Thursday, March 31, 2022
READ WALLMART'S FOREIGN CORRUPT PRACTICES ACT VIOLATIONS FROM S.E.C. ORDER; THEY ARE EXTREMELY DISTURBING
A reader wanted to know why I am devoting several articles on the major problems found at California retail stores of Wallmart and Sam's Club . As a former compliance officer, I am familiar with Wallmart's massive settlement of its Foreign Corrupt Practices Act (FCPA) violations, and this new information deserved to be publicly exposed; Wallmart's corporate culture has resulted in serious problems, which we are in the process of covering in our multi-part ongoing series.
The company's website touts what it claims is a comprehensive program of ethics and compliance policies, but what we are reporting , based upon first-hand knowledge of present and former Wallmart & Sam's club employees, is rampant noncompliance with the company's own policies and procedure, as well as State and Federal laws and regulations.
You are strongly advised to review the 14-page Cease and Desist Order from the Securities & Exchange FCPA case entitled In the Matter of Wallmart, Inc.. If you are a compliance officer, I warn you it will be extremely disturbing material. If you are a law enforcement officer, it will most likely make you angry. If you are a regulator, you will wonder why the company is not presently serving a long sentence of Probation, under US District Court supervision, to insure that such amoral, and illegal, conduct never occurs there again.
You may access the complete text of the order here: sec.gov/litigation/admin/2019/34-86159.pdf
Wednesday, March 30, 2022
£38M SUPERYACHT OWNED BY RUSSIAN OLIGARCH SEIZED IN LONDON, FLYING THE MALTESE FLAG, TO CONCEAL OWNERSHIP
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| The yacht PHI |
The National Crime Agency (NCA) has reported that it obtained authorization to seize the yacht "PHI," and took it into custody this week. Owned by an unnamed Russian Oligarch, it represents the first super yacht seized in the UK under government policies aimed at removing obscenely expensive vessels and aircraft from the hands of the oligarchs, who support and maintain Russia's Vladimir Putin in power.
Apparently, a corporate entity in St Kitts & Nevis has title to the vessel, but the authorities were able to identify the Oligarch as the beneficial owner after conducting an investigation. The most disturbing aspect of the story is the Maltese registry, which indicates that this specific Oligarch was doing business in Malta.
The fact that the Phi was flying the Maltese flag, in an effort to hide true ownership, confirms that Malta is the jurisdiction of choice for every corrupt Russian Oligarch who seeks to hide his assets, with the ready assistance of Malta's amoral offshore financial service providers. We are checking to see whether any of the other yachts seized in other European countries, in the grounds of Oligarch ownership, also fly the bloody Maltese flag.
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| The Banner of the Damned |
RUSSIAN OIL TANKERS GO DARK TO AVOID CAPTURE; BOUND FOR OFFSHORE MALTA ANCHORAGE AND OFFLOADING ?
Maritime information companies are reporting that the crews on Russian oil tankers are all disabling onboard tracking devices, making their location and route data. Given the global quest to seize or disable Russian assets abroad, especially those owned by the Oligarchs, this action, which is being widely reported by a number of sources, can have significance for the possible destination of these vessels. This is due to the black market in sales of Russian oil, which has apparently grown exponentially since the invasion of Ukraine.
When the Trump-era Secretary of Defense met with Malta's Prime Minister a while back, one of the items on his wish list was American monitoring of Europe's Dirty Little Secret, Hurd's Bank, international waters just offshore from Malta, where the world's dirty oil transfers furtively occur, in a Black Hole free from international sanctions. Malta's willful blindness about the activities that occur in Hurd's Bank, especially regarding nocturnal visits to that area by Maltese vessels picking up "conflict oil" or sanctioned petroleum products, is part and parcel of the country's rampant corruption regarding energy.
Prior to their disabling locater and tracking devices, some tankers bearing Russian petroleum products were headed toward's Hurd's Bank, and it is suspected that certain of Malta's organized crime elements, who have a long history of illegally relabeling petroleum products for resale, are involved. The question is, will such activities originating in Malta come under international scrutiny, and are they being directed by powerful business forces linked to Malta's Ruling (and exceedingly corrupt) Labour Party, whose connections to Russian oligarchs run deep.
We are continuing to investigate the actions of these "fugitive" Russian tankers, and who has the temerity to launder their cargoes. Stay tuned.
Tuesday, March 29, 2022
WAS BVI COMMISSION INQUIRY REPORT ON CORRUPTION EFFECTIVELY BLOCKED ON BOGUS "NATIONAL SECURITY" GROUNDS ?
Whilst we await the much-anticipated April release of the Commission of Inquiry into corruption in the British Overseas Territory that is know to be the favoured jurisdiction for Russian Oligarchs seeking to hide their ill-gotten assets, there is still no public answer regarding precisely what government documents were redacted on purported National Security grounds. There were two extensions granted to the Commission to complete its work and issue a comprehensive report, reportedly mainly due to dilatory action by government agencies, what material was belatedly produced is said to have been of poor quality, with missing segments, or out of order, and obviously put together in a confusing manner, as if to make the job of the Commission difficult, if not impossible, to properly discharge timely.
Given that both foreign affairs and defense of the islands is specifically reserved by law to the United Kingdom as the sovereign, the excuse of "National Security"can have no factual basis to justify redaction of material. The BWI has no history of external national security threats, but there have been multiple accusations of a relationship between senior and career government officials and organized crime groups. Whether the actions by government to obscure that alleged relationship deserves investigation by an outside law enforcement agency, which could be conduced by the United Kingdom.
Second, given the massive amount of BVI companies known to be owned by Russian oligarchs, due to a complicated multi-part scheme orchestrated by local solicitors that guarantees beneficial ownership remains completely opaque, the question on the minds of compliance officers abroad is whether evidence of bribes and kickbacks, from the Oligarchs, might be revealed in financial documents detailing the assets, meaning Unexplained Wealth.
Whatever the reason that the Commission's efforts met with a roadblock on National Security, it definitely was propounded by Government to interfere with its search for the truth. We trust that its findings of fact will expose corruption wherever it exists in the British Virgin Islands, and result in much needed reform of a beautiful country with dark secrets.
JOSEPH MUSCAT, MALTA'S SON OF PERDITION, STILL HAS HIS EYE ON RETURNING TO POWER
Like Richard Nixon and Donald Trump before him, the amoral Joseph Muscat, once the powerful Prime Minister of Malta, wants desperately to return to the position of power and influence that he gave up when he resigned in disgrace. Whether he can still unseat Robert Abela, from behind the scenes, and take back the throne is the question on everyone's mind in Malta, where justice is only a word learnt in school, and never observed in real life.
Robert Abela falls short of Joseph Muscat at the polls
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| Credit: Times of Malta |
Some sources claim Muscat's forthcoming political move is contingent upon a poor showing by Abela in last weekend's National Election; others assert that, notwithstanding the votes for Abela, Muscat will worm himself back into office, due to his ability to wield raw political power, and banish Abela, because, in Muscat's view, he has not been a loyal disciple. Muscat wants his premiership back.
What will the Members of the European Union think if an unelected leader ascends to the throne, solely through his manipulation of power ? Trust me, they will not be supportive, in this time of pushback against authoritarian leaders. Muscat, and Malta itself, will be viewed as a tinpot dictatorship, where both the Rule of Law and the power of the vote are not only ignored, but completely disregarded.
Picture this: the Holy Father is soon to arrive, and he might be officially greeted by The King of Corruption himself, Filius Perditionis, a deviant who has engineered an illegal return to office. The Man of Sin himself as national leader of Sodom and Gomorrah; we all know that there will not be a Happy Ending to Malta's story.
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| Valletta, 2022, the new Sodom by COSIMO |
Monday, March 28, 2022
SAM'S CLUB LITIGATION INDICATES A PREDATORY CORPORATE CULTURE
Our first article, requesting that the Securities and Exchange Commission (SEC) investigate the repetitive, unlawful and very possibly criminal behavior of corrupt Sam’s Club management, was just the tip of the iceberg.
The million-dollar question, from investors and shareholders alike, is: Why hasn't Sam’s Club terminated the employment of Brenda Caldera, a District/Division manager for one of the club’s largest divisions in the State of California ?
Just a sample of a few obviously preventable lawsuits, as detailed below in Ms. Caldera’s district, demonstrate how incompetent and corrupt her leadership is, which is costing shareholders millions of dollars, and which they are completely in the dark about.
California:
(1) On 11/15/2021 CHARLES WILLIS filed a Personal Injury action {Charles Willis vs. Sam's Club, Inc. et al } Just one more Personal Injury lawsuit against SAM'S CLUB, This case was filed in Los Angeles County Superior Court, Spring Street Courthouse, located in Los Angeles, California. The case is currently pending.
(2) Capstone Law APC, filed a representative action, under the Private Attorneys General Act of 2004, on behalf of current and former non-exempt, hourly-paid employees who worked at a Sam's Club store location in California, and on behalf of the State of California. The lawsuit, entitled Stockman v. Wal-Mart Associates, Inc., et al. is currently pending in the Placer County Superior Court, Case No. S-CV-0041531. The lawsuit alleges the following violations against Sam's Club:
- not paying all overtime wages;
- failing to calculate the regular rate of pay properly, for purposes of paying overtime;
- not paying at least minimum wages for all hours worked (relating to hours worked off-the-clock);
- not providing employees with timely, uninterrupted meal and/or rest breaks;
- not paying employees one hour of pay for each missed meal or rest break;
- not providing employees proper wage statements (pay stubs);
- failing to maintain accurate payroll records;
- not paying wages timely during employment and upon termination;
- failing to pay the time spent for and the costs of mandatory pre-employment physical examinations and/or drug testing;
- failing to pay reporting time pay;
- failing to pay split-shift premiums;
- failing to provide employees with suitable seating; and
- failing to reimburse work-related business expenses.
We believe that these are violations of California’s Labor Code, and we also believe that these violations occurred on a systematic basis to Sam's Club employees.
(3) SAM'S CLUB SETTLES ETHNIC HARASSMENT SUIT FOR $440K
Sam's Club, owned by Wal-Mart Stores Inc, has settled a class action brought against it over allegations of ethnic harassment. The suit was filed by the U.S. Equal Employment Opportunity Commission on grounds that several Mexican employees had allegedly suffered racial slurs.
Sam's Club has agreed to pay $440K to settle the suit, which involved one associate employed in the Fresno, CA store, and who was accused of harassment, and subsequently fired. Nine employees at Sam's Club's Fresno location filed the suit, one of whom is married to a Mexican national.
(4) On March 16, 2020, Marie Taylor, together with some of her colleagues, filed a lawsuit against their California Sam’s Club Retail Warehouse stating that they allegedly failed to pay their employees for the work they had done. This includes the employees’ “off-the-clock” work, due to the security bag searches conducted after their shifts ended. She filed the case in the Superior Court for the State of California, County of Los Angeles. Miss Taylor was employed in Sam’s Club in El Monte, California, as one of their cashiers. Her employment lasted from July 2, 2018, until her termination on November 7, 2019.
This matter was heard in the US District Court of The Northern District of California. Former California cashiers accused Walmart of failing to provide them with seating as they worked. During the Court’s proceedings, Walmart failed to challenge the plaintiffs’ accusations for seating violations. They also made groundless arguments, based on the cashier’s duties, that had been earlier denied by the District Court. After listening to both parties, the Court ordered Walmart to pay compensation of $65 million in damages, which were incurred by approximately 100,000 former and current cashiers in California.
(6) On 04/05/2021 Matsumoto filed a Personal Injury {Matsumoto vs. Sam's Club, Inc.) Still another personal Injury lawsuit against Sams Club Inc. This case was filed in San Diego County Superior Court, Central Courthouse, located in San Diego, California. The Judge assigned to this case is Carolyn Caietti.
The forgoing are just a sampling of all the lawsuits created by unprofessional, criminally minded managers in Brenda Caldera's district in California, who obviously should never have been appointed to positions of supervision, let alone be retained after problems were exposed through employee litigation.
As this series of articles continues, you will read first-hand accounts, from personal knowledge, of honest associates, and some supervisors, all having between sixteen and thirty years’ experience working at the various clubs. Our next article will profile the names of some of Ms. Caldera’s most corrupt, incompetent and sometime racist managers, who should have never been in charge of the company's hard-working employees, or make major financial decisions that affect shareholders. The pattern of corruption and middle management misconduct is not limited to just California,
Stay tuned.
DOMINICA FINDS A BACKDOOR INTO CONTINUING TO SELL RUSSIAN OLIGARCHS CBI PASSPORTS THROUGH TURKEY
If you were paying attention this week you may have seen that the Foreign Minister of Turkey, in a public announcement that was ignored by western media, announced that his country welcomed any and all Russian Oligarchs, including those that have been sanctioned by the EU, US and Canada. He actually invited them to move their obscenely large yachts to Turkey, as it is outside the jurisdiction of the European Union, where sanctions supporting their seizure and forfeiture threaten them.
Why is this important, you ask ? Because at the same time, the leaders of the Commonwealth of Dominica have literally gotten into bed with a major Turkish company that sells its Citizenship by Investment (CBI) passports, met with the company's ownership, and reportedly even visited the company inside Turkey. to further consolidate the relationship. That is Dominica's Prime Minister, Roosevelt Skerrit, with the Mellat Turkey leaders, on the company's Twitter webpage. It doesn't get much closer than that.
Here is there situation:
(1) Turkey opens the door wide for sanctioned Russian Oligarchs, seeking their wealth, notwithstanding that they are international pariah, due to their financial support for Vladimir Putin.
(2) Dominica embraces a leading Turkish CBI passport sales company, and meet with its leadership, abroad.
(3) Dominica, which has a long and sordid history of welcoming Russian Oligarchs, and taking
their Dollars, to sell them the prized passports, which give visa-free access to Europe, stands ready to quietly accept new Russian business (at higher rates, of course, due to the world's condemnation of Oligarchs).
(4) Russians, with aliases, and with their place of birth changed on the CBI passports they buy from Dominica, anonymously enter Europe, with their wealth intact, defeating both the letter of the sanctions law, and the world's efforts to rein them in.
Given the Dominica, reeling politically from the exposure of its recent live affair with Syria, and sale of CBI passports to that terrorist state which supports Russia, has no moral compass, and will sell to just about anybody with USD cash, can one reach any other conclusion ? Perhaps its time for the Western democracies to take a stand against this madness, and teach Dominica something about international responsibility.
Sunday, March 27, 2022
MALTA, ON THE ROAD TO PERDITION
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| Robert Showers Love on the Gahan by COSIMO |
A FEW WORDS FROM THE VOTERS...I CANNOT SAY IT ANY BETTER.
I refuse to congratulate the Party of corruption and vote buying. Not sour grapes, but I have never ever, in my 70 year life, been surrounded by so much corruption, partisanship and blatant vote buying by a regime of autocracy, nay, dictatorial, impunity. Pity poor Malta, and very good luck in convincing the EU that you are a rule of law Government, worthy of release from Greylist and EU prosecutions.
Saturday, March 26, 2022
SHOULD THE UNITED KINGDOM IMPOSE DIRECT RULE ON THE BRITISH VIRGIN ISLANDS IF IT FAILS TO ACT ON RUSSIAN OLIGARCHS ?
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| Flag of the Governor of BVI |
The global furor over Russian Oligarchs, who have been skillfully hiding their assets in British Virgin Islands companies, to conceal their beneficial ownership, has now focused upon the BVI, which has been the offshore jurisdiction of choice, for decades, of individuals who cannot stand the light of day. BVI companies have been the bane of compliance officers, who cannot conclusively determine whether a client, or counterparty, who are sanctioned, might exist, as ownership is concealed from their inquiry.
The United Kingdom is pressing BVI government officials to divest themselves of their Oligarch clients, due to their support of the Russian regime, now engaged in an invasion of Ukraine. Given the reluctance, in the past, of BVI officials, to disclose beneficial ownership of their most lucrative local industry, compliance will most likely run into excuses, or worse, dilatory action. Should the BVI not comply forthwith with UK demands, which are not only lawful, but are in compliance with UK international obligations, it is suggested that Direct Rule is the only reliable solution.
Readers who are not familiar with Direct Rule by the UK may want to read The British Overseas Territories and Direct Rule, by Graham Wheeler, ukconstitutionallaw.org There is ample Constitutional precedent for the United Kingdom to impose Direct Rule upon a British overseas territory; the most recent example was over the Turks & Caicos Islands in 2009-2011. Prior to that was over Anguilla in 1969.
If the BVI, active through its government officials, chooses rot delay, deny or obfuscate UK requirements, the only logical choice may be Direct Rule. We certainly hope that it does not come to such a drastic action, but the UK should be prepared to take that step, if circumstances demand. Otherwise, the goals of the Oligarchs. to place their assets where they cannot be seized and forfeited, will be accomplished, and President Putin's financial supporters will continue to assist his illegal and immoral war.
Friday, March 25, 2022
MALTA HOLDS A SHAM ELECTION: THE VOTES HAVE ALREADY BEEN BOUGHT AND SOLD
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| Abela's Little Crown not Landed yet by COSIMO |
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| Abela and Muscat Assembling the Majority by COSIMO |
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| Awaiting the Returns at Castille by COSIMO |
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| Robert Rewards the Voters by COSIMO |
JUST A FEW OF THE WAYS IN WHICH THE VOTES WERE BOUGHT:
(1) Allowing inmates in the prison to cast their votes, which is an illegal act.
(2) Getting the votes from dementia patients in the nursing homes in Malta.
(3)100 & 200 Euro vouchers sent out to everyone just prior to election date.
(4) Flat screen televisions sent as gifts to voters from sitting Labour ministers.
(5) Giving building permits to persuade the voters in advance of the elections.
(6) Gifts of petrol vouchers sent to voters to guarantee their election support.
(7) Passing out jobs for residents of Gozo to insure they cast their votes today.
MALTA IS NO LONGER A EUROPEAN DEMOCRACY.
Thursday, March 24, 2022
READ THE COMPLETE TEXT OF THE CONDEMNATION OF ROSIANNE CUTAJAR BY THE COUNCIL OF EUROPE
Our thanks to Jason Azzopardi for making it available to the media; we believe this is the only publication that is publishing the complete text of the Findings of Fact in legible form.
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| Hubris by COSIMO |
AMERICANS ARE BUYING UP CBI PASSPORTS: THEY ARE MAKING A BIG MISTAKE
This week, I saw yet another one of those "infomercials, " commercials artfully placed on Internet websites, masquerading as news articles. It's disinformation, readers, because when individuals think that they are clever in acquiring a document attesting to a second nationality, they unwittingly are complicating their lives; Here's why.
1. A CBI passport, the vast majority of which are issued by the five East Caribbean states ( St. Kitts, Antigua, Dominica, St. Lucia and Grenada) and Malta, paints a bulls' eye on the back of the recipient. Why, you ask. All of the aforementioned countries are, or have been, tax havens. This means that tax cheats, white collar criminals, corrupt foreign government officials, and other dodgy individuals also have bought one at the same jurisdiction where you purchased yours. Don't you think that makes all such holders of interest to the world's law enforcement agencies, who are tasked with enforcement of their country's criminal laws, especially money laundering ? Do you really want to be placed in the same category as those career criminals, and possibly new subject to luggage searches when you travel, or having your passport photocopied, and perhaps even questioned at length ? I doubt it.
2. The CBI passport doesn't really give you visa-free entry to countries that you are most likely to visit, in Europe for example, or in the English-speaking world. Why did you spend all that money to purchase it ? As a status symbol, perhaps. You cannot easily use it to enter the United States, and you will certainly invite serious scrutiny if you attempt it; you will need a visa; how are you going to pull that off at a US embassy abroad, as they will find out immediately who you are, a US citizen.
3. All the supposed reasons the articles state are bogus; America's political turmoil, the desire to travel anonymously and low profile, ease of entry as the holder of a passport from a Commonwealth of Nations jurisdiction passport, none of the slick reasons proffered are valid.
4. Given that the nations issuing those CBI passports generally do not follow either the Rule of Law, or Due Process, your visits to your adopted country could actually result in your illegal detention, the levy of a fine or civil penalty, if you are operating a business there. without any legal redress. You may also be the victim of injustice when you suffer a loss, or are a victim, as the result of your contact with a local citizen or company, especially if it is closely aligned with the ruling party in power. And by the way, the local jurisdiction can cancel your passport, and citizenship, for a variety of reasons, in a ruling that you cannot appeal from.
5. The US isn't about to let you off the hook on taxes, either. Americans must pay income taxes on their worldwide income, and try to give up your US citizenship; it's a landmine of complicated tax issues that you do not want to navigate.
All the polished sales techniques of the international CBI consultancies aside, you do not want to buy a potential carload of issues that you did not anticipate when you took possession of that shiny new passport. Remember, these consultants are not your lawyers; they do not dispense legal advice to you, and their sole motivation is a large commission. Avoid them, and the purchase of a CBI passport, as a educated consumer who rejects unsuitable purchases.
Wednesday, March 23, 2022
MALTA's PRIME MINISTER ROBERT ABELA, AND HIS CABINET, IGNORED BANK OF AMERICA'S OFFER OF ASSISTANCE IN UPGRADING AML/CFT WHEN FATF SANCTIONS THREATENED
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| Robert, the Almost King by COSIMO |
Could the FATF Greylisting of Malta have been prevented by the Labour government ? That is the question many in the country's financial services industry have been asking, and new information, that has come from a source inside government, indicates that there may have been a way to avoid it.
We are advised that Bank of America, by and through its Chairman, Brian T. Moynihan, made an offer, directly to PM Robert Abela, at the end of 2020/beginning of 2021, to help Malta improve its Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT) policies and procedures, in order to bring them up to acceptable international practices.
At the time, Malta had been previously adequate given advance warning, by the FATF, that, should the country not raise its AML/CFT levels, it would be placed upon the Greylist. Specifically, Malta was to ramp up its compliance and regulatory capacity, and improve the legal framework and function of the financial & banking sector; there was also a lack of enforcement of anti-money laundering laws.
The BOA offer was made directly through the Office of the Prime Minister, through its Chief of Staff, and direct line telephone numbers were offered to initiate contact. The offer was also conveyed to then-Deputy Prime Minister Chris Fearne, and to the Ministry of Finance as well. Although the offer was made repeatedly, and followed up by BOA staff, no reply was ever received by the bank, and no contact, telephonic or otherwise, was ever made by government officials.
You know the rest of the story; Malta was subsequently and very publicly Greylisted by the Financial Action Task Force, with lasting reputational damage throughout the European Union, as it was the first EU Member to suffer such a designation. The global financial world outside of Europe also governed itself accordingly, and there has been lasting reputational damage to the country's economy.
While there is no guarantee that government cooperation with BOA would have delayed or halted the FATF Greylisting, the failure of Robert Abela to engage is :
(A) Symptomatic of his administration's isolationist policies.
(B) Irresponsible, given that over 100 financial firms have left Malta since Greylisting, along with the jobs those companies represented, and tax income. The exodus of financial services-licensed firms has been widely reported in international media.
(C) A Cause for Concern: why would Abela not want assistance from the world's biggest bank, given Malta's endemic issues with capacity, and its reputation for corruption? A possible answer: BOA assistance would most likely have uncovered rampant money laundering and corruption, and identified senior members of the present, and former government, including the recipients of the bank's offer.
Maltese businessmen, who have been busy blaming the United States for the Greylisting, need to look closer to home when assigning the real blame for this debacle, which should have never been allowed to happen in a nation whose primary industry is financial services. Think about it when you cast your vote this week.
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| Robert, Making it Clear by COSIMO |
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HOW MANY DOMINICA SHELL COMPANIES HELP SYRIA EVADE GLOBAL SANCTIONS ?
The disclosure that three Syrian shell companies, and the frontmen who assist Syria's sanctioned President Bashar Al-Assad in evading global economic sanctions, as a Designated State Sponsor of Terrorism, raises the obvious question: given the previously-identified issuance of Dominica CBI passports to Syrian PEPs, how many Dominica corporations have also been employed to aid and abet Syria, in violation of international law ?
It is suggested that the prominent Dominica law firms who also act as CBI consultancies, and are close to the regime of Prime Minister Roosevelt Skerrit, would be the most likely bad actors to have formed those shell companies, set up complex corporate ownership structures to prevent exposure, and made them available to the Syrian PEPs who were existing clients.
Inasmuch as corporate formation for Syrian nationals would bring a premium price, and since US Dollars are the currency of the CBI programmes, any large deposits abroad by those Dominica law firms, or through immediate family members, are themselves sanctions violations, as well as money laundering, compliance officers at international banks should examine client lists to determine whether their banks unwittingly accepted the proceeds of crime.
Given Syria's imminent recent exposure as a supplier of troops to assist the Russian Federation in the Ukraine Invasion, any international bank later found to have facilitated Syrian sanctions evasion, in any way, even unwittingly, risks massive regulatory action, including OFAC sanctions, or denial of access to the US financial structure, which would generally be fatal to a bank's operation, it would be prudent for compliance officers to initiate a robust inquiry of any possible existing accounts of Dominica lawyers, or their immediate family members.
Three Shell companies are being used to help the Assad regime and embargoed entities with links to it avoid western sanctions
Shell companies are being used to help the Assad regime and embargoed entities with links to it avoid western sanct
Shell company(Black)
Company under sanction(Red)
Existing company(Blue)
Individual under sanction(Red)
1.Generous
2.Trappist
3.Super Brandy
All jointly owned by frontmen:
Rana Ahmad Khalil
Ali Najib Ibrahim
Rita Ahmad Khalil
Daughter of Ahmad
Part-owns
Daughter of Ahmad
Tele Space
Part-owned by
Ahmad Khalil Khalil
who part-owns:
Sanad Protection
and Security
Services
Wafa JSC
Part-owned by
Yasar Hussein Ibrahim(Advisor to Al-Assad)
Partner
Nasser Deeb Deeb
Adviser to
Co-owns
Ella Services(Sanc)
Syrian President(Sanctioned)
Co-owner
Bashar al-Assad
Khodr Ali Taher
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