Sunday, April 30, 2023


Given that the United States Government has stated publicly that it believes Robert "Bob" Levinson, the retired FBI Special Agent who was kidnapped by Iranian agents on Kish Island back in 2007, is most likely deceased, it is time for certain details to be disclosed. Bob's friends from his FBI service, who made sure that he was not forgotten, deserve no less. Given that there may be issues involving nonpublic or restricted information, I have taken the liberty of redacting the names of anyone who played a role.

While there has been a substantial amount of anger against the then-US Secretary of State for most likely failing to exploit an opportunity to recover Bob, which appears to have been vetoed for political reasons, the United States did attempt a rescue. Why it has never become public knowledge I cannot say.

First of all, be advised that I worked with Bob Levinson for several years, on a number of projects, teamed up with the late Thor Halvorssen. The subjects are best left out of this article, but just prior to departing for Kish Island, Bob met with a Confidential Informant who provided him with details about an Iranian government leader involved in the WMD program, and who might be persuaded to assist in providing actionable intelligence to the United States. Bob was, if anything, a multi-tasker. He had a number of things on mind for his Iran trip, and making contact with this potential source was one of them.

At a later date, while working on another matter, I was shown a list of compromised emails (with passwords) under surveillance by Cuba's intelligence services, working out of the CANTV (state-run telephone company) building in Caracas. Bob's RAL email was among them; was his upcoming trip to Iran disclosed in advance to Tehran? We cannot say, but he was one of the very few Americans on that list.

On to the story; several months after Bob was detained, the same Confidential Source happened to have contact with a field-grade military officer, and when the officer related his role, as paymaster for a special operations raid, to be conducted inside Iran, to retrieve a high-value American prisoner, the CI identified Bob by name, and the fact that he was the target was confirmed. I regret that any further details will expose these two individuals, but given that the CI knew the Iranian who Bob was targeting for enrolling as an Agency source, there was no mistake about who it was.

The officer advised that the mission, planned at an American facility in the Continental United States, was later cancelled when Bob was abruptly moved to another location, which was not known. Perhaps, since a sufficient amount of time has elapsed since Bob's kidnapping in Iran, the United States Government might want to release additional information to show that it did, indeed, make an effort to bering Bob Levinson home.

As to whether Bob is still alive in Iran, that mystery continues.


This week's money laundering news from the Republic of Malta: a senior HSBC officer was indicted last year for money laundering and fraud, but the matter was quietly orchestrated so that the media did not learn about, or report on it. Apparently he stole €1 million from bank customers and bought a large farm, complete with an exotic animal collection, moving money around accounts, Ponzi-style.

The most damning thing about the case is where tellers willingly gave him cash from client accounts, no questions asked. So much for the principle that you can always trust your banker.

Malta has literally dozens of major money laundering cases withering on the legal vine, fated never to go to trial. The legal system's antiquated "Compilation of Evidence" rules, which allow an infinite number of post-indictment hearings, allegedly to assemble the evidence, but in truth and in fact to delay ad infinitum the proceedings, where the defendants are members of the totally corrupt ruling party, Labour, which has dominated Malta since 2013.

Two major defendants, who have been barred from entry into the US due to their career criminal corrupt status, will obviously never go to trial. official corruption is simply too ingrained in the DNA of PL to be excised. My advice to the world's compliance officers: block any and all significant wire transfers TO or FROM Maltese banks, including the local branches of foreign financial institutions. The banks of the country are simply too far gone with systemic money laundering to be trusted. You may rue the day you allowed funds transfers from there.

Friday, April 28, 2023


If you were wondering why you have seen some really good compliance positions at major banks remaining open and unfilled for months, it's because experienced compliance officers are themselves performing due diligence upon the financial institutions offering those good jobs, and ignoring those banks that have histories of repeated regulatory fines and civil penalties, or who are named in money laundering cases for failing to identify and interdict major criminal organizations.

If you have a good resume, the last thing you want to do is to be associated with a bank known for having an ineffective AML program, whether that be in correspondent banking relationships, permitting major sanctions violations, facilitating Russian organized crime or oligarch operations, or other major cases in the news. Being tied to such a bank, which considers repeatedly paying such fines as a necessary part of its operation, while enjoying record profits, can be fatal to the career of a senior compliance officer.

You cannot simply delete such a bank from your resume, when you are out in the job market trying to forget you ever worked there. There is also another serious consideration: what if law enforcement chooses to pursue you, either as a witness, or worse, as a target. In that case, your last job has turned into an occupational nightmare.

To those major banks whose plum compliance positions remain unfilled, and who have taken to asking current employees if they have anyone in mind to take those slots, you may want to examine whether your existing plan, suffering civil fines & penalties from time to time, but not changing your corporate culture, is resulting in your perceived unsuitability as an employer.


Ask any compliance officer how international product diversion money laundering works, or the criminal use of Life Settlements, and you get a bloody blank stare. It's because financial institutions never invest the time to hold closed-door training sessions, where their frontline compliance officers actually learn the nuts and bolts of advanced and esoteric money laundering techniques, what the brits call Tradecraft. Given the strong language contained in the massive British American Tobacco case, and the news that US compliance officers who approved over 300 transactions that ultimately benefited North Korea, because they didn't understand what was happening, you can expect that heads will roll, and it will not be pretty.

And it's not just the banks themselves; how many useless hours do compliance officers spend annually at industry conferences and events, where the content they receive is neither helpful nor current? Far too many, in my humble opinion. There simply are no private lectures, restricted to active duty compliance staff, where cases demonstrating the evolving methods of laundrymen are not only explained, but analyzed, and investigative solutions detailed, given the availability of Artificial Intelligence platform countermeasures, for attendees.

I'm sorry, but appending a long train of initials after your name, to demonstrate your AML/CFT competency to the world just doesn't cut it for this old former money launderer, if you cannot diagram for your frontline staff each and every advanced money laundering technique in present use, and identify it solely from raw data presented to you. There is a knowledge deficiency in the industry, and it my take a major casualty among America's banks before they wake up and smell the coffee. Read the BAT Criminal Information, and govern yourselves accordingly.

Wednesday, April 26, 2023


While the agreement between British American Tobacco (BAT), and the United States, involving the payment of hundreds of millions of dollars in fines and penalties, is not receiving significant attention in the American compliance community, there is one aspect which will eventually demand the attention: The failure of the US banks to exercise effective enhanced due diligence in their correspondent accounts could result in Federal prison sentences of up to 30 years, for those who permitted 310 transactions which resulted in massive international North Korea sanctions violations.

Apparently, those American compliance officers and account representatives did not appreciate the strict US policy of enforcement of DPRK sanctions, and the fact that American bankers involved in this extraordinary amount that benefitted North Korea will be held to account for their negligence. there are rumors that compliance officers will be indicted for willful blindness, and they should be taken seriously.

BAT Press Release

While in the past, regulators and US Attorneys have routinely imposed civil penalties solely upon the offending banks, in this instance, where a point must be made to the American compliance community that examples must be made for North Korean violations, to serve as an effective deterrent of others. We trust that the compliance officers involved have already retained the services of competent defense counsel.


According to the Daphne Caruana Galizia Foundation, which tracks global corruption through its journalists, Harlan Crow, the billionaire who reportedly has been providing US Supreme Court Justice CLARENCE THOMAS will expensive vacations abroad, using private jets and yachts, holds currently or has held recently a St. Kitts & Nevis Citizenship by Investment (CBI) passport. The vacations, which were not duly reported by Thomas, have opened a Pandora's Box of ethical questions about the Justices' moral lapses, and spawned a Congressional investigation.

Back to the SKN passport; for those who are not familiar with the Foundation, it was founded in the aftermath of the assassination of Maltese investigative journalist Daphne Caruana Galizia, who exposed global corruption, and paid particular attention to the fact that CBI passports are used by transnational criminals engaged in money laundering and financial crime. The Foundation has carried on her work, and is a network of crusading journalists who seek to uncover official corruption wherever it can be found. Daphne would have been proud of their purpose and anti-corruption goal.

We ask aloud for what purpose did Harlan Crow obtain an SKN CBI passport back in 2014? St.Kitts, where I openly operated as a career money launderer in the past, has a dark and sordid history involving international criminals who have used and abused the CBI passports they purchased there. It is worth noting that, while we have not yet seen a copy of Crow's St. Kitts passport, it is common that such identity documents are issued under aliases, or with slight changes in the names of the purchasers, which effectively confuses any law enforcement or customs & immigration authority that is seeking to identify the holder upon arrival at an international airport of entry.

So we ask again, why on earth does an American citizen, whose US passport gives him visa-free entry into anywhere but Russia and Iran, purchase a St. Kitts cbi passport? Does Justice Thomas also own one?

Tuesday, April 25, 2023


Remember the Law of Unintended Consequences? Whether it will be applied to the AI-powered future of AML/CFT compliance is worth discussing. The vastly expanded treasure trove of information and data potentially available to the compliance officer is a blessing, but with it comes what I see as increased responsibility. If compliance officers now have access to previously-unobtainable information, then they are charged with the proper use of same. This means you had best analyze it, and produce results. This means you stop money laundering and financial crime in your bank, cold.

If I am a wealthy shareholder at an international bank, I have paid a pretty penny for my stock, and like all high net-worth individuals, I fully expect a decent return on my investment. If the bank sustains a multi-million dollar civil penalty for AML or CFT failure, it will impact whether I will be receiving a dividend this year, or even next. The increased resources now available to compliance through the AI revolution means that I am now expecting results, not fines, penalties and agreements with prosecutors that end up costing me my dividend payment. You see, I have come to expect more from my bank's compliance department, now that their staff has AI to help them do their jobs better, and my lawyers agree that there is personal liability verging on compliance malpractice, meaning professional negligence, for failure to ferret out financial crime in the Age of Artificial intelligence. Enter litigation against compliance officers, individually, I fear.

If you think that's bad, it gets worse. Will American prosecutors also get on that increased compliance duty to catch the laundrymen, and indict for willful neglect?

As I see it, the only way out of this dilemma is to equip compliance officers with the knowledge to succeed, which candidly, I am not observing anywhere yet. Unless and until the banking community takes the time to actually teach their compliance staff the tradecraft of money laundering, that new data will neither be understood nor acted upon. The world's banks has consistently failed to educate their staff in most advanced and esoteric money laundering techniques, and until they do so, expect one or more the nightmares listed above to come true. Govern yourselves accordingly, ladies and gentlemen.

Saturday, April 22, 2023


His name was Ramon Navarro, and he was one of the real life desperados in my "Miami Vice" days, always whispered about by some of my clients. Known on the street as El Turco (The Turk), due to his Middle Eastern ethnicity, he specialized in stealing cash or drugs from traffickers, who could not very well report such strong-arm thefts to the police. Carrying a pistol in his sock, and a machine gun in the trunk, he was even known to bring his children along on his nighttime ripoffs. he received immunity from prosecution more than once due to his rendering of substantial assistance to law enforcement.

I once wrote about how he met his end, in an article on my blog entitled A Tale of Two Incidents, Miami 1991, Malta 2021 (February 10, 2021). Scheduled to be an important witness in the upcoming cocaine-for-100,000 M-16s trial of Panamanian General Manuel Noriega, he died in a mysterious and unsolved one-car crash in his BMW; it was no accident. A witness reported that a plainclothes civilian amazingly appeared, claiming to be a police officer, attended to Turco, and he suddenly expired.

Had artificial intelligence-powered platforms been in existence back them, individuals searching for information would have stumbled upon United States vs. William Saldarriaga, a then-pending 300 kilo criminal case actually in trial when Turco died. According to the facts of that case, which were later reported due to an appeal [987 F.2nd 1526 (11th Cir. 1526)], he was involved in a cocaine shipment seized by Colombian authorities in the Caribbean. That information was not available through normal resources, but an inquiry today would have found it in a heartbeat.

In performing due diligence, I often find that criminals have more than one thing going on at the same time, and it's that other activity which you tumble upon. Using resources employing AI gives you a better chance of finding that other thing earlier, rather than later. By the way, William Saldarraiga, a Colombian "businessman" was sentenced to the maximum, twenty years, and died in custody five years later. There are no happy ending to any of these stories.


Reports that it is a real possibility Iran may, either officially or unofficially, adopt the US Dollar as a second currency, are disturbing, due to the potential adverse effect such a move might have on global AML/CFT efforts,as well as the enforcement of international sanctions against Iran's ballistic missile and WMB programs. This could present a dilemma for both American law enforcement as well as a boon for the world's professional money launderers, who are constantly seeking to change criminal proceeds in other currencies into something they can use to clean their clients' profits.

The unchecked downward spiral of Iran's national currency, in large part caused by effective US sanctions, has reportedly resulted in the country's affluent to protect themselves by holding large amounts of Dollars, and the fact that the Central Bank of Iran earns fifteen per cent on currency demands of private banks for Dollars may just be a benefit to the Islamic Republic to unofficially, but really officially,to encourage dollarization.

How American law enforcement might deal with this enforcement nightmare is not known. We know that there are more US Dollars in circulation abroad than domestically, but those greenbacks are essentially moving due to market demands for stable hard currency, and not subject to any American controls. Just thinking about the possibilities of increased global money laundering opportunities, when a large cache of Dollars become readily available to criminal elements, is enough to keep both our law enforcement, as well as Treasury officials, sleepless and up at night.

Even if dollarization in Iran remains only a de facto reality, on the part of Iran's affluent, it represents a clear and present danger on many fronts. The US government had better start planning on how it can respond to such a development, before it becomes a reality, and the world's laundrymen and sanctions evaders reap the benefits.


The abrupt resignation of MIGUEL BORG, the Bank of Valletta's Chief Risk Officer and Executive Director, in the aftermath of the Steward Healthcare scandal has uncovered a trail of official corruption which, at the end of the day illustrates how Malta's Labour Party feeds its supporters at the expense of the country's taxpayers, resulting in more and more national debt, which must be dealt with down the road, as malta edges closer to insolvency.

Borg reportedly received, on addition to his six figure salary at the bank, €1.4 million, from two shell companies which only maintain a tiny one-room office: E CUBED CONSULTANTS and E CUBED ISLANDS. These companies are owned by BOV Chairman GORDON CODINA, the son of a former rabid supporter of Malta's radical Socialist first Prime Minister, Dominic Mintoff, who was responsible for turning the country into a corrupt banana republic, from which it has never extricated itself.

Codina has received several millions of Euros in Direct Orders from the Labour government since 2014; he also was paid €115 per hour as a consultant to Malta's Gaming Authority, a conflict of interest that was well known but never terminated in a country rife with such sweetheart arrangements between government agencies and the nation's insiders. As the result, the country's online gaming industry only banks at BOV. There are also links with former minister KONRAD MIZZI, and the list goes on and on. There is no end to the extent of systemic corruption in Malta, and individuals like Borg continue to benefit from it. Malta will eventually end up the only EU Member nation to eventually become insolvent; what happens to it at that point we fear to consider.