Sunday, October 30, 2022





The British alone have a word for it: TRADECRAFT, the actual nuts-and-bolts trade secrets in any profession, that are employed successfully in the field, and not known to the public. In the world of money laundering, it is tradecraft that beats compliance officers every time, whether it be a technique or tactic unfamiliar to legitimate bankers, an esoteric (known to only a privileged few) practise that nobody teaches at AML/CFT conferences and lectures, or a permutation of an existing technique that renders it invisible to conventional check-the-box compliance due diligence. Whatever it is, it invariably works.

Two years later, when your bank is visited by law enforcement, bearing a subpoena, you ruefully find out to your chagrin that a money launderer ran a technique right over your department, and you failed to identify it in real-time, and were unable to interdict the transfers as gatekeeper. This can have a negative effect not only on the compliance department but could result in ccivil penalties, and negative press, especially if criminal indictments result, and your bank in named as one of there funnels for the laundering. it can also cause you to lose face with senior management, which could have career implications, none of them good.

Therefore, start learning about obscure money techniques; learn to understand the money launderer's perspective, how he or she thinks and acts; how they disguise their operations, to hide in plain sight, and most importantly, how they are adept at innovation, modifying their techniques own the fly. If you need further details, ask yours truly or someone else who has actually done these things, not some professional AML lecturer, and start learning how to catch money launderers in the act.


I'm in Control Here by COSIMO

In an unsurprising turn of events, Maltese media has exposed what appears to be a third major scandal involving the payment of substantial disguised bribes, paid to former Malta Prime. Minister Joseph Muscat since he left office in a cloud over allegations of corruption, and involvement in homicide. A major local developer, who has benefitted greatly from a number of favourable decisions regarding acquisition and construction projects, involving prime properties, has reportedly gifted Muscat with substantial "consulting fees" that have now surfaced. he has admitted making the payments.

Claims that JM has ably assisted the developer with his "understanding" of the Maltese economic picture are a joke; Joseph Muscat has neither the education nor experience to aid anyone in understanding the opportunities presented from an economist's perspective, or has he ever held himself out as such during his career. The money paid to him is obviously disguised payback for political favours allegedly done whilst JM was PM, nothing more. He is not the only one who has benefitted, in a country drowning in official corruption.

Payments made to present or former government officials, in furtherance of corrupt activities, which are the Proceeds of Crime often end up in bank accounts, exposing both the banks and the bankers involved in accepting them to criminal charges in multiple jurisdictions, as those bank rarely, if ever, obtain evidence of both Source of Funds and Source of Income from Political Exposed Persons (PEPs) that they allow to be depositors. As many financial institutions in Malta are guilty of such conduct, compliance officers at major banks in the European Union should govern themselves accordingly, when assessing risk levels in accepting substantial funds transfers to or through them from Malta. 

Saturday, October 29, 2022



Can Joseph Muscat return to power, like Nixon did?

Malta watchers have made much of Joseph Muscat's distancing of himself from his old partner in crime, Keith Schembri, and have been wondering aloud whether Muscat is on mission to launder his unsavoury reputation, and is separating himself from his Labour cronies, whilst he reinvents himself. Whether Schembri, who is still facing criminal charges, and has intimate knowledge of Muscat's darkest deeds, will allow the disengagement is unknown, but assume it goes off without a hitch, with all the old guard of Muscat's Merry Men of Mischief.

 Known to be a student of history, is he perhaps modeling his comeback on the life of the American President, Richard Nixon? After all, Nixon's career was stained by dirty political tricks, and behind-the-scenes misconduct and even criminal activities, such as Watergate. If so, he is missing one of the most important lessons of our history, as there are limits to being the comeback kid, as Nixon learnt to his chagrin and dismay. Even when you win, your actions can be so counterproductive that you ultimately draw a losing hand.

Nixon, who lost the 1960 Presidential Election to John Kennedy, and thereafter a subsequent election for Governor of the State of California, was though by many to be finished politically, but he engineered his nomination for the presidency in 1968, and was elected. Is that Muscat's agenda, to rehabilitate his image over a period of time, and then stage a comeback, replacing Robert Abela, who replaced him, as the next Prime Minister? Stranger things have happened in politics.

Here's why Nixon makes a poor model for Muscat; ben when he was able to get back on top, he could not help himself, he eventually placed himself back on the outside, through resignation to avoid impeachment, and his subsequent efforts for a second comeback fell on deaf ears. he spent the last twenty years of his life in exile, not exactly in obscurity, but close to it. 

Someone needs to tell Mr. Muscat that, even if he manages to reenter politics, and succeeds in returning to power, his lack of conscience will eventually lead to his banishment, again, from which he will not be able to recover. His lack of character will bring him down every time, and the next time it will be much harder.



Pilatus Bank "Something Wicked this way Comes."

The Maltese reformist organization OCCUPY JUSTICE has graphically illustrated the country's rampant corruption, and venue as a Mecca for money laundering and financial crime by placing a giant illuminated spider's web in front of the building that served as the global headquarters of there now-closed Pilatus Bank, which was a hotbed of money laundering and sanctions evasion until shut down by the EU.

Occupy draws our attention to the fact that none of the five senior directors and officers of Pilatus Bank have been arrested, notwithstanding a magistrate's findings of fact incriminating them on money laundering charges, and requiring the Attorney General and the Malta Police to make arrests. The close connection between these individuals and Malta's resigned Prime Minister, Joseph Muscat, the local Il Duce, who though out of office still controls Malta's institutions, has resulted in a major miscarriage of justice, with no resolution in sight. Malta's directors remain free to commit new financial crimes abroad.

Occupy Justice logo

Given that the Pilatus money laundering machine moved (and cleaned) the Proceeds of Crime into and through the United States, the United Kingdom, and the Members of the European Union, the officers and directors should be facing justice in all three jurisdictions, but thus far, they have been able to commit transnational crimes with total impunity, allowing Malta to thrive as the EU's very own Banana Republic. Whether justice will prevail remains an open question. 

Friday, October 28, 2022


Ali Sadr Hashemi Nejad, Claude-Ann Sant Fournier and Antoniella Gauci

ANTONIELLA GAUCI, the former Money Laundering Reporting Officer (MLRO), Accounting Officer and Risk Manager for the closed Pilatus Bank, shut down by the European Central Bank for massive money laundering, is single, unemployable, and extremely wealthy. Gauci, as we have previously reported in NGO says Malta's Attorney General Signed Secret Dismissal of Money Laundering charges in Pilatus Bank Case (October 24, 2022) is suspected of being one of the two senior Pilatus executives that is the Attorney General secretly ordered not charged with money laundering crimes, notwithstanding a magistrate's order for her indictment.

She is known to have been the subject of a special personal demand, made by former Maltese Prime Minister Joseph Muscat, that her name be removed from any possibly of prosecution. Readers of our coverage may recall that Gauci was literally caught in the act, by a team of video journalists, removing evidence from Pilatus Bank, in the dead of night, in the company of Pilatus Bank owner, the Iranian national, Ali Sadr Hashemi Nejad. She literally ran away from the cameras, towards her automoble, refusing to be interviewed, in an incident that has forever enshrined her as the face of Maltese corruption and financial crime.

The documents removed from the Pilatus safe by Gauci are believed to include corporate documents from the offshore Panamanian corporation, EGRANT, which the whistleblower, former Pilatus employee Maria Efimova, swore contained proof that MICHELLE MUSCAT, the wife of the disgraced former Maltese PM, was the Beneficial Owner of the company, which reportedly received bribes and kickbacks intended for JM.

Reliable sources within Malta's ruling Labour Party have asserted that Gauci had threatened to publicly reveal all the details about Egrant ownership, as well as the transfer of documents to her car with Sadr in the middle of the night. As the result, our sources report that she is being regularly and repeatedly allegedly paid for her silence. Given her notoriety. Gauci represents a huge potential liability, and nobody in Malta's financial industry is willing to employ her.

Whether Gauci is ultimately charged with money laundering by an American criminal court is a question on the minds of many in the European Union, given that Pilatus was involved in the transfer of many millions of US Dollars from Venezuela, remains an open question. Stay tuned.  


When I went to law school, I was fortunate enough to be taught by some of the giants in legal scholarship. One of those was Professor Hugh Sowards, whose treatises and casebooks can still be found in the libraries of America's law firms involved in the practise of Securities Regulation. Sowards, who was at one time a serious contender to head the Securities & Exchange Commission, would most certainly be weighing in on the controversy over whether cryptocurrency is a security or a commodity, were he still among us. Does crypto meet the classic Howey-in-the-Hills* test for determining if it is a security, and therefore subject to SEC regulation and registration?

The contest between the SEC and the Commodity Futures Trading Commission (CFTC) has not as yet been resolved, but in the meanwhile,  we must win our readers that, for the most part the crypto industry gets a failing grade, when it comes to compliance. The vast majority of crypto vendors either have no AML/CFT programme, or purport to maintain one, although it is ineffective or completely bogus. Sellers of crypto are simply not doing due diligence upon their customers before onboarding them, taking advantage of the fact that the industry is not yet adequately regulated.  I don't see any compliance on the cryptocurrency trading platforms I have observed, with rare exceptions.

The problem is, if there is not a speedy resolution to the SEC-CFTC dispute, we can only estimate how much dirty money will be cleaned through cryptocurrency. Right now, it's open season for professional money launderers, to be sure. If you are a bank compliance officer, and your crypto clients have not shown you an effective, and actually operational, compliance programme is in place, you are violating banking best practises, regarding your risk-based operation. Don't be facilitating financial crime because of the glamour of a new class of clients in a new industry; watch yourself here.

It is humbly suggested that those cryptocurrency firms reading this article on LinkedIn contact those professionals who have reported online on cryptocompliance to assist them in creating an effective programme.


*S.E.C. vs. W.J. Howey Co., 328 U.S. 293, 66 S.Ct. 1100 (1946). 

Wednesday, October 26, 2022


I wonder how many bankers have heard of Albert vs. Association of Certified Anti-Money Specialists, 18-CV-05464 (ND GA), where a compliance officer sued, under Federal laws regarding the rights of the handicapped, regarding the conditions under which his examination for AML certification should be relaxed and modified for the plaintiff, who is learning-disabled. We are all aware that, at the university level, students with disabilities are given additional time to complete exams, and/or other benefits not available to others.

This is not a argument against such practises, which do effectively level the playing field, but the case involves a professional certificate, which could make the difference whether an individual is later hired, or not, as a compliance officer. My point is that compliance officer is a frontline, not support, position, where money launderers and financial criminals are constantly attempting to commit crimes through the bank, and not is up to the compliance officer, as the gatekeeper, to identify them in real-time, and interdict that dirty money, inn transit whenever possible. The job is not for anyone who is not at the top of their game, and is painfully aware that they work in an extremely time-sensitive environment, with little room for error. Speed of operation is a key element of compliance success; you've gotta be fast to meet deadlines.

If you don't have the best skills, and are always fast on the draw, you will probably miss that sole suspicious transaction, or transfer inconsistent with the client's trade or business, or obscure regulatory change, with the result that your bank or brokerage house passes a money laundering transaction, and faces possible civil penalties, negative publicity, or even a major regulatory hit. 

These frontline compliance positions are the combat roles, defending and protecting the bank's reputation, and sometimes even its future. They must be filled by the best, most competent people you can find, and anyone who might not be as sharp, represents a potential failure that doesn't have to happen. Put your best compliance people up front, please, and give support roles to those others who might not be, allowing them to provide valuable services in a secondary role. In the military, we call that combat support, and they are as necessary to your operation as frontline staff, but make sure you have everyone in compliance properly placed.

Tuesday, October 25, 2022



Robert Mitchell, from Riskscreen, has posted his personal list for profiling Politically Exposed Persons (PEPs) that compliance officers will find instructive; he calls it "TIGHT."and I highly recommend its use: 

  1. 'T’ – the Type and extent of any interactions the PEP has with officials. You need to employ identification using a world-class database such as Dow Jones or Refinitiv World-Check. In addition, ask lots of questions to discover who they are and see if there are any adverse media associated with them? Find out how did they got to their position, how they earned so much money, and what is their source of funds? 
  2. ‘I’ – the Industry that earned the PEP their money. You also need to include any family members or business associates that are linked to the PEP. Keep a special look out for higher risk sectors such as Mining, Hydrocarbons, Armaments, Telecoms, Construction, Water Resources, Healthcare, Railways, Construction etc.  
  3. ‘G’ – the Geography and jurisdictions involved. Most PEPs who have been investigated for illegal financial activities come from corrupt countries. As a result, pay close attention to PEPs in countries that sit in the lower quartile of Transparency International’s Corruption Perception Index. 
  4. ‘H’ – the History of the PEP. Has the PEP, or the introducer or any family members, had any previous allegations made against them? Find out if there have been any public compliance failures at the businesses involved in the transaction, if there have been any previous wrongdoings or internal controls issues, or if their lawyer has been under investigation by the Solicitors Regulatory Authority? 
  5. ‘T’ – the Transaction. Examine the details of the transaction and all the parties involved – the beneficiaries, trustees, lawyers, advisors and even the agents. 

Using these five steps, you can more accurately monitor and remediate PEP risk – before it becomes an issue. Our thanks to Rob for making it available to all on the blog.


                                                               OJ comes to Malta?

The Shift News has exposed the fact that Malta's defrocked former Prime Minister, Joseph Muscat, has formed a new consultancy, which he has named OJmed Limited. Poor choice of words, perhaps? In any event, when individuals who are not lawyers create consultancies in Malta, it is usually so they can use them to disguise the receipt of bribes & kickbacks that they are due in the European's Union's most corrupt  Member state.Which one is it, Joe? Is the company to be the recipient of medical kickbacks, perhaps? Check out the name of the lawyer who formed it, and you may have your answer.

Look at Muscat's track record; after being drummed out of the premiership, he mysteriously starts receiving "consulting payments" from abroad, especially from jurisdictions known to be opaque when it comes to such minor details as Beneficial Ownership.  Does anyone from Malta call him on this, other than some minor items in Malta's self-censored establishment press? Outside of the reformist NGOs, who are the Conscience of Malta, his ill-gotten gains are soundly ignored. No wonder he is doubling down by forming a new entity; he believes that he can act with impunity in his little domain.

Credit: the Shift News

Can someone tell me what Malta-based bank has has opened accounts in the name of OJmed, please so that I can notify OFAC and FinCEN, because it is most likely that some American businessmen are going to be sending US Dollars there, and violating our Foreign Corrupt Practises Act (FCPA) in the process?

Monday, October 24, 2022


Robert Aquilina, the president of Malta's reformist organisation REPUBBLIKA, has asserted in a public announcement that his country's Attorney General, Victoria Buttigieg, has executed a classified document ordering that criminal indictments ordered filed against two senior Pillatus Bank officers and directors be  dismissed with prejudice. Aquiline demanded that the document, which he labeled has been illegally designated Top Secret, be made public, and that Buttigieg resign in disgrace forthwith.

 The order, which was reportedly executed by the AG several months ago, explains why she has refrained from moving forward in the Pilatus case, notwithstanding massive public unrest over her inaction to date. Buttigieg has been accused for blindly following the directions of Malta's disgraced former Prime Minister, Joseph Muscat, who is reportedly linked to bribes and kickbacks that allegedly passed through Pilatus Bank, into his hands, and those of his close associates in the Labour Party. 

Whilst we  have not yet learnt the names of the two persons identified in the document, Malta court observers believe that they are ALI SADR HASHEMINEJAD. the Iranian chairman of Pilatus Bank's board of directors, and ANTONIELLA GAUCI, Chief Risk Officer, acting MLRO and Accounting Officer.


GAUCI has deep knowledge of EGRANT transactions, and was threatening to uncover everything on Egrant, including the transfer of documents in her car with Sadr in the middle of the night. Joseph Muscat personally pushed for her name to be removed from prosecution.

 We are endeavoring to confirm this information from our sources, as well as from other individuals who may have have seen the original AG document, in the performance of their official duties. Calls for AG Buttigieg to resign her office for malfeasance and corruption are likely to increase as the direct result of public knowledge of the existence of this document, which is a major breach of her oath to administer all lawful orders of Malta's judiciary.

Sunday, October 23, 2022


A New York Times journalist, in search of an elusive American billionaire known for his support of far-right politicians, including Donald Trump, stumbled upon the sordid reality of Malta's IIM (Citizenship by Investment) programme recently. His article, In Malta, a Door Knock Brings a Lead,  proves that not only is the residency requirement totally bogus, but the participants actually rent out their mandatory residence to others. In this case, it actually was a fully functioning Airbnb vacation home, supervised by the applicant's Maltese attorney. The journalist actually encountered the temporary tenant in person.

In truth and in fact, the applicant, American billionaire, Peter Thiel, was not really living in that "two-bedroom apartment, in a sightly rundown building, surrounded by beer cans, " to quote from the article, which appeared today on page two of the NY Times. Given that the story appeared in the Sunday edition of our country's most popular newspaper, considered to be the newspaper of record here, which is routinely purchased and read by Americans all over the nation, as they regular weekend required reading, millions of American decision-makers will learn today that Malta's IIM programme is full of legal holes, and should be given a wide berth. After reading the above story, the glossy PR articles being published of late touting the Maltese passports, placed by a major international citizenship consultancy, which has targeted affluent ultra high net-worth Americans, will most likely be totally ignored,

Malta, the cat, as we say, is definitely out of the bag. Your flawed CBI programme has been exposed.



Saturday, October 22, 2022


If you have been following our coverage of the Alex Saab Moran money laundering case, and the efforts of Saab's team of attorneys to extricate their client from a potentially long prison sentence, you may be interested in those development, his lawyers' plan to take sworn videoconference testimony, in support of his defence, in the Bolivarian Republic of Venezuela. 

We wonder aloud whether any of the defence witnesses fear that they have sealed indictments on file against them, which could result in their arrest should they arrive in the United States, or that they are concerned about assassination from anti-regime exiles living in America.

Inasmuch as much of what the defence does pretrial in a Federal criminal case is not publicly available, we though you m might like to read the attached filing, which spells out, in specific detail, the conduct of counsels' upcoming Venezuela activities. 

Friday, October 21, 2022


Joseph Muscat and Michelle Muscat

Malta simply cannot free itself from the systemic corruption that infects all its major court proceedings. The State Advocate has announced that there government is seeking leave to appeal the decision of the Constitutional Court, removing the Magistrate Judge Nadine Lia from a case involving Pilatus Bank, whose officers and directors have been accused of massive money laundering operations, on the grounds of Conflict of Interest. Judge Lia's attorney father-in-law, Pawlu Lia, has represented former Prime Minister Joseph Muscat, who was closely linked to Pilatus' Iranian owner, and to the alleged receipt of bribes and kickbacks, in connection with the approval of the bank's charter, and its criminal conduct.

It is a basic principle in Common Law jurisdictions that a judge must recuse himself or herself if there is even the perception of impropriety, which includes evidence of Conflict of Interest. After Lia declines to withdraw from the Pilatus case, Maltese NGO Repubblika filed an action seeking her removal, which was granted by the Constitutional Court. Whilst we supported her removal as perhaps a small step towards adherence to the Rule of Law, rather than there usual corruption, we now see that Malta's corrupt leadership has struck back, seeking to maintain its ironclad control over the judiciary, in order to protect the guilty, at the highest level. The efforts to reverse the reassignment of the Pilatus Case, on purely technical, or procedural, grounds are without legal merit, and just one more fatal effort by corrupt leadership to control the courts.

If Magistrate Lia is returned to preside over the Pilatus Bank case, then there will be no justice for the people of the Republic of Malta; the guilty will never be held to account for their crimes and transgressions.

Thursday, October 20, 2022


H. whereas the Maltese anti-corruption investigative journalist and blogger Daphne Caruana Galizia was assassinated in a car bomb attack on 16 October 2017; whereas she was the target of harassment and numerous threats in the form of threatening phone calls, letters and text messages, as well as an arson attack on her house; whereas the self-confessed hit man testified in court on 16 March 2021 that two years before Daphne Caruana Galizia was murdered there was a previous and separate plot to assassinate her using an AK-47 rifle;

I. whereas the murder investigations led by the Maltese authorities and assisted by Europol have led to the identification, arraignment and ongoing trial of several suspects and one of the potential masterminds behind the murder, the owner of the Dubai-based company 17 Black Ltd. and former member of the Board of Directors of ElectroGas Malta Ltd., responsible for generating the majority of Malta’s electricity, who was arrested on 20 November 2019 in an apparent attempt to escape Malta; whereas the United States Federal Bureau of Investigation was also involved in the investigations;

J. whereas the United Arab Emirates (UAE) was used to conceal transactions allegedly linked to corruption that Daphne Caruana Galizia was exposing at the time of her assassination;

K. whereas the Dubai-based company 17 Black Ltd. was listed as a company from which Panama-based companies owned by the former chief of staff to the former prime minister of Malta and by the former minister for tourism, formerly the minister for energy, were set to receive funds; whereas links between 17 Black Ltd. and numerous public projects in Malta continue to be exposed;

L. whereas the chief of staff to the former prime minister of Malta and the former minister for tourism, formerly the minister for energy, and their families have been designated by the US Department of State due to their involvement in significant corruption and have thus been barred from entering the United States;

M. whereas Pilatus Bank was exposed by Daphne Caruana Galizia as being the bank of choice for suspicious transactions involving Maltese and Azeri politically exposed persons; whereas Malta’s police commissioner publicly declared in August 2020 that charges against those involved in criminal activity at Pilatus Bank were imminent; whereas 26 months later, charges have only been brought against one person and investigations appear to have stalled; whereas those implicated were allowed in and out of the country freely despite arrest warrants having been issued; whereas a former compliance officer at the Malta Gaming Authority was allowed to leave Malta while travelling on holiday with the former prime minister of Malta despite a European arrest warrant being in force against him, and was subsequently apprehended on arrival in Italy;

N. whereas two partners at Mossack-Fonseca-linked firm Nexia BT, now defunct, exposed by Daphne Caruana Galizia and the Panama Papers as having designed the money laundering structures to facilitate corruption, have been charged for only some of the allegations made against them, excluding the ElectroGas scandal;

O. whereas the liquefied natural gas security of supply agreement between ElectroGas Malta Ltd. and the Government of Malta, signed by the former minister for tourism, who was at the time, in 2015, the minister for energy, was kept secret for years and only exposed in September 2022 by the Daphne Caruana Galizia Foundation and a media outlet; whereas the current attorney general has been criticised for facilitating the signing of this contract without any further approval from cabinet or parliament in her former role as deputy attorney general; whereas at the time of her assassination, Daphne Caruana Galizia was investigating a large cache of internal documents from ElectroGas Malta Ltd.;

P. whereas one of the alleged accomplices and certain recordings exhibited in court proceedings have implicated the former chief of staff to the former prime minister of Malta in the planning and funding of the murder; whereas he was arrested and charged with money laundering, fraud, corruption and forgery on 20 March 2021 in a separate case, which was the subject of Daphne Caruana Galizia’s work, along with several of his business associates;

Q. whereas a public independent inquiry into the murder of Daphne Caruana Galizia was initiated in late 2019 and concluded on 29 July 2021; whereas the board of the public inquiry published a report with a set of conclusions and recommendations on strengthening the rule of law, the respect of press freedom, freedom of expression and the protection of journalists, on legal reform at constitutional level, and on legislative proposals regarding media freedom; whereas the Board also established that ‘whilst there was no evidence that the State as such had any role in the assassination of Mrs Caruana Galizia, (...), the State should bear the responsibility for the assassination by creating a climate of impunity, generated from the highest levels at the core of the administration at Castille[5] and spreading its tentacles to other entities such as regulatory institutions and the Police which led to the collapse of the rule of law’;

R. whereas the Government of Malta has proposed a number of reforms to address some of those recommendations, including draft legislation to strengthen media freedom and a proposal for an anti-SLAPP law; whereas the reforms of the Maltese justice system that started in 2020 have continued to be implemented;

S. whereas the latest Media Pluralism Monitor rated the overall risk to media pluralism in Malta as ‘medium’, but rated the risk for editorial autonomy and political independence as ‘high’;

T. whereas Maltese news outlet The Shift News has been faced with 40 separate legal appeals from public authorities against freedom of information requests concerning public expenditure vis-a-vis the independent media;

U. whereas the judicial reform undertaken by Maltese authorities was mentioned in the 2021 State of the Union speech;

V. Whereas the Committee of Experts on the Evaluation of Anti-Money Laundering Measures and the Financing of Terrorism (Moneyval) has acknowledged Malta’s significant progress in the level of compliance with the Financial Action Task Force Standards, deemed Malta to be compliant and removed Malta from the grey list after 12 months;

W. whereas in its mission report following the visit of the LIBE Delegation on the Rule of Law to Malta from 23 to 25 May 2022, the Democracy, Rule of Law and Fundamental Rights Monitoring Group of Parliament’s LIBE Committee expressed concerns over the slow progress in the follow-up to the murder of Daphne Caruana Galizia and the implementation of the recommendations by the public inquiry, among others, while recognising that the judicial proceedings are still ongoing;

1. Pays tribute to Daphne Caruana Galizia five years after her assassination and to her essential work in exposing corruption, organised crime, tax fraud and money laundering, and in holding those involved in such illegal activities accountable; strongly condemns the criminalisation of, attacks on and killings of journalists for doing their job, including the killings of Ján Kuciak and his fiancée Martina Kušnírová on 21 February 2018, 


ALEX SAAB MORAN's "dream team" of experienced American attorneys has filed an extensive Motion to Dismiss for their client, in a direct challenge to the position of the US Department of Justice on Moran's status as a diplomat from Venezuela. The issue is whether an international money launderer for a rogue state can evade accountability for his crimes by claiming Diplomatic Immunity, when that status is contested. The case, which was remanded back to the District Court from the Fifth Circuit, has proven to be one of great public interest. Can an individual accused of being a sophisticated white collar criminal shield himself through what the United States considers bogus diplomatic status?

Saab's massive (39 page) Motion to Dismiss, with 43 exhibits and 5 attachments, seeks to extensively document his diplomatic status through a large number of affidavits, mainly from Venezuelan sources, which may render them suspect, and which purport to establish a long track record as a "Special Envoy" to the Government of Venezuela. Defence counsel clearly has documented, or possibly created, extensive evidence in support of their motion, leaving to the Court to sort out the truth and accuracy of their information.

 The defendant is charged with being a major transnational money launderer, who allegedly moved and cleaned many millions of US dollars for a wide variety of clients, many of whom were senior Venezuelan officials, and corrupt Politically Exposed Persons ( PEPs) acting on their behalf, including the laundering of narco-profits. It appears that he originally sought to settle, and mitigate, his exposure through an arrangement with US law enforcement, but he later reneged upon the agreement, and here seeks immunity from prosecution.

When the Department of Justice and the US Attorney's Office in the Southern District responds on the merits of the motion, we shall details their position on this blog; stay tuned.

Wednesday, October 19, 2022



NADINE LIA, the magistrate assigned to the criminal case in Malta involving senior officers and directors of Pilatus Bank, which has been accused of being a massive money laundering operation for its Iranian owner, has been removed from the case, after a Constitutional Court held that she should be removed and another magistrate assigned. She had previously refused to step aside, but the Court, establishing what it referred to as inconsistent judicial behaviour, reassigned the case.

This came after Malta's most prominent reformist non-governmental reform organization, REPUBBLIKA, had sought her removal from the Pilatus Case, on the grounds of Conflict of Interest. Lia's father-in-law, PAWLU LIA, is an attorney who has represented the disgraced former Prime Minister, Joseph Muscat, has been the legal counsel for the ruling Labour Party, and was involved in the inquiry regarding the Egrant offshore corporation scandal, which involved Pilatus Bank. 

After Judge Lia rejected prior pleas to recuse herself from the case, although she had taken such action in other proceedings, Repubblika filed its action in the Constitutional Court which, speaking through Judge Ian Spiteri Bailey, determined that the case was to be reassigned, in a 41-page opinion which discussed all aspects of the issue and the law.

Whether this ruling is indicative of a movement toward reform of Malta's flawed court system will depend upon whether we begin to see the Rule of Law actually followed in future decisions and opinions. Only time will tell; Repubblika's action did, however, bring a decisive response from the Court.

Tuesday, October 18, 2022


Since 1982, When the Foreign Minister of St. Kitts & Nevis, WILLIAM HERBERT, created the first Citizenship by Investment (CBI) passport programme, which allowed foreign nationals to acquire Kittitian citizenship, complete with travel document, I have been covering the pattern of abuse of CBI by transnational financial criminals, terrorist financiers, and especially corrupt Politically Exposed Persons (PEPs). The clear and present money laundering dangers that they present to the world's financial community have been the subject of many articles on this blog. 

There is another category of victim, however, that is rarely mentioned: the legitimate applicants for such passports, who represent the vast majority of individuals who acquire them, either to facilitate visa-free global travel, or to avoid the stigma of being from a high-risk jurisdiction, or for valid tax planning reasons. These people deserve to know the negative aspects of using CBI passports in international travel and commerce, and we present herein a number of them, in the hopes that they will become more knowledgeable and educated consumers of CBI products. Consider this a legal "Look Before you Leap," if you may.

1. MOST APPLICANTS DO NOT CONDUCT DUE DILIGENCE ON THE JURISDICTION THAT IS ISSUING THE CBI PASSPORT. Unfortunately, most individuals who apply for CBI passports do not retain independent legal counsel before proceeding. Whilst a number of the individuals at the various CBI consultancies are indeed attorneys they do NOT represent the applicants; in fact, they are generally paid a lucrative commission on all sales which they close, meaning that candidly cannot be trusted to disclose any possible negative factors surrounding the specific country that is selling you this CBI citizenship & passport. They are rarely admitted to the practise of law in that jurisdiction, and most likely do not know whether the local legal system is corrupt, and consistently disregards the Rule of Law for political actions. The CBI sales staff cannot and do not advise you on local taxation, customs duties, and other local laws which may impact you, directly or indirectly and what about local punitive criminal laws, the personal danger from violent crime you could face when you visit, or any number of possible dangers and pitfalls you may encounter in the future in your new adopted country? 

2. YOU MAY HAVE JUST PAINTED A TARGET UPON YOUR BACK BY SIMPLY HOLDING THAT CBI PASSPORT: Most of the jurisdictions that offer CBI products are former, or present, tax havens favored by transnational financial criminals, money launderers and members of foreign intelligence services. This means that you have a very good chance of coming to the attention of law enforcement agencies in North America and the European Union whose mission includes the interdiction and suppression of such activities when they impact their economies. Do you really want to be profiled, and become a Person of Interest, solely because you show up, arriving at one of their airports or ports, carrying what they judge to be a high-risk passport?

3. YOU MAY LOSE THAT VALUABLE AND EXPENSIVE PASSPORT FOR A NUMBER OF REASONS AND HAVE NO LEGAL REDRESS. What if the programme is terminated, as recently occurred in Cyprus and Bulgaria? What if the issuing jurisdiction revokes your passport without legal justification? It is extremely doubtful that you can successfully navigate your way through the local courts, to regain the privileges you paid for, as local courts in small island republics consistently favour government, especially corrupt government, over foreign nationals. What do you do then?

4. THE CBI JURISDICTION THAT ISSUED YOU THAT PASSPORT MOST LIKELY ALLOWED CRIMINAL ELEMENTS TO ACQUIRE THEM ALSO. There is generally little Due Diligence, and Enhanced Due Diligence, in that corrupt offshore which issued your passport, probably took cash to sell to international criminals, who eventually beak the law, and get arrested. Guilt by Association is unfair, but is a fact of life. Customs and Immigration officials at countries where these criminal have already committed crimes may not look kindly upon all individuals seeking to enter who happen to hold passports used by notorious fraudsters or other types of white collar criminals.Will you really enjoy being interrogated at length when traveling, and having your possessions regularly searched, with extensive delays?

These are just a few topics that have come to mind; there are several others. Prospective applicants for CBI passports are urged to consult the services of a competent attorney before seriously considering the purchase of a CBI  economic citizenship & passport. Please do not jump in feet first until you are aware of the dangers involved.  


Sunday, October 16, 2022



Company Number
Incorporation Date
20 August 2012 (about 10 years ago)
Registered Address
  • Malta
Source The Malta Business Registry

Two years ago, I asked the question whether the Iranian international sanctions evader (Oil-for-Gold) REZA ZARRAB was using Malta, to covertly move petroleum from Iran, or for some other illicit reason. The article, entitled, Is there a Connection between the Halkbank/Zarrab Case and the Maltagate Money Laundering Investigation? Kenneth Rijock's Financial Crime Blog, November 25, 2020.

                                                                 Bulk Cash Smuggling, anyone?

In truth and in fact, there was a connection. Zarrab, prior to his arrival at MIA, allegedly to visit Disney World with his family, had purchased a former Swedish Navy minesweeper, the OCEAN EXPLORER, which it was claimed he intended to use a diving vessel. Reports attributed to his maritime assistant, ADAM WOOD, state that he registering the ship in Malta, together with other vessels he owned, including but not limited to a submarine, all of which were purportedly used for Zarrab's deep sea diving activities. Given Zarrab's extensive history regarding illicit international shipment of bulk cash, the actual employment of his unusual fleet of vessels should be presumed to include illegal activities. Zarrab, or someone on his behalf, was reportedly carrying $103,000 upon arrival in Miami, according to an unconfirmed published report. Was the family holiday just a cover for another operation?

The Ocean Explorer

The Maltese company that was set up to register these maritime holdings, RZA YACHTING LIMITED, appears above. Sources advise that Wood was the original corporate official, but that, immediately after Reza's arrest in the United States, the company was taken over by MOHAMMAD ZARRAB, using the Turkish alias CAN SARRAF. Mohammad remains a fugitive from justice in the SDNY case which named his brother Reza and others.

 If you were wondering about the names,  Reza Zarrab was known in Turkey, where he resided, as RISA SARRAF. He is a dual national of Turkey and Iran, and is known to hold a passport from Azerbaijan, issued due to his Azeri origin, and an unknown number of CBI passports from the East Caribbean states, most likely including St. Kitts & Nevis, and Dominica.

Adam Wood and Reza Zarrab in the Middle East

Zarrab, now cooperating and released on bond, and living lavishly and privately in South Florida whilst the Halkbank issues are resolved in Federal Court, after which he is expected to testify on behalf of the US Government at trial in New York, is reportedly receiving substantial funds from Europe, as he engages in equine trading and ownership. Whether these transfers are originating in, or transiting through, Malta, and whether he has other active business there is not known, but he is the subject of existing international sanctions. 




Speak Truth to Power  by COSIMO

We can't say it any better than this gentlemen did today:

There is something disconcerting about the prime minister having never paid his respects at the murder site or makeshift shrine in Valletta, but instead planning a partisan meeting in Żebbuġ on the day of the murder anniversary.

Leaders are expected to lead, and if there is to be any genuine reconciliation, it will only begin once those in power move beyond private words of sympathy to public gestures of healing.

PM Robert Abela as a leader has no Values and Honour because he chooses to continue acting in the same way as disgraced Joseph Muscat who is a criminal and guilty of his unacceptable crimes that has tarnished the state's reputation around the world. The prime minister is in the same gang and a follower of Joseph Muscat if he cannot pay his respects to Daphne's makeshift shrine in Valletta who was using her rights as a journalist to inform the public with compelling information when the government was doing everything to silence it.

Sadly, this Mafia mob in power has totally destroyed the respect, reputation, and credibility of Malta from the rest of Europe's values by preventing justice to be properly exercised in time. This tragedy could have been prevented if the government and police would have been on the right side of the law doing its duty properly to serve and protect the public. But it failed miserably as the country's values and morals were being thrown out of the window preferring to accept greed and dirty crimes.

"Justice delayed, is justice denied" - and the price is going to be costly to the government of Malta by all the lies, denials, delays and lack of action.