at the proper time we will reap a harvest if we do not give up.

Galatians 6.                                                                           




 Taken verbatim from the Repubblika Public Statement

On the occasion of the end of the year, Repubblika expresses its appreciation toward the institutions that are still observing the oath of office that they undertook in favour of upholding standards of good governance and promoting the rule of law, namely the National Audit Office, the Commissioner for Standards, and the Ombudsman.

Repubblika recognises and appreciates that these offices have continued to fulfill their duties despite the significant obstacles and continuous hindrance from the government and other institutions that have chosen to sell their souls.

Repubblika also thanks those journalists and news outlets whose only loyalty is to truth and justice. In this context, Repubblika would like to emphasise that it cannot remain silent at the worrying situation at the Public Broadcasting Services (PBS), which instead of being an instrument of education and the development of critical thinking, is allowing itself to be used as an apparatus for government propaganda.

Repubblika expresses its appreciation towards those individuals who, despite the fact that their institutions’ leaders have allowed themselves to be bought, are still fulfilling their duties toward the state and justice. We recognise the challenges they face as well as their courage and determination. Thank you.

Repubblika would also like to thank other groups and citizens who are committed to the rule of law, the protection of human rights, the strengthening of justice, and the fight against corruption in the country. Thank you for your dedication and your work.

Repubblika reiterates its commitment towards the rule of law and declares that it will be even more committed in this fight during the coming year.

 Well Said.

Thursday, December 30, 2021


First, read the IRS News Release:

WASHINGTON — The competent authorities of the United States and Malta signed a competent authority arrangement (CAA) confirming their understanding of the meaning of pension fund for purposes of the United States–Malta income tax treaty (Treaty). The competent authorities have entered into this agreement after becoming aware that U.S. taxpayers with no connection to Malta were misconstruing the pension provisions of the Treaty to avoid income tax on the earnings of, and distributions from, personal retirement schemes established in Malta.

The CAA PDF confirms the U.S. and Malta competent authorities' understanding that (except in the case of a qualified rollover from a pension fund in the same country) a fund, scheme or arrangement is not operated principally to provide pension or retirement benefits if it allows participants to contribute property other than cash, or does not limit contributions by reference to income earned from employment and self-employment activities. Because Maltese personal retirement schemes contain these features, they are not properly treated as a pension fund for Treaty purposes and distributions from these schemes are not pensions or other similar remuneration.


Now, review the complete text of the agreement:


Wednesday, December 29, 2021



 Do you need to know whether your new affluent Malta client is using a Citizenship by Investment (CBI/IIP) passport, that he or she purchased, as proof of nationality, to deceive you ? The link below will give you access to the Maltese Government database of individuals that bought their citizenship & passport to appear to be low-risk. It also contains the names of new citizens who were naturalized on other grounds, but your focus is on those CBI passport holders. If you customer doesn't appear to be a native Maltese. you could have a staff member ask him a few questions in Maltese, to see how he responds. 

Is his true country of national origin Iran, Russia, Syria, China or North Korea  ? A large number of Malta CBI passport holders are from those high-risk jurisdictions.  Use this database as a part of your risk-based compliance programme. Should you find that a "Maltese" bank client is not what he or she says they are, perform Enhanced Due Diligence, or decline to onboard the client, depending upon your bank's policies and procedures. Personally, I would NOT accept any Maltese CBI passport holder whose real country of origin is high-risk, a failed state, or a State Sponsor of Terrorism, if so designated by the United States.  

Access the data here.

Saturday, December 25, 2021



                                                The Seven Deadly Sins by Pieter Bruegel

A number of commentators in Malta have been displaying the names of JOSEPH MUSCAT, and his associates, individuals who can only be labeled sinners. Perhaps it's high time that their specific transgressions are listed in Biblical terms.


The Travel Ban imposed by the United States State Department is the first in history against citizens of a European Union Member and friendly state. Muscat, his extended family, and his former Cabinet, risk possible extradition if they travel to the EU or UK. They may end up marooned on Malta, due to well-placed fears of possible arrest and extradition upon arrival at a foreign destination that they thought was safe.

We warned you on this blog, during the past three years, that there would be consequences for violations of the Foreign Corrupt Practices Act (FCPA), but the commentators all said the US would take no action. They also discounted the articles about three Cooperating Individuals, who come from the Labour Party, and who have reportedly given evidence against Muscat, Mizzi and Schembri, to American law enforcement agencies. Our warnings have become reality, and this is just the beginning.

It is widely known that Joseph Muscat paid high-priced American criminal defence attorneys fees in excess of $100,000, to obtain information confirming that he is not the subject of a pending indictment in the United States. That is incorrect, and any lawyer who has told you he can determine, with 100% accuracy, that you are not under indictment, has hustled you, Mr. Muscat. You are the Number One target.

One additional issue facing Muscat: he may now be ineligible to travel on any airline in Europe. Commercial aviation uses their US Dollar accounts to purchase fuel and parts, and for aircraft leasing. They apparently fear American sanctions if they accept payment from Muscat, his wife, and even his designer-clad children, given the broad scope of the State Department sanctions. 

If Malta doesn't immediately begin to clean up the rampant corruption and money laundering, through its presently inept court system, things will surely get worse. One look at the blunt threats currently being made against Russia and Belarus by the United States should concern every Maltese businessman, because an angry America can impose those sanctions upon their country; being cut off from the American financial structure, or the SWIFT wire transfer network. Either of these actions would cause chaos within the Maltese financial system, most likely followed by panic among the population, and domestic instability.

Both the EU and the United States are waiting for Malta to respond with a comprehensive anti-corruption programme; in the absence of it being implemented forthwith, you can expect Malta to soon experience even most drastic measures, which can only result in the slow death of the economy. 

Will the last person leaving Malta remember to turn out the lights ?


Romans 6.23,  Ladies and Gentlemen. 

Signpost near Castille

Friday, December 17, 2021


On December 17, 2021, Malta's Financial Intelligence Analysis Unit (FIAU) imposed a civil administrative penalty upon the Bank of Valletta, the country's most prominent financial institution, in an amount in excess of €2.6m. The stated reason for this act was the bank's utter failure to identify the ultimate  beneficial owners of more than two thousand of its corporate account holders, or shows otherwise incomplete information. Whether this penalty will result in further action by EU or American regulatory or law enforcement agencies, including FINCEN and  OFAC, including sanctions which will bar the bank from the US financial structure, cannot be determined at this time, but the FIAU Notice certainly increases the risk that American regulators will move against BOV.

Thursday, December 16, 2021


What GAO Found

Money transmitters and nonprofits that transfer funds to recipients in countries at high risk for money laundering or terrorist financing have reported bank account closures and delays or denials of requests to transfer funds. These banking access challenges can affect the provision of financial support and humanitarian aid in areas experiencing political conflicts or natural disasters. Bank representatives told GAO they limit or deny services to money transmitters and nonprofits largely because of their efforts to comply with Bank Secrecy Act/anti-money laundering (BSA/AML) regulations. For instance, they cited the high costs of conducting the due diligence necessary to ensure funds distributed in high-risk countries are not used for illicit purposes. They noted that these countries often lack adequate and transparent frameworks for countering money laundering and terrorist financing. Bank representatives also cited heightened scrutiny they receive from regulators when banking higher-risk money transmitters and nonprofits and uncertainty about regulatory expectations for conducting due diligence.

Among the representatives of banks, money transmitters, nonprofits, and federal agencies with whom GAO spoke, views varied on the best ways to address money transmitters' and nonprofits' banking access challenges. These industry stakeholders and federal agency staff discussed the benefits, limitations, and other considerations associated with several proposals commonly cited in relevant literature to improve banking access for money transmitters and nonprofits. For example:

  • Know-your-customer utilities refer to centralized sources of customer information (e.g., documentation of their licensing or internal controls) that banks can access to conduct their BSA/AML due diligence. Some industry stakeholders said use of these utilities for money transmitter or nonprofit information could lower banks' general compliance costs—particularly if the utilities provided analysis of customer risks that banks could rely on to satisfy their due diligence requirements. However, among other limitations, these utilities would not solve key due diligence challenges associated with the lack of transparency in some high-risk countries, according to some stakeholders and federal agency staff.
  • An enhanced federal role in facilitating fund transfers could be useful in emergency humanitarian cases in countries where the high risk of money laundering or terrorist financing generally impedes banking services, according to several stakeholders and some federal banking regulator staff. For example, a U.S. agency with a physical presence in a particularly high-risk country could serve as the intermediate recipient of funds, with responsibility for distributing the funds to the intended beneficiaries. However, staff from the Department of the Treasury said such federal involvement could have unintended consequences. For example, if the U.S. government were to make it easier to transfer funds to countries considered high risk because they lack proper governance, it could reduce those countries' motivation to enact fundamental government reforms to lower their risk levels.

Why GAO Did This Study

Some money transmitters (a type of nonbank financial institution) and nonprofit charitable organizations transfer funds to foreign countries' populations in need, such as areas experiencing conflicts or humanitarian crises. These organizations need bank accounts and other bank services to make these fund transfers. However, banks may be reluctant to provide these services when recipients of funds are in countries at high risk for money laundering or terrorist financing. The National Defense Authorization Act for Fiscal Year 2021 included a provision for GAO to identify options to address this issue.

This report discusses banking access challenges reported by U.S. money transmitters and nonprofits that transfer funds to recipients in high-risk countries and the drivers of these challenges, and stakeholder views on proposals for increasing banks' willingness to serve these customers, among other objectives.

GAO reviewed academic, industry, international organization, and think tank literature, as well as documentation from federal banking regulators and Treasury. GAO also interviewed agency staff, industry associations, and experts and held five discussion groups with representatives of banks, money transmitters, and nonprofits, which were selected to reflect a range of sizes and geographic areas served.



Wednesday, December 15, 2021


Here are the Guidelines published recently in Malta.  

They permit anyone convicted of a crime to have his or her conviction deleted from the
online system upon request, three years after the date of judgment. Read Paragraph 3.

This means that any compliance officer performing a due diligence inquiry upon an 
individual can no longer confirm the absence of a criminal history for a citizen or 
resident of Malta. This legislation violates the European Human Rights convention
 regarding the free availability of information. Malta has turned its back on Truth.

Malta will never be removed from the FATF Greylist if it continues to pass laws 
like this, to the contrary, it risks even more drastic penalties from regulatory authorities. 

(Taken verbatim from the government website)

1. Preliminaries

The right to a fair hearing requires that the judgments of the Courts be given in public.

Judgments of the Courts are accessible by law to the public in the Registry and in the Archives of the Courts.

The Legal Notice entitled 'Regulations on the Online Publication of Court Judgments (Data Protection) Provision of Functions' deals only with the publication of judgments on the website and with the in no way shall it prejudice the principle of publicity of judgments as protected by the Constitution and the law.

Judgments of all Civil and Criminal Courts will be published online on the website except for judgments of the Family Court or where there is a prohibition on publication which is out of law or which is ordered by the Court.

When the Chief Executive of the Court Services Agency receives a request for the removal of a judgment from the above-mentioned website for reasons of protection of the right to privacy and family life, they shall first the necessary checks shall be made to ascertain that the individual making the request is the subject of the Data identified or identifiable in the judgment and if so the request will continue to be assessed.

2. Criteria and Considerations

The criteria and considerations to be used in assessing whether the removal, in whole or in part, or the anonymisation of a judgment from the online system is justified are:

  1. The reason for the request, which must be explained by the applicant.
  2. Whether there is still a need for a judgment to remain on the website for reasons of public interest, the exercise of the right to information or the right to freedom of expression, or for research purposes historical or scientific.
  3. Whether the removal, in whole or in part, or the anonymisation of a judgment from the online system will have a negative impact on other individuals;
  4. The rules of the General Data Protection Regulation (Regulation (EU) 2016/679 in particular article 17 (right to erasure) of that regulation which also forms part of the law of Malta.
  5. Decisions of International Courts and in particular of the Court of Justice of the European Union and of the European Court of Human Rights with regard to the processing of personal data.

3. General Guidance - Balance between Rights and Obligations

As a general rule of thumb, the following requirements must be met before approving the removal, in whole or in part, or the anonymisation of a judgment from the online system:

  1. Three years have elapsed from the date of the judgment;
  2. If the offender has been sentenced to a fine, the fine must be paid;
  3. In the event that an appeal has been lodged from the judgment, the appeal must first be decided and the three years from the date of the judgment of the court in the degree of appeal must begin;
  4. In the event that the judgment is the subject of other proceedings those proceedings must be terminated;
  5. In the event of a conviction for a suspended prison sentence, the operative period must have elapsed;
  6. In the event that the person is found not guilty, the sentence shall, except on grounds of public interest, be revoked shortly after the request is made.

4. Notification of the Decision

The decision shall be communicated in writing to the person who made the request within 30 days of receipt of the request by the Chief Executive of the Court Services Agency.

5. Right of Appeal

The person making the request shall also be informed that with the right of appeal from the decision of the Chief Executive Officer of the Court Services Agency to the Commissioner for Information and Data Protection. in case the request is rejected.

Tuesday, December 14, 2021


Father, Ricardo & Luis


RICARDO ALBERTO MARTINELLI LINARES, the second son of former Panamanian President Ricardo Martinelli Berrocal, today (14 December) entered a guilty plea in US District Court in Brooklyn, following his brother's prior plea earlier this month. Both pled to Conspiracy to Commit Money Laundering, in the $28m Odebrecht bribery case. They were alleging acting as intermediaries for their father, who was the ultimate recipient of the bribes.

Odebrecht, a Brazil-based giant construction entity, funnelled more that $700m in bribes and kickbacks to government officials and others, to receive, or extend, lucrative government contracts around the world.



  By: Rev. Father David Muscat

 Yet another luxurious Dubai style project in Malta: the mega so-called development instead of a parking area of the ex-trade fair grounds in the north part of the island, a stone's throw away from historical buildings and the old village core of Naxxar predating the Knights of Malta.

This charming Maltese village will be forever ruined, and the quiet Saint Paul’s Gap residential area will be brought to its knees in the shadow cast by the planned high-rise buildings.  This will be done very close to the place where according to tradition Paul the Apostle preached and was heard in Malta’s sister island of Gozo.
Is there anyone worried about this? Of course there is. Various NGO’s such as Graffiti are relentlessly vociferous and indeed sometimes winning battles here and there, as the disfigurement of the island spreads.  But though the occasional battle may be sometimes won, the war is being lost as the country gets littered with these ugly structures meant to house residents, predominantly non-Maltese attracted by the tax-haven status and the multiplier effect on the economy that this island rock has cultivated, as repeatedly stated by both a well-known Maltese architect and an ex-ambassador to the EU. 

Activists, Graffiti, as well as other well-meaning environmentalists need direct their efforts to quash the causal factors producing this very Maltese green disaster.  This is no small feat because even our Brussels MEPs fight tooth and nail to maintain the ‘’tax haven’’ status that is the root cause of this disfigurement.

Someone of The Shift News tried to explain the continuing surge in support for the Labour government as Stockholm Syndrome.  He is painfully close to the truth, except that this falling in love with a corrupt system was love at first sight when in the 1990s the Maltese decided to finance their economy through the advantageous capital corporate tax system that effectively transformed Malta into a tax haven.  Joseph Muscat merely fine-tuned the system.   

NGOs like Graffiti and the leftist journalists of The Shift News (admittedly the best investigative journalism is found here) want to save the environment of Malta.  Fine.  Then, they should stop behaving like Gucci socialists.  They should start attacking the economic model and not just the corruption scandals of the Maltese government.  

I have not lost hope.  Sooner or later this Maltese venture capitalism based on financial services, gaming and betting will implode.  Listening to Jesus’s admonitions helps to hasten this, even though the situation is desperate and there are crooks everywhere: ‘’Do not be afraid to that which kills the body [the economic model] but cannot kill the soul.’’ (Matthew 10.28). 


Monday, December 13, 2021


National Westminster Bank Plc (NatWest) was today fined £264,772,619.95 following convictions for three offences of failing to comply with money laundering regulations.

Mrs Justice Cockerill, the sentencing judge at Southwark Crown Court, today said: '….it must be borne in mind that although in no way complicit in the money laundering which took place, the Bank was functionally vital. Without the Bank – and without the Bank’s failures - the money could not be effectively laundered.' 

NatWest pleaded guilty at Westminster Magistrates Court on 7 October. This is the first time the FCA has pursued criminal charges for money laundering failings.

The charges covered NatWest’s failure to properly monitor the activity of a commercial customer, Fowler Oldfield, a jewellery business based in Bradford, between 8 November 2012 to 23 June 2016. When taking on the customer, NatWest initially understood it would not handle cash from the Fowler Oldfield business. However, over the course of the customer relationship approximately £365m was deposited with the bank, of which around £264m was in cash.

Some of the bank’s employees, who were responsible for handling these cash deposits, reported their suspicions to bank staff responsible for investigating suspected money laundering, however no appropriate action was ever taken. The ‘red flags’ that were reported included significant amounts of Scottish bank notes deposited throughout England, deposits of notes carrying a prominent musty smell, and individuals acting suspiciously when depositing cash in NatWest branches. In addition, the bank’s automated transaction monitoring system incorrectly recognised some cash deposits as cheque deposits. As cheques carry a lower money laundering risk than cash, this was a significant gap in the bank’s monitoring of a large number of customers depositing cash, of which Fowler Oldfield was one.

A separate investigation by West Yorkshire Police has led to 11 people pleading guilty to charges relating to the cash deposits and three cash couriers being charged. A further 13 individuals are awaiting trial at Leeds Crown Court on 25 April 2022 in relation to the activities of Fowler Oldfield.

Mark Steward, Executive Director of Enforcement and Market Oversight at the FCA, said:

'NatWest is responsible for a catalogue of failures in the way it monitored and scrutinised transactions that were self-evidently suspicious. Combined with serious systems failures, like the treatment of cash deposits as cheques, these failures created an open door for money laundering.

'Anti-money laundering controls are a vital part of the fight against serious crime, like drug trafficking, and such failures are intolerable ones that let down the whole community, which, in this case, justified the FCA’s first criminal prosecution under the Money Laundering Regulations.'

( Credit: FCA)

Sunday, December 12, 2021


RICARDO ALBERTO MARTINELLI LINARES, the second son of former Panamanian President Ricardo Martinelli Berrocal to be extradited to New York to face bribery charges in the Odebrecht corruption case, arrived in the United States this week. He follows his brother, Luis Alberto Martinelli Linares, who was also charged when he arrived last month; Luis has already entered a plea of guilty to money laundering charges, and is awaiting sentencing, now scheduled for next year.

The case, which is pending in Federal Court for the Eastern District of New York, alleges that the Martinelli brothers received $28m in bribes as intermediaries for their father, who was at that time the President of Panama. The Government has opposed any bond for Ricardo; Luis was previously ordered into permanent pretrial confinement, The brothers originally fled the United States via a private yacht to the Bahamas; they were later, after extended international travel that involved counterfeit PARLACEN* diplomatic documents, arrested in Guatemala on a warrant from the United States.

Given the amount of bribe money they allegedly received, their illegal exit from the United States, and other criminal activities they engaged in during their flight to avoid prosecution, it is expected that their sentences, when handed down, will be lengthy, followed by their deportation to Panama, where they could face charges there by the time they have served their US sentences.


*Central American Parliament





If you read the recent New Yorker article detailing the collapse of the Afghan military immediately prior to the Taliban's relatively painless takeover of the country, you might have seen the note about individual Afghan soldiers being paid to remove their uniforms and desert, down to the issuance of a safe conduct pass to each of them, allowing them to return to their homes without fear of Taliban retribution.

What the article did not disclose is who, or what, financed the bribes paid to each Afghan soldier, to facilitate their demobilisation. While we are aware that the Taliban earned substantial income from narcotics trafficking, it is doubtful that this was the source of the disbursements paid to the soldiers.

So who is the most likely finding source ? We doubt that an investigation, at this stage, inside Afghanistan, can result in a finding of fact, but nevertheless, we believe it is important to determine what entity provided the money to pay off all those troops, in cash. to take them off the battlefield at a critical time.

My money is on Qatar as the probable funding source, although I must confess that, at this point, I have no evidence to support this theory. We can only hope that some investigators, following the money, literally, will stumble upon the answer. We certainly need to know who was behind it.


 Abdul Rahman Yasin Up to $5 Million Reward. Abdul Rahman Yasin directly assisted terrorist mastermind Ramzi Ahmed Yousef in carrying out the February 1993 World Trade Center bombing in New York City. Yousef and Yasin drove a van full of explosives into the basement of the World Trade Center, killing six people and wounding over a thousand. 

Yasin fled the United States immediately after the bombing to avoid arrest. After the bombing, law enforcement officials obtained evidence which led to the indictment and arrest of several suspected terrorists involved in the bombing, including Yasin. Yasin was born in the United States, moved to Iraq during the 1960s, and returned to the U.S. in the fall of 1992. He possesses a U.S. passport. 

The individual listed above has been indicted on the following charges: Damage by means of fire or an explosive; damage by means of fire or an explosive to U.S. property; transport in interstate commerce an explosive; destruction of motor vehicles or motor vehicle facilities; conspiracy to commit offense or defraud the U.S.; aiding and abetting; penalty of death or life imprisonment when death results; assault of a federal officer in the line of duty; and commission of a crime of violence through the use of a deadly weapon or device.

 Date of Birth: April 10, 1960 Place of Birth: Bloomington, Indiana Height: Approximately 5'10" (178 cm) Weight: Approximately 180 lbs (82 kg) Hair: Black Eyes: Brown Sex: Male Complexion: Olive Citizenship: American Characteristics: Possible chemical burn on right thigh. Epileptic; takes medication for condition. Aliases: Abdul Rahman Said Yasin, Aboud Yasin, Abdul Rahman S. Ta (taken from Rewards for Justice).

Saturday, December 11, 2021



Any objective observer must be asking what is behind the Maltese government’s frenetic drive to legalise the growing of cannabis for so-called recreational – as well as for medicinal – purposes.
I will not enter into the merits of whether this plant causes serious physical or psychological damage or why one cannot bring out his potted plants for the Roman Catholic Corpus Domini and Sacred Heart processions in June.  I have no opinion on this and leave the topic to psychiatrists. 
I will focus instead on the cannabis agro-industry that will potentially enrich Malta’s public exchequer to the tune of millions, whilst fattening the pockets of certain Maltese influential cliques and traffickers, both domestic and foreign.
The only drawback for the establishment of this agro-industry is Malta’s size and the relatively small acreage of her fields. Malta is 21 miles in length and has a width of only 10 miles.  Half a dozen cannabis farms in Spain or Italy could produce half of Malta’s output.   Additionally, Malta has already been converted into a concrete jungle, with EU-funded road extension projects to link the skyscrapers utilised by the local and foreign betting/financial services/gaming magnates. Furthermore, most of our agricultural land is broken into small farming plots which have been worked by scores of local farmers who pay land rents to the properties’ owners – government, private landowners (mainly members of the Maltese nobility) or the joint office (which caters for lands formerly owned by the Church).
All this is set to change following recent court sentences which have forced the evictions of tenant farmers from agricultural land, land that has been worked by several generations of Maltese farmers.  These court sentences have practically become a daily occurrence.
What all this boils down to is that a substantial chunk of Maltese farmland is now available – and ripe - for the greedy speculators. It will certainly prove to be a providential blessing for the nascent cannabis agro-industry in Malta. Indeed, the government is set to issue licenses for cannabis growing to the extent, that, even if the entire islands of Malta and Gozo are covered with marijuana plants, there simply will not be enough land for cultivation purposes.  Clearly then, every available acre of land is manna from Heaven for the cannabis speculators. 
The second worrying aspect of all this is that tonnes upon tonnes of cannabis from Latin America, North Africa and the Middle East will flow to the European markets via Malta.
 Given that we already launder money from the criminal activities of Russian oligarchs, Chinese tycoons, the Italian Mafia, African dictators and Arab sheiks, what will stop us from laundering the proceeds from cannabis production?  The international cabal of globalist charlatans is well aware of the fact that in Malta, the local administration will protect their “investments” in the present environment where impunity rules. 
Naturally Malta’s government will go to great lengths to assure the European Union that strict regulations and anti-laundering compliance rules will be in place to deter any Latin American and North African weed entering the EU through the Republic of Malta.  Does anybody seriously believe that these rules will be enforced?  With Malta’s track record of lack of enforcement of mafia money laundering, the future does not hold out much promise in this area.  As the FATF spokesman Marcus Plejer stated: “You Maltese enact laws in order that they remain on the statute books”.
Nor should we expect any reaction from the Maltese MEPs in order to prevent such abuses.  If, at some future stage, the EU does decide to investigate this speculative land grab for the cultivation of narcotics and the subsequent laundering of its proceeds, the Maltese MEPs will do everything under the pretext of defending the jobs and economic growth this provides.  They used this argument in the past.
When Satan tempted Jesus in the desert in order for the Divine Saviour to turn stones into bread, while Christ refused, we Maltese say Yes!  We said yes when we morphed Malta from an island based on work into a tax haven where money laundering reigns.  The next lucrative bubble is weed laundering. 
Mammon has become the new God of Malta’s political and business classes, as well as that of large sections of our population.  The One True God will laugh at them.

                                                          OUR COMMENTARY
We ask: which banks will be working with these new cannabis businesses in Malta ?  Internationally,  most countries still classify cannabis as a Class (Schedule) A drug.Most banks don't want anything to do with cannabis businesses.

It's a problem in the US in states where cannabis is legal, like Washington State, Colorado or California. Cannabis is still illegal at a Federal level, but legal in some states. This means most banks will not touch cannabis business as they can potentially be Federally prosecuted for money laundering, cannabis being a controlled substance. It's a cash only business.

What will happen in Malta once cannabis is legal ? Will BOV be digging its own reputational grave if it accepts cannabis business ?

Another issue is cannabis testing for motor vehicle drivers; no accurate tests exist that can confirm cannabis use within a few hours of use, but cannabis stays in the system for a few days. Will cannabis users  be forced to forfeit their driving priviledges ?

Tuesday, December 7, 2021



The new, and improved, Reza Zarrab

If you were wondering where the notorious "oil-for-gold" Iran sanctions evader REZA ZARRAB has been living, while he waits to testify in the HALKBANK money laundering trial in New York, he is currently living in Miami's upscale Coconut Grove district, in a luxury multi-million dollar gated residence, under the alias AARON GOLDSMITH*, according to multiple reports from Florida.

Zarrab is engaged in the  purchase and sale of dressage horses, and is believed to have taken over a local South Florida horse farm, which he is upgrading to meet his specifications; he is indeed living the Florida good life, while technically still on the hook for up to 130 years in Federal Prison for his sanctions evasion activities on behalf of Iran. His value as a major witness against Halkbank,  a Turkish-government owned financial institution, and which will, sooner or later, find itself inside the Federal courthouse in New York, cannot be underestimated. Zarrab certainly know where all the financial bodies are buried.

While it is easy to be critical of the ultra-luxury lifestyle this convicted sanctions evader currently enjoys, he will, sooner or later, face American justice, and there will be consequences, though they will be far less than what he faced upon his arrest. We will be closely watching Zarrab's odyssey, and will report back on the conclusion of his legal journey.



John Kaplan

Richard Ferrari

Aaron Goldsmith


 The court reduced the agreements and understandings from yesterday's hearing to an order.

Monday, December 6, 2021



The scheduled In-Person Status Conference in the Alex Saab Moran case was held today, December 6., 2021, and we are raising a number of points for our readers:

(1) The parties stipulated that the presently set trial date, January 3, 2022, is unrealistic. Another Status Conference, to set a new trial date, has been scheduled for January 7.

(2) The Court noted The interests of justice served by a continuance outweigh any interest of the public or the Defendant in a speedy trial.

(3) Whether you may construe these developments as further confirmation that the defendant has either already competed plea negotiations, or they are merely in progress, is a distinct possibility. Of course, until a change of plea is announced, we are guessing as to the developments behind the scenes, but the rumours persist.

We note the presence, at the hearing of DOJ attorney Alexander J. Kramer, who is a trial attorney with Main Justice's Foreign Corrupt Practices Act (FCPA) Unit in DC. He was there to supplement AUSA Kurt. K. Lunkenheimer, from SDFL. Kramer's attendance is a signal that senior DOJ staff are involved. Our analysis of all developments in this case, even those that some may regard as insignificant, shall continue.

Saturday, December 4, 2021





Some things that go on in the criminal justice system are impossible to understand. Take the hedge fund Ponxi schemer, FRANCISCO ILLARRAMENDI, who turned a major hedge fund loss into a massive Ponzi scheme, coldly leaving victims by the side of the road. He went through one defense attorney after another in his case, needlessly delaying the wheels of justice. His theory of defence was pure garbage. His bond was revoked when it was determined that illegally secured a tax refund, when that money should have gone to reimburse his victims. 

His appeal of his conviction was also without any merit at law; there was no reversible error committed during his trial, and there was sufficient evidence of his guilt. In short, he was one difficult defendant, with one dilatory tactic after another, but all proving to be without any merit. He wasted an extraordinary amount of both the Court's time and the resources of the US Attorney's Office, when a guilty plea early one might have saved him years of additional confinement. He received 13 years back in 2015, and he was ordered to repay $26.8m . His §2255 Petition to Vacate, Correct or Set Aside Sentence was denied in 2020. 

That being said, the question is why has he been transferred to a halfway house, in the Baltimore/D,C, area ? His case is in New England, and his Release Date is in 2124.  How can a difficult defendant receive such a benefit, long before he would generally be eligible for release to a halfway house ?

His dilatory conduct in his case would generally not endear him to either the sentencing judge or the string of AUSAs who had to deal with his attorneys' tactics, so why is he apparently at an inner city halfway house in the Washington area, far from Connecticut, where he committed his crimes ? We can only speculate that his knowledge of the Venezuelan financial jungle, especially the money laundering world, might assist Federal prosecutors in current Venezuelan financial crime cases.

 However,  in a sense he is cheating justice by enjoying the relative freedom of a halfway house, rather than a Federal Correctional Institution. Let's hope the favored treatment he is receiving is actually resulting in some additional indictments, or the seizure of criminal assets. Still, it seems that a hedge fund bad boy is getting over on Uncle Sam. 




We have been contacted by an international whistleblower known for his exposure of official corruption; in this case, however, he has advised us that a certain Malta company facilitated the illegal sale of ISIS  crude oil in the European Union, and elsewhere. The company provides laboratory testing, inspection, and certification of crude oil. Banks rely upon those reports when making payments; therefore, the company has a key role in the global petrochemical industry.

We have withheld the name of the company, as the whistleblower plans to reveal the details in a book, to be published in early 2022, but Maltese businessmen familiar with the oil, crude and refined products petrochemical structure in their country should be able to easily identify it from these facts. the company has been accredited by the Malta National Accreditation Body, more commonly known as the NAB. 

The company, past of a multinational entity, reportedly intentionally and deliberately misidentified oil coming from ISIS, as originating from legitimate sources; counterfeit documents and certifications were employed. The petroleum products were then shipped to, and sold inside, the European Union. the documentation falsely certified that the oil was of Iraqi origin, or had come from Turkey.These deceptive acts constitute terrorist financing, as well as providing material support to a terrorist organization.

I would certainly identify the offending company to law enforcement in Malta, but I have absolutely no faith that the information would be discarded, because someone in the previous Muscat government benefited financially from allowing the mislabeled ISIS crude oil to be sold within the EU (Italy) and to Israel. Bribes and kickbacks flowed to corrupt government officials to allow this charade to continue. ISIS was able to add the oil sales proceeds to its war chest as the direct result of the criminal acts of the Malta company, through its local resident officers and directors. 



Thursday, December 2, 2021



The first son of former Panamanian president Ricardo Alberto Martinelli Berrocal, Luis Enrique Martinelli Linares, has, as his attorney recently indicated at his arraignment, entered a plea of guilty to a single count in Conspiracy to Commit Money Laundering, in the EDNY Odebrecht bribery case.

Luis faces a maximum 20-year sentence; he and his brother, Ricardo Martinelli Linares, are accused of receiving $28m in bribes and kickbacks from Odebrecht, so that the international construction firm could receive lucrative Panamanian construction projects. Luis' brother is not yet in US custody, although his extradition from Guatemala is expected shortly.

Given the extremely large amount of bribe money involved, and the fact that the Martinellis' attorneys employed several dilatory appeals to avoid extradition, and the fact that they fled the US, most likely indicates that he will receive a long prison sentence.  

According to the US Attorney's Office, Odebrecht paid out an estimated $700m to government officials, in Panama and elsewhere, to obtain and retain large construction contracts with foreign governments. Martinelli's sons allegedly acted as intermediaries, accepting and transmitting the bribe money meant for their father.



The news from Malta today is full of a libel case, filed by disgraced former Prime Minister Joseph Muscat, against an attorney, Christian Grima, who reportedly accused Muscat of involvement in the Daphne Caruana Galizia assassination in social media. It seems that Mr. Muscat failed to show up no less than three times for court appearances, with the end result that the case was dismissed by the court. Muscat evaded the question when the media asked him directly why he failed to attend three times. I wonder, can Dr. Grima recover attorneys' fees from Muscat, for filing a case with no factual basis, and them allowing it to be dismissed ?

The Artful Dodger threatened to sue me several times, especially when the press was there to record his posturing, but he never did, he also alleged that I had lost a number of libel/defamation/slander suits, but regular readers of this blog know that I never have had a money judgment entered against me for damages for libel or defamation. Muscat also accused me of being a fantasist, but all Malta knows that the only fantasist is JM himself, because he believes his own lies.

My open offer to debate Muscat, any time, any place, live or virtual, stands, but he is clearly afraid to publicly answer my questions about his corrupt conduct, both before becoming Prime Minister, as well as while in office, and since resigning in disgrace. Ultimately, though, he will have to answer to a Higher Power for his sins and transgressions. 


President Maduro and Alex Saab Moran

Contained in the Government's response to the Court's Standing Discovery Order is a notice, which appears below, that it will present what is known as Uncharged Criminal Conduct to the jury at his trial, which is permitted by Rule 404 of the criminal rules of procedure. This means that other crimes that the defendant allegedly committed will be entered into evidence, a tactic which will most certainly signal to them that he is indeed a career criminal. It will most likely have significant impact.  The complete text appears below.

"The government will timely advise the defendant of its intent, if any, to introduce at trial extrinsic act evidence pursuant to F.R.E. 404(b). Pursuant to Local Rule 88.10, the notice will be provided regardless of whether the evidence may be used in the case-in-chief, for impeachment or possible rebuttal, and will include the general nature of the evidence. You are hereby on notice that all evidence made available to you for inspection, as well as all statements disclosed herein or in any future discovery letter, may be offered in the trial of this cause, under F.R.E. 404(b) or otherwise (including the inextricably-intertwined doctrine). 

In addition, the government may introduce under Rule 404(b) evidence underlying the defendant's past bad acts which include prior payments to Bolivarian Republic of Venezuela officials in order to obtain improper business advantages and access Venezuela’s government-controlled foreign currency exchange system. 

Those prior bad acts also include post-indictment bribing of Venezuelan officials to obtain and retain contracts and other business advantages, including obtaining multi-million dollar food and medicine contracts with entities and instrumentalities owned and Case 1:19-cr-20450-RNS Document 77 Entered on FLSD Docket 11/29/2021 Page 2 of 4 3 controlled by the Venezuelan government for the importation and delivery of food and medicine to the people of Venezuela, and to launder bribes, proceeds, and other funds related to the corrupt scheme into and through accounts in the United States in order to promote the illegal bribery scheme and to conceal the nature and purpose of the proceeds of the illegal bribery scheme, including, but not limited to acts described in Southern District of Florida criminal case, 21-CR-20509-MARTINEZ".