Friday, March 31, 2023


The largest seizure of cocaine in Norwegian history, eight hundred kilograms, means that there is, in place and operational, a sophisticated money laundering network within that country, capable of cleaning narco-profits on that scale, and integrating those funds into the legitimate economy. This begs the question; where is Norwegian law enforcement on identifying and interdicting that organization?

Reportedly, the seizure, which was conducted at a warehouse of BAMA, a prominent fruit and vegetable wholesaler, was based upon information received from German authorities, who themselves had previously seized 1200 kilos in Potsdam. This means that the theory that the Oslo seizure represented narcotics in transit, and bound for users elsewhere, does not hold water. The targeted consumers are therefore obviously Norwegian, which is a surprise and an indication that cocaine consumption must be on the rise there. The previous largest coke seizure in Norway was only 153 kilos. This new seizure is disturbing.

From an investigative standpoint, the criminal proceeds received will be in Kroner, as Norway never adopted the Euro, which increases the chances that integration of those funds will most likely occur within the country's borders, as currency conversion on that scale cannot occur unnoticed.With the adoption of Artificial Intelligence, employing Machine Learning to access information and data not previously available, the ability to find the specific ultimate investment of those criminal profits is now a distinct possibility. Will the opaque money laundering network constructed to handle 235 million Kroner be exposed? Stay tuned.

Thursday, March 30, 2023


If I was a director of compliance at a major international bank today, I would detail my staff to employ advanced artificial intelligence platforms to revisit my prior due diligence investigation of all current high-risk and high-value bank clients. I do that because AI/ML programs will uncover information and data that was previously unknown to me, but which law enforcement agencies and regulators, using AI, might find first, and target my bank for ineffective compliance, or worse, and levy civil or even criminal penalties.

Remember, other parties can also find incriminating information about your bank clients; you had best find it first. While it may sound like an expensive proposition to review all your high-risk clients, think about the consequences if the FBI or the DEA, using AI, find out that your esteemed bank client is a drug kingpin, and that fact shows up today in an investigative article about his arrest and seizure of accounts at your bank.

AI is therefore to be considered mandatory for this purpose, if you are truly operating a risk-based compliance program. To do otherwise exposes your bank to an unacceptable level of risk. Do not forget that if information is knowable, meaning that technology exists capable of finding that information, the failure of compliance to access and possess that data, is by definition ineffective, and we know what happens when this is the conclusion of law enforcement and/or regulatory agencies. Find the data before some agency does, please,


We noted a lengthy article yesterday extolling the virtues of certain unnamed European compliance officers for duty in the Middle East, and we wondered aloud just how many of those esteemed candidates actually read and speak Arabic as that is the principal lingua franca of the region. The use of generic compliance officers, not coming from the region in which they are seconded, while perhaps appearing appropriate, often results in ineffective individuals whose cultural illiteracy in the region causes them to fail at their jobs.

Remember, compliance officers must be knowledgeable about culture, history, language and business practices where they are working, and a monolingual compliance officer from Western Europe will miss more than he or she catches, regarding complex money laundering schemes that exploit loopholes in local laws, or in commercial operations. Unless your foreign compliance officer is truly an Arabist, with personal educational or vocational experience in the region, laundrymen will most likely run rings around him until he gets the lay of the land, if that even ever happens. Also, how will that individual be able to utilize the new advantages that advances in artificial intelligence offer if monolingual?

While there are some individuals who have the background to be transplanted halfway around the world to discharge serious compliance responsibilities, they are unfortunately few in number. Selecting locally-trained, educated and raised talent is generally the only effective choice that bank management should make. Give that well-qualified candidate a pass, in favor of those home-grown and locally educated individuals who may not have the stellar credentials of those from Europe or North America, but who will not fail due to cultural ignorance and unfamiliarity.

Money launderers and financial criminals make it their business to know precisely who is in command in compliance departments at international banks, as well as frontline staff, because I know I did that back in the day. Place locally savvy talent in those positions if you want to both deter as well as interdict the laundrymen, in real-time, consistently and effectively.


A grossly overloaded boat seeking to smuggle African nationals from Cameroon into the United States, with an Antiguan crew, sunk while en route, with a yet undetermined but significant loss of life. The passengers, who were seeking to illegally enter American territory in the US Virgin Islands, were lost when the vessel, the La Belle Michelle. sunk off the coast of St. Kitts. Fourteen survivors were taken on board a yacht that answered the mayday call; at least thirteen are known lost at sea.

Observers of the large number of African nationals who traveled to Antigua on a number of Antigua Airways flights last year feared that a pipeline for human smuggling of illegal immigrants in the United States was being established, and planned from Nigeria, by the virtual airline's co-owner, with the assistance of the Government of Antigua & Barbuda, which made investment in the airline part of the Citizenship by Investment (CBI) passport program, thereby giving Antiguan passports to the Nigerian investors. There are allegations that the investors never received their shares of stock; the airline appears to be defunct without any assets.

Indications that Antigua's CBI passport program has sold citizenships to Nigerian government leaders and PEPs know to be involved in corruption have resurfaced in the aftermath of the failure of Antigua Airways. Antigua's Prime Minister, GASTON BROWNE, who has been closely linked to the CBI passport scheme, has promised to conduct a full investigation. The vessel, which was seriously overloaded, capsized in rough seas.


NYRON ERICKSON, accused in the United States of international money laundering and bulk cash smuggling, has been extradited from the BVI to face those charges, after a two year delay in the proceedings marked by unexplained delays and the advancement of bogus issues without legal merit, designed solely to delay the administration of justice, and which further establishes the British Virgin islands as an uncooperative jurisdiction in the global fight against drug money laundering.

Local attorneys for Erickson, known locally by his street name "Batt," and who operates a trucking and maritime business now suspected of being a front for his illegal operation, and who has been charged with bulk cash smuggling INTO the Continental United States,delayed the extradition by asserting a number of clearly anti-American issues. They alleged that he could not receive a fair trial in the US, and that he would be forced to enter a plea. They also said his extradition would interfere with his family obligations in the BVI, even though two of his three children actually live abroad. The last straw was his appeal to the Privy Council, which was dilatory on its face, and failed utterly.

Erickson's links to the BVI's disgraced and indicted Premier, ANDREW FAHIE, and his co-defendants, have also been widely rumored. Given the pressure from the United Kingdom, the Grey List situation, rampant official corruption issues, and the beleaguered BVI corporation service industry, this extradition will only represent more bad press for the territory, with potential economic consequences for its concerned Belongers.

Tuesday, March 28, 2023


ALEX NAIN SAAB MORAN, alleged to be the primary money launderer to the Venezuelan criminal elite, including President Nicolas Maduro, has filed a massive initial brief, through counsel of record, in his appeal of the District Court's adverse decision regarding whether he posses diplomatic immunity as an absolute bar to prosecution.

 We have previously covered the grounds for the Court's decision on this blog, which was based upon the facts and the law, including (A) He was NOT traveling on a diplomatic passport, and did not notify Cape Verde authorities of any transient privileged diplomatic travel prior to arrival (B) He initially did NOT claim diplomatic immunity when detained, (C) His diplomatic appointment in Venezuela was illegally backdated through alteration of government records, and (D) Even if he was a Special Envoy, such states does not confer diplomatic immunity. The District Court's decision should not be overturned. The appeal is, in my humble opinion, without merit, and filed to avoid the legal consequences of Saab's extensive money laundering career.

The issues stated in the brief are:

1. Whether the District Court clearly erred in disregarding uncontroverted documents establishing Mr. Saab's diplomatic status in favor of a conspiracy theory with no evidentiary support. 

2.Whether a a Special Envoy of Venezuela, traveling on a diplomatic mission to Iran enjoys diplomatic immunity from arrest, detention, and prosecution.

These are the points the brief makes:

A. The District Court clearly erred in concluding that Mr. Saab did not travel as a diplomat.                    B. Documents related to Mr. Saab's Spring 2020 missions are sufficient to establish diplomatic status.  C. Additional uncontradicted documents confirm M.r Saab's diplomatic status.                                      D. The District Court clearly erred in construing the record.                                                                    E.  The District Court erred in accepting an unsubstantiated conspiracy theory over probative evidence. F.  The District Court erred in construing the remainder of the record.                                                     G. Mr. Saab is immune under the Vienna Convention and the DRA.                                                      H.  Mr. Saab is immune under the Vienna Convention.                                                                              I.   The District Court's bases for rejecting immunity under the Convention lacks merit.                          J.    This Court's precedent rejects the District Court's theory.                                                                   K.  This Court's precedent correctly reads the Convention.                                                                      L.    Mr. Saab is entitled to immunity under customary international law.                                                  M.    The President's Constitutional Powers do not enable the Government to violate international obligations imposed by Congress.                                                                                                              N.  The relevant recognition under the law is that of Sending and Receiving States.                               O.  The Constitution does not authorize the Government to violate the law.                                            

Saab's attorneys, which prominently included a university professor among them on the cover of the brief, have requested Oral Argument. All the relevant diplomatic conventions are attached to the brief, including two which appear only in draft form. We await the Government's response; stay tuned.







US Department of Justice

The Justice Department announced today the final resolution of two civil cases seeking the forfeiture of various luxury assets that were the proceeds of foreign corruption offenses and were laundered in and through the United States. With the conclusion of the cases, the department has recovered roughly $53.1 million in cash – constituting the net liquidated value of the defendant’s assets – plus a promissory note with a principal value of $16 million. According to court documents, from 2011 to 2015, Nigerian businessmen Kolawole Akanni Aluko and Olajide Omokore conspired with others to pay bribes to Nigeria’s former Minister for Petroleum Resources, Diezani Alison-Madueke, who oversaw Nigeria’s state-owned oil company. In return, Alison-Madueke used her influence to steer lucrative oil contracts to companies owned by Aluko and Omokore.


According to the Rashomon Effect, different people provide contradictory accounts on the same event. In the world of money laundering, the self-serving interests of the players often result in competing, and even contradictory, explanations of the problem and its solutions, all to the disadvantage and detriment of the compliance community.

Perhaps an analysis from someone who is, from personal experience, especially sensitive to all the diverse perspectives will make this clear:

(1) The Regulators: are focused upon increasingly stricter ways in which to hold the compliance industry to a standard which seems impossible to bear, given the restrictions imposed upon it by their superiors in the banking chain of command. Management does not want New Accounts seemingly handicapped by assertive compliance officers who veto prospective clients that they believe represent acceptable risks at account opening.

(2) Law Enforcement: Holding individual compliance officers personally liable for what they regard as ineffective policing, and even professional negligence, demanding 100% efficiency, while at all times trying to get along with the business realities. banks exist to serve clients, and make a profit, not to be the policemen of the financial world, yet compliance officers are fully expected to be gatekeepers, barring all who are bent on financial crime. Compliance officers charged with being willfully negligent for doing their job is the the solution.

(3) Legislators: Their utter failure to make complete corporate transparency a reality, including real-time access to beneficial ownership data, is one of the reasons the war on money laundering will remain an abject failure. Their dependence upon campaign contributions hampers their ability to assist compliance where it needs it the most.

(4) The money launderers: Their adoption of new technology, for universal information access through the Internet, to access to software, including AI programs not yet in common use by the compliance officers whom they match wits with daily, makes them more formidable than they have been in the past, which is troubling. They will continue to find new roads to success, unless and until reined in by imaginative and innovative compliance officers, working within their restrictions, but still able to interdict the laundrymen in real time.

The compliance solution to all these competing and often overreaching interests has to be the universal use of advanced artificial intelligence platforms, as they can find critical data not previously available or accessible, develop it through machine learning, and thereby allow analysis and conclusions that will effectively satisfy all these interests, and save the day for each and every compliance officer with good outcomes. Let us hope that this bit of wisdom from a old former money launderer will result success against today's laundrymen, where there has previously been only failure. Hit them hard with the new tools, please.

tatus is online

Monday, March 27, 2023


Investors in Antigua Airways, now out of business when it failed to meet regional aviation safety standards, are alleging fraud, in that they never received their stock certificates in the defunct company, which was a joint venture between the Government of Antigua & Barbuda and a private Nigerian company, under Antigua's Citizenship by Investment (CBI) passport scheme.

The operation suggest that it is similar to the failed Grenada CBI passport scheme, known as GSA, run by Swedish national Soren Anders Dawody, where the investors received their passport, but the investment was never made by the operator, who made off with $19m. It is not known how much the Nigerian and other investors paid in for their shares. Antigua Airways was a virtual business; it leased its sole aircraft, and its investors have alleged that they were defrauded.

Additionally, Antigua Airways allegedly allowed bulk cash smuggling of the proceeds of crime, in cash, from Africa into the tax havens of the Caribbean. Antigua has a number of offshore banks, two of which were formerly owned by the Colombian money launderer Alex Saab Moran, now awaiting trial in Miami in US District Court. It has also been alleged that the government facilitated the illegal immigration of Nigerian nationals in the United States via Mexico by offering them visa on arrival in Antigua, from which point they continued their journey to illegal entry through the American southern border.

Friday, March 24, 2023


Exhibit from US vs. Alex Saab Moran (SDFL).

To: Swartz, Bruce (CRM)                                                                                                                        

 From: Abrams, Elliot                                                                                                                                

Sent: Sun 6/14/2020 9:00:35 PM (UTC)                                                                                                

Subject: Saab                                                                                                                                          

Tidbits about Saab below:                                                                                                                                 he seems to have Antiguan and Dominican passports, perhaps dip passports, as well as Colombian and Venezuelan Sec Pompeo wonders if we can argue that his Venezuelan dip passport is illicit because awarded by criminals not President Guaido, but if it had been issued before January 2019 we too recognized Maduro ( and anyway CV probably follows the UN in recognizing Maduro). Pompeo also noted that in any event he was not accredited to CV nor was he in a diplomatic mission: he was involved arguably in a mission designed to violate UN sanctions on Iran.          


I was once asked to give a presentation before a compliance association at one of Europe's tax havens/offshore financial centers. The evening before, I flew in from Heathrow; not expecting that anyone would be meeting me in the Arrivals Hall, I went directly to my hotel via taxi, and began preparing for the lecture.

The telephone then rang; it was the lead organizer. Apparently, they had gone to the airport to meet me, and to drop me at the hotel, not knowing that I knew the city from my prior life as a laundryman. They were surprised to learn that I had actually arrived because they had closely watched the arriving passengers from the flight, and not seen me. They wanted to know how on earth I had managed to slip by them.

As you can see,old habits die hard; I had instinctively positioned myself in the midst of a group of locals returning home when I disembarked from the aircraft, and my greeting committee totally missed me in the airport. Once the group was in the baggage claim area, I detached myself from the throng, and slipped out the door, unnoticed by anyone. Of course, I only had hand luggage. We call this hiding in plain sight. Being elusive was a survival skill in my previous occupation, and it has become second nature.

This is how money launderers operate; there might be but one amidst a group of completely legitimate transactions, where a bored compliance officer, looking at transactions at the end of a busy week, and thinking of what he or she is planning for that evening, quickly passes over one solitary entry among many, and not giving it a second thought, misses it completely. It's all about deception, misdirection and mischief.

Start thinking like a money launderer, to catch yours; what would I do to beat my compliance program today, if I was the opponent? Know your enemy, ladies & gentlemen; what specific methods would most likely succeed, given your strengths and weaknesses? Learn the laundrymans' tradecraft and look hard for the telltale indicia of each method; Happy hunting.