Tuesday, January 31, 2023


What’s our cause?

Pilatus Bank was set up in Malta in 2014 to launder money for embezzling tyrants and tax evaders. When Daphne Caruana Galizia exposed them, they sued her for $40 million. They threatened every newsroom in Malta that dared write about them. Until the European Banking Agency shut them down.

And yet, those responsible have never been brought to justice. We think it’s because if the Pilatus Gang goes down, they’ll bring the Maltese politicians who helped them down with them. We are challenging the decisions of the Maltese authorities to let the Pilatus Gang get away with it. It’s a long and complex court battle. And it costs a lot of money.


A magisterial inquiry into the Pilatus Bank affair was completed nearly two years ago. The public paid almost €8 million to get it done. The Magistrate ordered arrests and prosecutions and the re-opening of the Egrant inquiry that tried and failed to confirm whether Joseph Muscat received bribes through Pilatus Bank.

Months went by and the police and the attorney general ignored most of what the inquiry had told them to do. Arrest warrants were allowed to gather dust. In one case, one of the persons identified for prosecution by the Magistrate came to Malta and met prosecutors in court. He was allowed to leave undisturbed.

We have taken the police and the attorney general to court to challenge their decisions to allow the Pilatus Gang to get away with it.

We’ve faced some tough hurdles. In one case, our complaint was assigned for a decision by Magistrate Nadine Lia. Her father-in-law was Joseph Muscat’s lawyer in the Egrant affair. She could never give us a fair hearing.

We tried and so far, failed to get a court to confirm that we even have a right to a fair hearing. Our next step on that front will be to go to the Appeals Court and argue what to us seems obvious: if we have a legal right to complain to a court, surely, we have the right to complain to an impartial judge.

We admit we’re a long way away from forcing the prosecution of the Pilatus Gang and its ringleader Ali Sadr Hashemi Nejad. But we’re closer than he’d want us to be. We’re closer than the police and the attorney general want us to be.
We Need Your Help

We get help from lawyers working pro bono and volunteers that are doing research. But we still need to pay hefty court fees to fight this battle.

We can’t do this without you. We don’t just want justice for the Pilatus Gang because we don’t like them. Their crimes have hurt Malta’s reputation. They have bullied and intimidated journalists who worked on exposing them. They have handled the accounts of people like Keith Schembri making sure that having friends in high places would let them use our country as a vehicle for their crimes with impunity.

You too deserve justice. You too deserve to have our institutions work for you rather than for criminals. If we leave it up to the police and the attorney general, you’ll never see justice.

Help us change that.



Sunday, January 29, 2023


With the ever-expanding compliance costs plaguing most financial institutions, even to the extent that it diminishes shareholder profits, many banks look to cut costs wherever they can. This poses a problem for individuals in their compliance departments, as the use of artificial intelligence, with machine learning capability and advanced analytics, becomes so common that it is fast attaIning the status of being considered Banking Best Practices.

Here's why this is a problem; regulatory agencies and auditors will be looking to see that ai is present in compliance programs, and given the shift to indicting compliance officers who commit professional negligence in failing to catch major money laundering operations, at customs identification or transaction monitoring, can compliance officers risk serious individual problems, should they choose to remain at a bank who will not pay for ai/ml platforms?

Perhaps it's time for compliance officers, after demonstrating the ability of ai to bank leadership, insure that budgets for 2023/2024 are expanded to allow for the acquisition of such platforms, lest the bank's failure to adopt them leads to a massive compliance failure, with the compliance director left holding the proverbial bag. Use your own personal risk-based program, and insist that it be brought online, to avoid such a potentially dangerous outcome. I know that I wouldn't want to remain where I didn't have everything in my toolbox to catch money laundering and financial crime.



Choksi's EXPIRED CBI Antigua passport

MEHUL CHOKSI, trying  desperately to find any possible means of avoiding a very long prison term in an Indian court for his crimes, gave a prominent human rights attorney in France a Power of Attorney to assist him in filing claims that he is a victim of human and civil rights violations. On June 5,2021, Choksi made Marseille attorney LUDOVIC HENNEBAL, a specialist in international human rights cases, his Attorney-in-Fact, to represent him before the United Nations and Organization of American States (OAS), and "any other Inter-American human rights bodies," to lodge petitions on his behalf, and to consent that his name be made public.

Advocate Hennebal

There is absolutely no previous information, from any of Choksi's attorneys, in any country or territory, alleging any set of facts to support an allegation that his human rights or civil rights have been violated. Obviously, this is a ploy to gain more time, especially in front on the Antiguan judiciary, as that power of attorney was duly filed there, in connection with his pending extradition proceedings. This shows us the lengths to which this fraudster, India's Most Wanted Man, will go to evade being held to account for his crimes, which involved cheating a government-owned bank in India of the equivalent of over two billion dollars, and fleeing the jurisdiction to avoid prosecution.


Saturday, January 28, 2023


STEADROY BENJAMIN, the Minister of Justice and Attorney General of Antigua & Barbuda, and who allegedly has been the key figure behind the two-year delay in the extradition of India's fugitive master fraudster,  MEHUL CHINUBHAI CHOKSI, ordered his staff to alter the Police Report about Choksi's illegal arrival in Dominica, to fabricate a bogus kidnapping story. The Report was used by Choksi's attorneys to convince Dominican judicial authorities to dismiss his unlawful entry case, so that he could return to Antigua, where he has remained immune from deportation and extradition to face justice in his native India, over fraud claims in excess of the equivalent of USD$2bn.

Internal correspondence amongst government officials, obtained from local Labour Party sources, confirming Benjamin's illegal alteration of police records, shows his direct role in the manipulation of evidence; Choksi has bestowed lawish bribes throughout the Antiguan government to have his extradition case indefinitely delayed, including officials at cabinet level. We have previously detailed his influence over a magistrate and a senior police official; new evidence in our possession has verified  this information, and showed that Choksi literally rules his own legal proceedings in Antigua's court system, with the assistance of a "dream team" of attorneys in three Caribbean countries.

Indeed, confidential correspondence made available to us by our Dominica sources has shown that two prominent East Caribbean law firms sought to intimidate and influence local police and judicial officers in Dominica, to extricate Choksi from his criminal case there, by grossly exaggerating his medical condition, and throwing their considerable legal weight around. Correspondence from these attorneys was sent to Dominica's Princess Margaret Hospital, Dominica Prison Service, Dominica China Friendship Hospital, police and court officials, Remember, Choksi has alleged that he is too ill to travel back to India to face justice.

The law firms are:

(1) DYER & DYER, Barbados.


Note: Choksi was represented in court in Dominica by NORDE AND LAMBERT, including CARA SHILLINGFORD-MARSH, WAYNE BENJAMIN MARSH and JULIEN PREVOST. These attorneys used fabricated evidence to perpetrate a Fraud upon the Court.

In our next article, we intend to go into specific detail about the legal misconduct of Antiguan government officials, in their efforts to delay and deny Choksi's extradition, using the documents and exhibits referred to above. Given that Antigua was able to delay the extradition of its former banking regulator Leroy King for more than a decade, to the United States, it is probable that Antigua's corrupt judicial system, lubricated by Choksi's substantial bribes, intends to see that he spends the rest of his life safe from the administration of justice in India. 

Friday, January 27, 2023


When most compliance officers think about Hawala, the alternative international funds transfer system that accomplishes its goals outside the traditional banking system, they generally envision a small businessman of South Asian origin, toiling in a small retail store somewhere, furtively accepting cash for transmission overseas, and reaching out to his cousin abroad, who will disburse the money paid here by the remitter. It is more or less off the books when it comes to a financial transaction that bank compliance officers, or even law enforcement investigators, can trace, period. How these two cousins settle up later does not relate back to the transactions, and usually the whole thing is total mystery.

As a career money launderer, I participated in what I choose here to call American Hawala. I had a number of clients who were narcotics traffickers; some were also international smugglers, whom you generally refer to as kingpins, others merely wholesalers and retailers of large quantities of narcotics in North America.

Some clients had earned drug profits that they now wanted to move abroad, hopefully without being caught in the act by law enforcement, while bulk cash smuggling. Others feared exposure by compliance if they employed wire transfers, on matter how cleverly they executed them. That's the First Problem.

One the other hand, another group of clients already had criminal profits in offshore financial centers in the Caribbean or Latin America, and needed some of it back here, to make certain covert cash investments, which would integrate their funds into businesses, giving them legitimate, cleaned up status. That's the Second Problem.

By matching up each client's needs, I performed a service to both. The client with offshore funds transferred ownership to the onshore client abroad. Remember our articles on Bearer Shares of a corporation? he simply passed over the share certificate to a corporation then holding that cash in an overseas account. The other client got the cash he needed for a domestic operation. No US banks were involved.

Simple ? Yes; impossible to trace? Until now, yes, but with the advent of platforms using advanced Artificial Intelligence, searches of remote data which previously was out of reach by compliance, as well as criminal investigators, can now be accessed in real-time. The onshore client's deals, even if totally covert, using third parties, leave bread crumbs that machine learning can not only find, but develop. Offshore client's tracks are no longer impossible to find, and tying the together, even if they only have one quick point of contact, can now be accomplished. Will AI take a bite out of financial crime.

Thursday, January 26, 2023


The so-called "Economic Envoy" Venezuelan passport, produced by lawyers for ALEX NAIN SAAB MORAN, in support of his motion to dismiss upon the grounds of Diplomatic Immunity, had expired two months ( March 22 2020) before his ill-fated trip to Iran (June 12, 2020), via Cape Verde. He used two ordinary passports to travel, not this one,. In truth and in fact, his alleged diplomatic status was not even initially mentioned after his arrest in Cape Verde. Readers of our articles know that it was invented later, a fact which was proven by the absence of a 2019 entry in Venezuelan official records. The copy produced was a poor attempt to back-date his status, and it failed. 

As you can see, even the fraudulent efforts to create diplomatic status failed, because the Government of Venezuela did not even insure that the subsequently produced diplomatic passport was valid. if you are going to create a bogus government document, make sure it's still current. The document not only does not support Saab's allegations, it actually fatally damages his position.

 His appeal to the Eleventh Circuit should fail as a matter of fact and of law for this and several other reasons.Venezuela committed a fraud upon the court and they couldn't even get the document right.



Money laundering through the purchase of fine art is a black hole that narcotics traffickers and white collar criminals can drop their criminal proceeds into, with little fear that they will be discovered and exposed. When I spent that decade as a career money launderer some of my clients attended the auctions in New York City looking for suitable investments in Latin American Art to place their refits. Of course, they relied upon frontmen and and proxies to actually bid and purchase the items.

They were also looking to sell their previous acquisitions; I had a relationship with a Coral Gables art dealer from whom I purchased original Art Deco furniture for my own  collection, and he had a source who was a diplomat inside Communist Cuba who was able to smuggle out original works of art inside a diplomatic pouch, which my clients purchased for cash. While a couple of the works were later found to be counterfeit, due to Cuba's flourishing cadre of art forgers, most of them were genuine. Years later, US law enforcement was looking for them after their convictions; they were never found.  

Unfortunately you can count the number of detectives who have university degrees in fine art on the fingers on one hand; most investigators could not identify an Old Master if they tripped over it, which is  a boon for enterprising money launderers working for narcotics traffickers looking to clean their money. Remember, you can literally throw a million dollars painting, siting in a cheap frame, in the boot of your Volvo in Poland, and drive it to London, or anywhere  else in Europe, without detection. Some laundrymen drop an extremely valuable purchase into a shipment of cheap copies and ship it globally, only to see it on there other side of the world, walking away with what their lawyers describe as a "find," having successfully navigated the complete cycle of money laundering, with nobody the wiser, especially law enforcement.

Today's however, employing the expanded search ability in programs using advanced artificial intelligence, criminal investigators, smart compliance officers, insurance agents looking for provenance, and others, can extract search remote records and publications, and find relevant data from the either side of the opaque art world, where cash-deals prevail, but where prior sales offers can still expose covert sales, and trip up the money launderers and their clients. Advanced AI/ML technology can reach out and find where these dirty transactions started, and even where they ended up. Art money laundering crime has now become a much more dangerous undertaking for the laundrymen, thanks to emerging technology. 


Note: The above painting, Femme Cheval,  by the Cuban artist Wilfredo Lam (1902-1982), which sold for $1.6m at Christie's, appears here only to illustrate the value of such works. We are not claiming that it was ever part of any money laundering activity.



Wednesday, January 25, 2023


Buried in the news of the British Virgin Islands this week is the sad fact that the island's government has declined to fund its new Integrity Commission. The Commission, which was set up under the Integrity in Public Life Act,  and requires all officials file a declaration of income, assets, liabilities, private interests and gift received. It also creates offenses for Abuse of Office, Misconduct and Neglect of Duty.

The Integrity Commission was authorized to receive complaints, and initiate investigations. It was also to establish a Code of Conduct for all persons in public life. The USD$294,000 funding was not authorized by the BVI after Andrew Fahie's money laundering and narcotics trafficking arrest in the United States. Fahie awaits trial under house arrest.

Rumors that Fahie will accuse additional BVI government officials of corruption, to mitigate his ultimate sentence, have been flying around since his original arrest, after he alleged that he had first-hand information regarding others in government in the Caribbean who have worked with narcotics traffickers, and that is a possible reason why there is a reluctance for current government officials to fund a program that will force them to disclose assets in excess of their stated government salaries.


We have written a number of articles detailing how a number of lawyers in Barbados have been engaged in the theft of real estate from absentee Bajan owners, or those who are powerless to protect themselves from fraud, forgery, corruption of the court system, and additional white collar crimes committed by unethical and greedy members of the Bar, who have been acting with impunity.

Our latest information involves property that was once owned by the leading American/Bajan civil rights activist the Right Reverend Michael Haynes. Haynes was a close friend of American icon Martin Luther King, Jr., and the two of them worked together in the Civil Rights Movement in the 1960s.

The real estate in question passed, through inheritance, to Haynes' son; On January 18, 2023, attorney CORY H.D. BECKLES allegedly broke into the property, without permission, or colour of law. He was  reportedly accompanied by clerk ANTHONY HINDS, attorney KAVIER CALLENDER and an individual claiming to be a Bailiff, WAYNE MCKENZIE. Beckles is reportedly acting on behalf of a client named JOSEPH JORDAN, of Sunset Crest, St. James. Jordan's claim has no basis in law, according to our sources. An attorney's failure to adequately research authorities before taking action constitutes gross negligence, and requires disbarment, but the law in Barbados is weak, corrupt and useless when it comes to the administration of justice.

Readers of this blog will recall that attorney Beckles is connected to known Bajan fraudster and unlicensed jailhouse lawyer WINSTON CLARKE* also known as JOE GRIFFITH, who has victimised a number of Bajans through the unauthorised practise of law, allegedly working out of Beckles' law office. Until the Barbados Bar Association, and the courts, start disciplining and punishing attorneys who steal real estate from their clients, and from innocent expats living abroad, these crimes will continue unabated.


* Clarke's latest alias is JUNIOR CLARKE.


Artificial intelligence-powered platforms can be employed to identify and interdict those money laundering techniques that have, to date, generally escaped detection. It's such an obscure money laundering method that the first time it appeared in a federal criminal case in the early 1990s, a lengthy introduction in the indictment was necessary to detail the scheme for the Court, in a case brought in District Court in New Jersey for activities that originated in the Port of Newark.  When I was first introduced to it, my source was working with Russian organized crime in the New York area, and traditional Mafia elements were also involved. It's called International Product Diversion.

Let's say that you are an American narcotics trafficker, or other type of transnational criminal, who has criminal profits located outside the United States. How do you repatriate these illicit funds, while at the same time, laundering them in the process so that you can invest them without fear of being discovered by law enforcement agencies or bank compliance officers monitoring large transactions? 

Inside information: managers of America's latest companies making food items at times overproduce their products, and since they sometimes are about to expire, making them worthless, they try to unload their goods, to at least recover their costs of production. 

(1) Some items are therefore donated to charities, or nonprofits in the United States, where tax deductions might be available foe the corporate entity.

(2) In an attempt to create new markets abroad, some manufacturers and distributors will sell at greatly reduced costs (stripping off advertising, profits, and other charges generally applied)  to foreign entities, especially those that are nonprofits, churches and charitable organizations. Coming from such legitimate entities, US-based compliance officers rarely question the payments, especially given the prominent Fortune 500 company sellers.

(3) Enterprising money launderers know about this practice, and set up front companies abroad, including bogus charities and nonprofits, and solicit US manufacturing entities for those excess products, which the companies are glad to sell, so they can at least obtain their basic costs.

(4) Here's where it gets interesting; the good are shipped abroad BUT they never arrive at their stated foreign destination, as they are quietly turned around and returned to America, where they do not pay duty as "Returned US Goods," under our Customs laws. Sometimes they never even leave American ports, but are illegally and covertly diverted elsewhere. (Those returned often violate our Customs laws, because the manufacturers can get tax breaks for exporting finished goods made with imported raw materials).

(5) Once in the hands of the bad actors, the goods can be relabeled, with the expiration dates changed, and they are then sold in the commercial market, at prices below the going rate. Whether consumers become ill from eating expired food is not their concern.

(6) Payments to the criminal element, from the buyers of the relabeled goods, coming from reputable supermarket chains, are clean funds which can now be invested without any concerns by the money launderers of being exposed as the proceeds of crime. 

To date, it has been nearly impossible for compliance officers to identify such transactions as being of criminal origin, due to the complexity of the scheme, the international scope of the method, and the fact that one would have to connect several seemingly unrelated events, and create a scenario that constitute a crime. Enter Artificial Intelligence programs, using machine learning, which can pair up these unconnected facts, and find similar prior acts among massive data, finally ending up with a conclusion supported by the facts weaved together into a recognizable scheme by the platform.

While this, and other esoteric money laundering schemes, have historically gone unnoticed by compliance officers, the advent of AI/ML changes the equation; They can now be found and interdicted. The challenge is securing universal adoption of this advanced technology, by the financial services community to stop these exotic money laundering methods cold, 

Tuesday, January 24, 2023


Here's the latest fraud on the Citizenship by Investment (CBI) passport scheme being manipulated in the Commonwealth of Dominica. A number of CBI projects have been shut down, before completion, Wirth no signs of being restarted, and many of those which have been finished are vacant, totally unoccupied, and therefore, not income-producing for their developers, who are legally obligated to pay existing investors.

Here's how the builder/developers are being able to afford to pay investors: the government gives them literally hundred of additional CBI passports to sell; they use those new identify document sales to fund payments to the original investors in stalled or vacant properties that have no cash flow. it's a classic variation on the Ponzi scheme; so long as the developers can hawk those CBI passports, they can make the payments, and won't be exposed as frauds who failed to complete or monetize their projects.

Passport issued to Egyptian national under an alias.

This is only happening b because Dominica's corrupt government reaps substantial fees from new CBI passport buyers, much of which appears to have totally disappeared from public view. Those rumours that Dominica's Prime Minister, ROOSEVELT SKERRIT, has a room piled high with greenbacks are true, as they have been confirmed by witnesses who have been there, for purely romantic purposes, and therefore have no political reason to make those statements. It is a veritable Ponzi scheme, Caribbean style. No wonder the developers are beating a path to Dominica, although  there's no commercially sound reason to build hotels and residences in the island nation.

Monday, January 23, 2023


In today's news from the Republic of Malta, prosecutors in the Pilatus Bank money laundering case are requesting an indefinite delay, so that they can receive assistance from the UK and other foreign jurisdictions. The United Kingdom request is to locate and obtain sworn video testimony from an unidentified individual who was the Money Laundering Reporting Officer (MLRO) at the bank's Mayfair London address. Prosecutors have stated that they are seeking information regarding the criminal charges pending in Malta, against the bank and its former Malta-based MLRO, CLAUDE-ANN SANT FOURNIER.

If you have been reading our continuing series on the Pilatus Bank scandal, you know that our investigation, and that of many others, revealed that the bank's London branch, at 4 Old Park Lane, was little more than accommodation address, and its sole employee, HANNA OLAFSSON, seemed to be wearing a number of hats on behalf of the bank. The Pilatus London branch, according to Daphne Caruana and other sources, was a branch that existed only on paper, whose sole function was to move money internally, through Pilatus from Malta to the UK, to launder dirty money through real estate acquisition. 

Given that no bank can exist, under UK banking regulations, without having an MLRO, Ms. Olafsson  presumptively had that responsibility. No wonder Maltese authorities want to take her testimony. Excuses from bank counsel, to the effect that she was "in the dark" about the bank's true activities, is simply not credible, as are most of the statements defence counsel has made on behalf of the bank.

Ms. Ofafsson needs to come forward, as the case has been postponed indefinitely pending receipt of evidence from abroad. Whether the entire case will later be dropped, due to some flaw or error in criminal procedure, which is how justice is delayed and denied in Malta's corrupt courts, remains an open question.