MONEY LAUNDERING PHANTOSMIA AND ITS TREATMENT

Phantosmia, which is a medical condition wherein you detect a smell that is not really present in your environment, has a money laundering equivalent: false positives. Every day, compliance officers involved in transaction monitoring observe data that your platform suggests may be a suspicious transaction, and it is up to them to rule it out as not only a reportable event for the purposes of a SAR, but which will cause further inquiry into whether evidence of money laundering, with or without additional financial crimes, is present. Are you smelling burnt toast* when there is none?

I have dubbed this money laundering phantosmia, and it occurs when non-criminal transactions are judged to be worthy of both a SAR, and further investigation, although in truth and in fact there is no money laundering in process. We wonder just how many non-criminal transactions each day cause compliance officers to hit the proverbial SAR panic button, advise their supervisor, and spend far too much time following up, only to eventually conclude that they were wrong. Of course, this is long after a Suspicious Activity report has been started, or even completed and filed. And you wonder why so many SARs never go anywhere.

The treatment for money laundering Phantosmia is as follows:

(1) A BASIC KNOWLEDGE OF YOUR BANK CUSTOMER'S INDUSTRY, ITS CUSTOMS AND IDIOSYNCRASIES: Are there specific traits and practices, involving their financial transactions which are quite normal, and are known to industry insiders, but appear to be otherwise? It's all about Know Your Customer, ladies & gentlemen. When compliance officers do not understand their customers' business, mistakes can occur, especially in this age where one may err on the side of caution.

(2) A COMPLETE WORKING KNOWLEDGE OF MONEY LAUNDERING TRADECRAFT GOES A LONG WAY TO RECOGNIZING MONEY LAUNDERING WHEN YOU SEE IT: If you are confident in your knowledge base of the subject, you know what to look for, and you also know when a fact pattern can't possibly result in a money laundering result or objective. Knowledge, in this instance, is power. Only when you know enough to rule out specific disorganized transactions without a goal can you stop wrong decisions that cause false positives to be reported.

Remembering that knowledge is power, and an educated compliance officer can artfully avoid the flde positive pitfalls. Train your people accordingly, and you will reap the benefits of increased efficiency, and less wild goose chases every day in your compliance department.

 

CORRUPT BARBADOS LEADERS ASSISTED DOMINICA PEPs IN LAUNDERING THE PROCEEDS OF CRIME ABROAD THROUGH A SHELL COMPANY NAMED IN THE PANAMA PAPERS

 

Adding to the recent allegations against 93 allegedly corrupt Barbados attorneys, accused of massive and systemic probate and real estate fraud is public outrage over the USD$1.2 bn missing from Dominica's treasury, and documents found in the Panama Papers linking a number of prominent Bajans to corrupt Dominica government leaders, as well as certain Politically Exposed Persons (PEPs), including the attorney ANTHONY ASTAPHAN, the adviser to Prime Minister ROOSEVELT SKERRIT, both of whom have been specifically named in Dominica media as involved.

Astaphan

A Panama corporation curiously named the NATIONAL BANK OF DOMINICA, operating out of a Barbados law firm, whose original board of directors included:

ROBERT T M TONG

DR VALDA HENRY

PATRICK PEMBERTON

PHILLIP ROLL

MERVIN RIVIERE

BIRMINGHAM ACKROYD

STEVEN ISIDORE

Skerrit

Allegations of money laundering by the corporate entity deserve an immediate investigation, as well as the activities of all the above-named individuals. Now that corruption in Barbados is being exposed, and finally seeing the light of day, perhaps we can get some answers. Dominicans have long known about this corruption; it is time that Bajans also have this information.

TRADECRAFT 101 PART SIXTEEN ; THE USE OF DISINFORMATION AND MISINFORMATION BY MONEY LAUNDERERS, TO DECEIVE COMPLIANCE OFFICERS

Before I went to law school, I enlisted in the US Army, and spent a substantial amount of my military service with the First Infantry Division in Vietnam in 1969-1970, mostly in the field searching for an elusive enemy who was extremely experienced in what we now refer to as asymmetric warfare. This involves the artful use of deceptive tactics whose civilian equivalents are disinformation and misinformation, the techniques of fooling your adversaries to achieve success.

Years later, I would employ some of the methods and techniques I observed while engaged against hostile forces as an attorney-turned money launderer, acting as a sort of financial Viet Cong,  constantly changing up and modifying my criminal activities, always seeking to spread confusion among my opponents, both in the financial, as well as law enforcement, worlds. Over a period of more than a decade, I honed my craft, to escape and evade detection and capture, and if some of my clients had paid attention to my instruction, I might very well still be engaged in that dark profession, had I succeeded in staying alive in a dangerous life where financial errors have dire consequences.

Some of those techniques that I used then are in common use today, because frankly, they are not generally recognized as disinformation and misinformation. For example:

1. USING CORPORATION NAMES THAT ARE SIMILAR TO THOSE OF ESTABLISHED ENTITIES. Bankers, especially compliance officers, often erroneously believe that these deceptively similar names are somehow part of a major Fortune 500 company. i once used "Continental" in a name, and DC lawyers wanted to know whether it was owned by Continental Grain.

2. FORMING COMPANIES IN OFFSHORE FINANCIAL CENTERS, WHERE BENEFICIAL OWNERSHIP CANNOT BE TRACED, BUT USING THEM DOMESTICALLY, WITHOUT DISCLOSING THE JURISDICTION OF FORMATION. Many compliance officers mistakenly assume that a local bank client, with a brick-and-mortar location ( e.g. office) is domestic. It isn't necessarily so.

3.FORMING COMPANIES WITH THE SAME EXACT NAME IN A NUMBER OF JURISDICTIONS. Another cute trick to fool wire transfer department; having previously passed a company's international wires, one coming in at the close of the day, which is stated must be sent forthwith, ends up going to an entity with the same exact name, but elsewhere.

4. OPENING AND CLOSING A CORPORATION, AND ITS ACCOUNTS, WITHIN A CALENDAR YEAR, AHEAD OF ANY REPORTING REQUIREMENTS WITH THE SECRETARY OF STATE. Only the original frontmen from the day of formation are ever shown, and they may be attorneys, accountants or financial services company agents.

5. MAKING A VERY SMALL CHANGE IN A RECOGNIZABLE CORPORATE NAME TO DISGUISE YOUR FRONT COMPANY. Sometimes, just modifying a name with a single letter, or a suffix, confuses compliance officers, some of whom may even consider it  simply a typographical error, and correct it in their records.  

We will discuss the use of Psyops ( Psychological Operations) by laundrymen, in a subsequent article.

WE IDENTIFY THE 12 OBSCURE PALESTINIAN TERRORIST ORGANIZATIONS OPERATING IN GAZA; ARE YOU UNWITTINGLY BANKING ANY OF THEM?

Compliance officers at international banks that wish to avoid sanctions and civil penalties for unwittingly providing material supports to designated Palestinian terrorist organizations are advised to carefully review this list, to determine whether any of these names has been encountered in any correspondence funds transfers, or otherwise in any way, in connection with accounts at your bank or non-bank financial institution. it might be wise to keep this list on hand, and to periodically alert your frontline compliance staff.

For further information, it is suggested that you access The Meir Amit Intelligence and Terrorism Center at terrorisn-info.org.il/en

• The following are the 12 organizations that participated in the joint exercise in the Gaza Strip, as reported by the joint operations room (Telegram channel of the joint operations room, December 26, 2020).
  • Izz al-Din Qassam Brigades (Hamas’ military wing)
  • Jerusalem Brigades (PIJ’s military wing)
  • al-Aqsa Brigades (Fatah splinter group)^[6]
  • Ayman Jawda Squads (Fatah splinter group)
  • Abd al-Qader al-Husseini Brigades (Fatah splinter group)
  • al-‘Asifa army (Fatah splinter group)
  • National Resistance Brigades (Democratic Front for the Liberation of Palestine military wing)
  • Abu Ali Mustafa Brigades (Popular Front for the Liberation of Palestine military wing)
  • Salah al-Din Battalions (Popular Resistance Committees military wing)
  • al-Mujahedin Brigades (military wing of the Mujahedin Movement, which split from Fatah in 2006 and adopted the Salafist Islamic worldview; it has close relations with Hezbollah and Iran)
  • Jihad Jibril Brigades (Popular Front for the Liberation of Palestine-General Command military wing)
  • al-Nasser Brigades (military wing of the al-Ahrar Movement, established in the Gaza Strip in 2007 by Khaled Abu Hilal. He also split from Fatah and reached a détente with Hamas).

LEADERS OF CBI EAST CARIBBEAN NATIONS WHOSE COUNTRIES PROFIT FROM CBI PASSPORTS WITH VISA-FREE ENTRY TO THE UK COME DOWN HARD ON BRITAIN

 

The prime ministers of the five East Caribbean states that have been selling Citizenship by Investment (CBI/CIP) passports to all who apply, and which allow the holders, as nationals of Commonwealth of Nations members, visa-free access to the United Kingdom, are hopping mad, according to Britain has cancelled visa-free access for the Commonwealth of Dominica, due to what the Home Secretary declares pose a risk to the UK."

That visa-free entry is, in a large part, the reason Iranians, Russians, Syrians and North Koreans all beat a path to the East Caribbean "CBI states," so that they can, posing as West Indians for former British territories, can slip into Europe, without being questioned and interrogated in a visa application, and rejected. it is the Golden Goose that Dominica's corrupt leadership, especially its Prime Minister Roosevelt Skerrit has benefitted from for two decades, as have leaders from the other four CBI passport-selling states. They all now fear, rightly so, that their lucrative CBI money train, which accept payment only in US dollars, may soon be over.

Not only are the five CBI EC states vigorously complaining, and even angry, about Dominica's "loss," but three other jurisdictions in Organization of Eastern Caribbean States (OECS), who don't even have CBI passports for sale, have also raised their voices in protest, in what most observers have concluded is nothing less than anti-UK  sentiment, couched as anti-Colonialism. This is about threats to the United Kingdom, ladies and gentlemen, about terrorist financiers, corrupt PEPs, thieving Russian Oligarchs, and other of the Usual Suspects in the world of transnational crime, all sneaking into the UK with impunity.

As their response, the EC Prime Ministers have privately stated that they intend to forthwith remove the image of the British Sovereign from their common currency, the East Caribbean Dollar. Whether this action has any effect upon King Charles III is doubtful, and their negative comments may even steel the resolve of the UH Home Secretary to yank the visa-free status of ALL the remaining four EC states, as the unintended consequences of the jingoistic actions of the PMs. According to reliable reports, the image will be removed by the EC central Bank Monetary Council.

In truth and in fact, given that the European Union has also had it with dangerous and unsuitable individuals clutching those CBI passports, and doing damage in Continental Europe's Schengen Zone. Only lone Malta continues to plague EU members with financial criminals carrying those purchased CBI passports; the other EU jurisdictions have been forced to shed their economic passport programs, and the EU has signalled that EC CBI passports may have a short shelf life. 

Are CBI passports an endangered species? We cannot say, but Eastern Caribbean leaders may have inadvertently cut the life expectancy of their passport sales programs short this week; Stay tuned.

WHATEVER HAPPENED TO RYAN BATEMAN, THE CANADIAN FRAUDSTER WHO STOLE $450m FROM INVESTORS IN THE CAYMAN ISLANDS?

 

RYAN BATEMAN, one of a group of fraudsters operating out of Grand Cayman several years ago, known unofficially as the CAYMAN GANG OF FOUR, he defrauded scores of retired Canadian pensioners out of an estimated four hundred and fifty million US Dollars ($450,000,000). Escaping a felony warrant in  the Cayman islands for inflicting "grievous bodily harm" in a domestic violence case, his last known location was the SOUTHWEST RANCHES, an extremely isolated rural area adjacent to the Florida Everglades, in Broward County, Florida. He may still be hiding out there. 

We have reported extensively on the blog regarding his activities. Where on earth is Ryan Bateman? Certain US law enforcement agencies would be interested in administering justice to this individual.

 

MALTESE CABINET SECRETLY CONVENES TO REMOVE PRIME MINISTER ABELA THROUGH NO-CONFIDENCE VOTE

If you thought the current chaotic political situation in the Republic of Malta was bad, it is about to get worse. The country's Cabinet is covertly conspiring to oust their ineffective Prime Minister, ROBERT ABELA, by a Vote of No Confidence. This method, which was previously responsible for Abela's Godfather and predecessor, JOSEPH MUSCAT, has been brewing remotely, and not in person, through a private WhatsApp chat group operating in total secrecy.

The Cabinet is apparently waiting for the opportune moment to spring into action, because RA has complete control over the Labour Party(PL) media apparatus, and they are well aware of this. The Cabinet has party insiders feeding them the directives RA is giving to his loyal henchmen at the Party's television station and on radio. They are patiently waiting for the right time to strike.

The reason that this rebel cabal of the Cabinet are furious at Abela is simple; he listens far more to his father's advice than he does to his cabinet. GEORGE ABELA, Malta's former President, is in effect leading the show, as if he was still in power. As we have previously explained, George has the reputation of a spiteful politician who hates opposition of any kind, and RA is well known to always listen to his father. Daddy's Boy accusations appear to have a basis in fact. Abela even ignored his wife's pleadings about the JEAN PAUL SOFIA scandal. She tried to convince him, in vain, to open a public inquiry in the case.  Even the tightly-controlled and censored major Maltese media is critical of how RA is mishandling the matter.

Who will replace Abela at Labour? No one candidate stands out at this time, for they fear becoming too assertive, thereby incurring George Abela's displeasure, with potentially dangerous consequences, in a country where organized crime works hand in hand with the most senior leaders in government. It can be hazardous to your health to politically cross George Abela; We wait for the ax to fall.

MALTA COURT CENSORS INDEPENDENT JOURNALIST; WE PUBLISH THE TRUTH HERE

    NOTE: THIS ARTICLE IS FOR READERS OUTSIDE OF MALTA ONLY.

A court in Malta, acting upon the request of Malta Today owner SAVIOUR BALZAN, has ordered deleted certain published messages linking Balzan with Maltese Businessman YORGEN FENECH, who has been charged with a role in the assassination of investigative journalist Daphne Caruana Galizia. we reprint the deleted segments here, exclusively for Maltese expats, as well as others who have an interest in Freedom of the Press.

INDICTED FORMER USMC OFFICER WHO TRAINED CHINESE FIGHTER PILOTS IN CARRIER LANDINGS CHARGED WITH MONEY LAUNDERING AND OTHER OFFENSES

We can expect that the United States Department of Justice will employ money laundering charges as an additional weapon against individuals engaged in prohibited activities involving China, if the case against DANIEL DUGGAN is any indication of this policy. Duggan, a former US Marine Major and fighter pilot, is fighting extradition from Australia. He is alleged to have trained Chinese pilots in how to launch and land jet aircraft on a naval aircraft carrier, without receiving the required permission from the United States Government. Duggan, currently an Australian citizen, surrendered his American citizenship after the period in which the alleged criminal activities occurred. He previously lived in China for an extended period of time.

According to reports from Australia, Duggan has been indicted in the United States on charges of:

1. Money Laundering Conspiracy.                                                                                                                  2. Arms Trafficking.                                                                                                                                          3. Conspiracy

It is alleged that Duggan, at the time an American citizen,  concealed $182,570 in prohibited transactions from the US Government while training what appear to be PRC fighter pilots. He reportedly worked for the Test Flying Academy of South Africa, which imported a T-2 Buckeye, an American jet trainer Duggan used, without export authorization from the US. China has been accused of approaching a number of former military pilots from the West to assist its military.

The use of money laundering charges, which can carry a prison term of twenty years, against defendants who commit crimes unrelated to financial crime, to bolster their potential exposure, has long been a tactic of the DOJ, and its application here to former MAJ Duggan's case is instructive, and a warning to an future defendants in China sanctions violations cases that they will face some serious prison time in indicted.

 

HAVE ALLEGATIONS OF ORGANIZED PROBATE AND REAL ESTATE FRAUD DAMAGED BARBADOS PM MIA MOTTLEY'S CANDIDACY FOR LEADERSHIP AT THE WORLD BANK?

Whether the ability of Barbados' Prime Minister, Mia Amor Mottley, to become the new leader of the World Bank, has been irretrievably damaged by allegations that she is linked to the massive probate fraud and real estate fraud, committed by a large number of prominent lawyers, which is rampant in her country, has become an open question. The Bajan plaintiffs, in a civil suit filed last week in the United States, allege that she is part of a vast conspiracy to deprive a major portion of the population of their inheritance.

While specific details of Mottley's alleged role in the systemic fraud, whereby significant tracts of valuable real estate are excluded from probate, and are diverted through counterfeit warranty deeds to corrupt attorneys, who then sell of the land to foreign investors and hotel developers, have not yet been pled in the case, the plaintiffs have named her as a party defendant, together with another 92 Barbados lawyers, in what is claimed to be an organized civil racketeering enterprise which exists to deprive Bajan of their patrimony. The facts filed in the case, if proven, could support criminal charges of money laundering in the United States, as many of the defendant attorneys have allegedly invested what are stated to be the proceeds of crime there.

This fraud occurs when aged relatives pass away, and local lawyers allegedly remove a portion of the deceasedents' lands from the estate, while delaying probate, sometimes for years, giving the time to prepare and record counterfeit deeds, alter public records, and destroy irreplaceable original documents, all as part of a well-planned operation designed to unjustly enrich themselves and others. 

The filing of the suit has resulted in a widespread outcry in Barbados, among others who also claim to have been defrauded, for justice for those claiming to also be victims. Barbados' tightly controlled media has thus far ignored the civil suit, and some Bajans reportedly have stated that this is because of unofficial media censorship, coming down from senior government officials, whose power to being criminal charges for purely political reasons to those interests that they believe threaten the status quo, has occurred in the past. We shall continue to monitor all developments in this matter as they occur.

JOSEPH MUSCAT, MALTA'S DISGRACED EX-PM, FEARING ARREST, SEEKS PARLIAMENTARY IMMUNITY THROUGH ELECTION AS MEP

 

JOSEPH MUSCAT, the defrocked & disgraced former Prime Minister of the Republic of Malta, is attempting to do what America's indicted former president, Donald Trump, is attempting: to avoid prison by being elected yet again. Muscat is actively seeking to be a candidate in the upcoming European union parliamentary MEP elections, which are scheduled to occur June 6-9, 2024. He desperately wants the Parliamentary Immunity which comes with the position. He is said to be under criminal investigation  in more than one jurisdiction for Foreign Corrupt Practises Act/Bribery Act violations. Haven't his lawyers already told him MEP status will not protect him outside of the European Union?

 He was previously an MEP from Malta during the period 2004-2008, and that was where his membership on the Azerbaijan Membership Committee reportedly exposed him to corrupt Azeri connections that he later allegedly helped launder government funds illegally diverted abroad through Malta's Iranian-owned Pilatus Bank.

The source of the information, an Insider in the PL Executive Committee* who contacted us in confidence on WhatsApp, has advised that the current PM, Robert Abela, presently under attack from within his party, does not want Muscat representing Malta in the European Parliament, due to his potential criminal liability in a number of foreign jurisdictions. Will he prevail, or will Muscat continue to dominate PL politics? 

Muscat continues to use his diplomatic passport when traveling abroad, notwithstanding that he is not entitled by law to have one after he left public office, as it allows the holder to totally bypass customs officials at international airports of entry overseas. It should be confiscated.

__________________________________________

*Consider this an open invitation to all PL Executive Committee Members to contact this blog, in complete confidence that their information will be received anonymously, giving them peace of mind,about disclosing additional Muscat statements that confirm his manipulation of the party machine, to guarantee him PL support for his candidacy. Their statements and identity. are protected by our journalist-source privilege.

DID THE UK REVOKE VISA-FREE ACCESS PRIVILEGES FOR DOMINICA'S CITIZENS DUE TO ENTRY OF TERRORISTS WITH CBI PASSPORTS?

We believe that the recent cancellation of visa-free entry for holders of passports from the Commonwealth of Dominica, and the imposition of visa requirements was due in large part to well-founded British fears that terrorists can, and have, entered the United Kingdom through the use of Citizenship by Investment (CBI) passports issued by the five East Caribbean states in the Commonwealth. The new visa requirements are a direct response to that security threat.

This is not a fiction; reports have been circulating for some time to the effect that terrorist financiers, as well as terrorists themselves, have entered the UK under the blanket visa-free status accorded St. kitts, Antigua, Dominica, St. Lucia and Grenada. We were further reminded of that fact by the report that two individuals deported from Britain by the authorities due to terrorist associations illegally re-entered the UK  by acquiring Dominica CBI passports.

We have been warning for several years that these CBI passports, which are issued by jurisdictions known for corruption at the highest level, can be purchased by literally any terrorist with a sufficient quantity of cash, in US Dollars, and constitute a Clear and present Danger to the National Security of the United Kingdom, as well as of the Members of the European Union (EU), which also extended visa-free entry privileges.

Note well the precise language in the press release issued by the UK Home Secretary,  Suella Braverman:

 “Careful consideration of Dominica’s and Vanuatu’s operation of a citizenship by investment scheme has shown clear and evident abuse of the scheme, including the granting of citizenship to individuals known to pose a risk to the UK.” 

CARIBBEAN MONEY LAUNDERERS FROM THE TAX HAVENS NOW HAVE CARTE BLANCHE VISA-FREE ENTRY INTO USVI

 

 The Virgin Islands Visa Waiver Act of 2022, which allows foreign nationals from the island republics of the Caribbean immediate, visa-free access to the USVI, may have been enacted to facilitate trade and tourism, but there are definitely unintended consequences of importance regarding money laundering in the United States. Obviously, the Department of the Treasury was not consulted when this bill was presented to the US Congress. Here's why.

Most of the jurisdictions in the East Caribbean remain offshore financial centers, a nice term for tax havens where money laundering and transnational financial crime still flourishes. Since their domestic economies depend, to a large extent, upon their "offshore" business, anti-money laundering and countering the financing of terrorism enforcement is a joke, meaning that it essentially does not exist in those countries. Dodgy individuals who would otherwise fail to qualify for a visa can now freely enter the USVI through a simple visa-waiver procedure, to conduct whatever illegal business they wish, with impunity. 

The US Virgin Islands is an American possession, it is United States territory. Therefore, all flight between the Continental United States (CONUS) and the USVI are considered domestic flights. Consider for a moment what this means for money launderers; they are therefore free to move cash or  "monetary instruments" directly to St. Thomas, via scheduled airline flights, in any amount, without fear of violating the $10,000 Customs reporting requirement, because it's technically NOT an international flight.

I can tell you from a decade of experience on that side of the law that money launderers have used the loopholes presented by intermediary jurisdictions successfully for decades, in this manner. The Caribbean banker/lawyer/money launderer entered the US Virgin Islands under the visa-waiver program, is met by an American cash courier arriving from the mainland, makes the exchange, and returns quietly to his tax haven home. The American courier never violates US Customs laws, and you can be certain that the Caribbean laundryman's exit from St. Thomas, among the throng of fellow West Indians returning home, is not scrutinized, especially if he has bought a suitcase of consumer goods. I have played that game myself in other places; it works.

Perhaps American Federal law enforcement agencies might want to consider assigning a task force to profile the arriving Caribbean "visitors" because they may find out that some not the tourists that they appear to be. It's just another application of the Law of Unintended Consequences.

   

READ THE COMPLETE TEXT OF THE SUIT AGAINST BARBADOS LAWYERS AND GOVERNMENT OFFICIALS WHO ARE LAWYERS FOR PROBATE AND REAL ESTATE FRAUD

 

Due to multiple requests, we are attaching herewith the Verified Complaint in Alex Mitchell et al vs. Mia Amor Mottley, et al, filed this week in Miami-Dade County, Florida, being Case Number 23-19729 CA-01(Cir. Ct.).

VICTIMS OF MASSIVE PROBATE AND REAL ESTATE FRAUD IN BARBADOS SUE 93 ALLEGEDLY CORRUPT LAWYERS, INCLUDING PRIME MINISTER MOTTLEY

A number of Bajans who have lost valuable real estate which they should have properly inherited from their families, but which was taken from them through massive, organized probate fraud, conducted by several dozen prominent Barbados attorneys, acting in concert, have brought an action in Miami-Dade County Circuit Court, alleging repeated violations of Florida's Civil RICO law, Chapter 895 Florida Statutes. This case represents an indictment of the systemic lack of integrity of Barbados' legal community, and the government's role in facilitating widespread organized fraud, which many legal observers view as a Kleptocracy masquerading as a democracy. 

Included as defendants are a number of attorneys now serving in senior government posts, including sitting Prime Minister MIA AMOR MOTTLEY, and members of the judiciary who were formerly private attorneys. The Plaintiffs allege that through the forgery of  conveyances , fraud, material misrepresentation, exploitation of uneducated clients, manipulation of official records (especially the real property register), and probate files, the Defendant lawyers have cheated the Plaintiffs out of the right to inherit family real estate valued at hundreds of millions of dollars, if not more, over a 50-year period.

A common type of real estate fraud exploited by corrupt lawyers there explained to me involved the use of sequential warranty deeds, conveying stolen realty, relying upon a loophole in Barbados law involving the creation of legally sufficient title to convey to a third party. Many old family estates were looted in this manner; the status of real estate titles to most Barbadian real estate is questionable as the direct result of this illegal technique. Several extremely valuable hotel properties are claimed by old-line Barbadian families who allege they were stolen by local attorneys and sold to foreign developers and hotel chains.     

The Plaintiffs asks the Court to order a transfer to them of their substantial real and personal property assets owned by the Defendants, and located within the State of Florida, which was allegedly purchased with funds the Defendants obtained through sale of the properties they reportedly stole through rampant fraud, and for money damages that exceed $50,000. Justice, which cannot be had in Barbados' corrupt court system, may turn out to be served against these ninety-three lawyers elsewhere.

BE ALERT FOR MONEY LAUNDERERS OPERATING THEIR OWN VERSION OF RISK MANAGEMENT IN YOUR BANK

 

One of the reasons that money laundering continues to be repeatedly successfully practiced is its reliance on flexibility. While most compliance officers understand that most laundrymen have not only advanced professional educations that may exceed their own, and are zealous about their roles which comes from the criminal penalties that result from failure in their dark pursuits, the broad range of their operations, often even in the same financial institution, is often neither understood nor grasped. 

We often remark how money launderers' only limitation is their imagination; they take the personal cost of failure seriously, given the possible wrath of their criminal clients should their illicit profits be seized and lost. Therefore, being fully aware of the possible adverse consequences of the loss of funds, they often  engage in their own version of risk management: diversification in more than one dimension.

While they generally seek the most efficient ways to move and clean the proceeds of crime, they employ tactics designed to insure the best chance of success. Once compliance officers understand these principles, and why they are in place among many money launderers, the chances of uncovering one of their operations in progress increases.

Here are some of those tactics:

(1) ROAD-TESTING A PIPELINE: Repeatedly moving relatively small amounts of money through a specific account or accounts, prior to risking a substantial sum, which then is done only once, and then the account abandoned, and all connections at both ends severed, and not used again, ever. The laundryman the moves on to other banks. You then uncover his operation, but only after he has already. departed.

(2) ALWAYS OPENING AND CLOSING FRONT CORPORATIONS WITHIN THE REPORTING PERIOD, TO DENY THE DISCLOSURE OF ANY INFORMATION,  OTHER THAN NOMINEES AND FRONTMEN: The so-called "window of opportunity," the time frame before annual reporting must be made to regulatory authorities, such as Secretary of State,  and after corporate formation, or acquisition, is their sole period in which to utilize that entity. You allow the corp to be administratively dissolved, giving the appearance of a defunct legitimate entity that went out of business.

(3) REDUCING RISK THROUGH LIMITING VOLUME AND SPREADING RISK: insuring that there will not be one major loss, resulting from a funds transfer being seized, by dividing it up in a number of  transactions, all using separate front companies and accounts. In that manner, should one account or transaction be exposed, all the others, being unconnected, pass through without incident. Drug traffickers often use the same method, in shipping narcotics, so that even if one aspect of their operation is discovered, all the others get through. 

(4) IMITATING OR SIMULULATING LEGITIMATE COMMERCE: Shutting down successful operations for periods, so as not to establish a pattern of activity that might be evident, or reducing them, seeking to imitate the fact that legitimate businesses often have periods when profits or shipments decline, for seasonal or market reasons. The idea is to appear to be just another company in that particular industry, so you fit the low-risk profile.

The goal of laundrymen is to transfer the proceeds of crime, cleaning it in the process, before investing it elsewhere, and to artfully deceive you into ignoring their operation. Catch them in the act.

 

  

VICTIMS OF PROBATE AND REAL ESTATE FRAUD TO MOVE AGAINST CORRUPT LAWYERS IN BARBADOS

The systemic corruption in Barbados, whereby attorneys steal valuable tracts of real property when handling probate matters, as well as having public records fraudulently altered or destroyed, and creating forged instruments, which has not been previously addressed, reportedly will now be the subject of legal action abroad. A number of the victims plan to bring civil actions against the offending lawyers, in a forum outside of Barbados' tainted legal system, where powerful attorneys and government officials can improperly influence the outcome, through prevailing upon the country corrupt judiciary to delay proceedings indefinitely, or  simply dismiss cases against lawyers.

The matter will have international implications, for many of the lawyers who allegedly stole real property have gone on to serve in local government at the national level, and the stain of exposure of their dark deeds could affect their reelection prospects. It is noteworthy that when such criminal actions regarding lawyers stealing real estate from the descendants of the original owners were exposed in St. Lucia, it resulted in a change of government. Whether the ensuing scandal will have the same outcome is not known, because of the stranglehold that corrupt Bajan lawyers have on the political system.

When these proceedings become a matter of public record, we intend to cover all developments as they occur. Pushback from the lawyers involved in illegal activities is expected, including attempts to censor the news in local media, but elsewhere in the East Caribbean, where similar misconduct among attorneys is common, it is likely that there will be media commentary for Bajans to review.

ARE YOU RUNNING AN EFFECTIVE AML/CFT TRAINING PROGRAM, OR RELYING UPON INADEQUATE CERTIFICATE ACQUISITION?

 

For those compliance officers who live and die, based upon how many initials their staff can append after their name, indicating how many AML certificate programs they have completed, think again. Those programs, most of which area not academic degrees, but based upon passing exams, or attending seminars, are not resulting in a significant reduction of successful money laundering operations in the world's banks. If anything, money laundering has expanded exponentially, notwithstanding the plethora of AML/CFT alphabet-conferring programs that are offering what they claim are credentials in the field.

In the thirty years since the certificate programs became the rule, rather than the exception among compliance officers, the trillion dollars of successful money laundering operations has grown, even if we take conservative estimates. Laundrymen are taking full advantage of the options that the growth of technology has given them, and moved into new industries and fields that they previously ignored. The programs, which teach regulatory requirements, and rules-based procedures, are not getting the job done.

This means that the minimum required knowledge base of compliance officers has grown, while the certificate programs are studiously ignoring the problem. There are two issues that directors of compliance must now address regarding the training of their staff:

(1) Are they operating an in-house ongoing program that educates their staff in money laundering tradecraft, the actual methods and techniques employed by money launderers?

(2) Are they teaching the efficient use of AI-powered AML/CFT platforms, so that their staff, once savvy about recognizing and understanding money laundering techniques, can pick them out of all this new information now available to them?

The combination of tradecraft education and proper use of Artificial Intelligence-equipped systems will afford your staff the ability to find the laundrymen through the identification of their techniques. Pairing advanced knowledge with newly-available information is the trick to uncovering ongoing money laundering in your bank. Go find those laundrymen, and put those certificates in the drawer; they are not helping you.

MONICA ELFRIEDE WITT, EX-USAF TECHNICIAN AND DEFENSE CONTRACTOR WHO DEFECTED TO IRAN

 

WHY WON'T BVI PREMIER ANDREW FAHIE PLEAD GUILTY ? THE EVIDENCE IS STRONG AGAINST HIM

The late John Ashe

Apparently, the Court's most recent rescheduling of the trial of ANDREW FAHIE, the former Premier of the British Virgin Islands wasn't sufficient time for defense counsel, who asked for, and received, an additional delay, to June 23, 2024. The identity of a Confidential Informant has not yet been disclosed to Fahie's attorney, and certain of the Discovery has not been transcribed.

Fahie's position, given the volume of incriminating evidence that has been made publicly available, plus the likely testimony of his two co-defendants, who have already pled guilty, and await sentencing. In order to obtain that prized Sentence Reduction next year, they will need to appear at the eventual trial on the Government's behalf. It makes you wonder why Fahie doesn't mitigate his significant exposure to a long prison sentence, by changing his plea, and cooperating.

 Does he fear that there may be personal consequences if he testifies against other Caribbean leaders, especially those in the British Virgin Islands, to reduce his ultimate sentence? Readers who recall the very suspicious death of the corrupt Antiguan diplomat John Ashe, as well as of other individuals far less prominent, know that the region has a history of violence against cooperators, and Antigua has come up in the conversation about who Fahie might be able to incriminate. Fahie may fear retribution, against himself, or others in the BVI. Something about his continued defense doesn't make sense.  

WHY JOURNALISTS COVERING COMPLEX FINANCIAL CRIME CASES SHOULD HAVE A LEGAL EDUCATION

Ex-Theranos CEO Elizabeth Holmes to be released from prison 2 years early (sic)

Complex financial crimes should be reported by those who have a basic knowledge of criminal law and procedure. Once again, I am seeing incorrect information published, and then repeated elsewhere ad nauseam.  Federal Inmates earn 54 days of Gain (Good) Time a year off their sentences, provided they follow the institutional rules. Elizabeth Holmes did not received a Sentence Reduction. That's around 15%; such a basic fact should be known by the financial press. This is why journalists with law degrees are better equipped to cover financial crime cases.

READ CFPB PRESS RELEASE AGAINST BANK OF AMERICA FOR $80.4m in UNFAIR CONSUMER FEES

Bank of America, N.A.

On July 11, 2023, the Bureau issued an order against Bank of America, N.A., which is a national bank headquartered in Charlotte, North Carolina with branches and ATMs located in 38 states and the District of Columbia. When a consumer writes a check or authorizes an ACH transaction to a merchant or other payee using their deposit account at Bank of America, the merchant or other payee may then present that check or ACH authorization to the bank for payment. Until February 2022, if a consumer did not have sufficient funds in their account to pay for the transaction and the bank decided not to pay it, Bank of America assessed the consumer a $35 non-sufficient funds fee. Merchants commonly “re-present” these returned transactions—that is, they again try to receive payment—often multiple times. For many years, Bank of America assessed non-sufficient fund fees on ACH and check transactions that it returned unpaid even though it had already assessed a $35 fee for the same ACH or check transaction that it had previously returned unpaid (i.e., repeat non-sufficient fund fees). Bank of America would assess these repeat non-sufficient fund fees potentially as soon as the next day after the initial transaction. From September 2018 until February 2022, Bank of America generated hundreds of millions of dollars in such fees. The Bureau found that Bank of America’s assessment of repeat non-sufficient fund fees was unfair in violation of the Consumer Financial Protection Act of 2010. The Bureau’s order requires Bank of America to refund all repeat non-sufficient fund fees that it collected since September 2018 and has not yet refunded, totaling approximately $80.4 million in redress. The bank must also pay a $60 million civil penalty to the Bureau. The Office of the Comptroller of the Currency (OCC) concurrently issued an order against the Bank separately fining it $60 million.

CARIBBEAN EARTHQUAKE NEWS MAY SIGNAL ATTEMPTS TO MOVE CRIMINAL PROCEEDS INTO THE REGION UNDETECTED

 

Last night, an earthquake, registering 6.6 on the Richter Scale, occurred more than 200 miles north of Antigua & Barbuda. Although no damage or Tsunami issues were observed, compliance officers would be well advised to remember that smart money launderers often use natural disasters as a smokescreen to shield their movement of the proceeds of crime. Remember, the East Caribbean contains offshore financial centers with a long and sordid history of accepting the proceeds of narcotics crime and fraud, and corrupt bankers that ask no questions still hold senior positions there.

Laundrymen generally, but not always, disguise any criminal funds transfers made in the aftermath of a natural disaster by showing them as payments from charitable organizations, NGOs or nonprofits. Compliance officers observing such post-event transfers into the region should carefully vett the sender, which is often using the name of a known charity, but with a minute change in the exact name, to give the impression that it is an established entity. Of course, it is a but well-executed deception, using a name very slightly different, even down to the use of a non-Latin/Roman alphabet letter or letters very similar to the real thing. 

The the United States, we have observed post-hurricane movement of illicit profits by experienced money launderers, because they know that, in the chaos of a natural disaster, compliance officers are often seconded to tasks other than their primary responsibilities, leaving a vulnerability, and even those that are still on their assignments, the public policy of rushing aid to the victims of natural events may cause them to approve and pass transactions that they might otherwise take a hard look at.

 

FUGITIVE GAL LUFT, "WHISTLEBLOWER" CHARGED AS CHINESE SPY, IRANIAN OIL SANCTIONS EVADER AND ARMS TRAFFICKER

NOTE: This is the individual touted as the whistleblower on President Biden.

    ( DOJ Press release July 10, 2023)

Gal Luft, a Dual U.S.-Israeli Citizen, Allegedly Evaded FARA Registration While Working to Advance the Interests of China in the United States and Sought to Broker the Illicit Sale of Chinese Manufactured Weapons and Iranian Oil to China

A dual U.S.-Israeli citizen who serves as the co-director of a Maryland-based think tank was indicted today for allegedly engaging in multiple international criminal schemes.

According to court documents, Gal Luft, 57, is charged in an eight-count indictment with offenses related to willfully failing to register under the Foreign Agents Registration Act (FARA), arms trafficking, Iranian sanctions violations and making false statements to federal agents. Luft was arrested on Feb. 17 in the Republic of Cyprus based on the charges in the indictment. Luft subsequently fled after being released on bail while extradition proceedings were pending and remains a fugitive.

According to the allegations contained in the indictment, for years, Luft conspired with others in an effort to act within the United States to advance the interests of the People’s Republic of China (China) as agents of China-based principals, without registering as foreign agents as required under U.S. law. As part of this scheme, while serving as the co-director of a Maryland-based nonprofit think tank, Luft agreed to covertly recruit and pay, on behalf of principals based in China, a former high-ranking U.S. government official (Individual-1), including in 2016 while the former official was an adviser to the then-President-elect, to publicly support certain policies with respect to China without Luft or Individual-1 filing a registration statement as an agent of a foreign principal with the Attorney General of the United States, in violation of FARA.

Among other things, in the weeks before the 2016 U.S. presidential election, Luft and a co-conspirator (CC-1), who is a Chinese national and worked for a Chinese nongovernmental organization affiliated with a Chinese energy company, created a written “dialogue” between CC-1 and Individual-1, in which Luft wrote Individual-1’s responses and included information that was favorable to China. The dialogue was then published in a Chinese newspaper online and sent to, among others, individuals in the United States, including a journalist and professors at multiple U.S. universities. When Luft was writing the dialogue, CC-1 told Luft that “[i]n these articles, we do not want to spill all the beans yet, just enough to let ‘people’ know he [i.e., Individual-1] is in the corridor of power to be. Just broad stroke policy consideration that leaves plenty of room for interpretation and imagination to be filled in later.” After the purported “conversations” were published, Luft told CC-1 that certain information, favorable to China, had been “tucked between the lines.” Shortly after the 2016 election, Luft and CC-1 also discussed possible roles Individual-1 might have in the incoming U.S. administration, and discussed Individual-1 taking a “silent trip” to China. Luft responded that “[w]e are debating about his role in the new admin. There are all kinds of considerations . . .We should talk ftf [i.e., face-to-face] as there can be a supremely unique opportunity for china.”

Second, Luft conspired with others and attempted to broker illicit arms transactions with, among others, certain Chinese individuals and entities. In his role as a broker or middleman, Luft worked to find both buyers and sellers of certain weapons and other materials, without a license to do so as required under U.S. law, in violation of the Arms Export Control Act. Among other things, Luft worked to broker a deal for Chinese companies to sell certain weapons to Libya, including anti-tank launchers, grenade launchers and mortar rounds (which Luft and his associates referred to in coded language as “toys”). Luft also worked to broker deals for certain weapons to be sold to the United Arab Emirates, including arial bombs and rockets. Luft further worked to broker deals for certain weapons to be sold by a Chinese company to Kenya, including unmanned aerial vehicles (UAVs) – and specifically “strike” UAVs, which Luft acknowledged “[t]he US doesn’t want to sell[, . . .] hence the opportunity.” Luft also discussed brokering a deal for weapons to Qatar, and told CC-1 that Israel was “not a good fit” as the middleman for the deal because it had the “[s]ame problem the [] Q [i.e., Qataris] have w uncle [i.e., the United States]. Need a third party. . . . I will activate.” In his role as a broker for illicit arms deals, Luft worked on a commission basis, and traveled to meetings and received and passed on documentation needed to secure the deals. During a voluntary interview with U.S. law enforcement in which he was asked questions about his involvement in arms trafficking, Luft made multiple false statements, including that he had just been checking prices for a friend and had not sought to engage in or profit from arms deals.

Third, Luft conspired with others and attempted to broker deals for Iranian oil – which he directed an associate to refer to as “Brazilian” oil in an effort to conceal the activity and evade sanctions – in violation of U.S. sanctions against Iran and the International Emergency Economic Powers Act (IEEPA). In his role as a broker or middleman, Luft solicited buyers and passed on pricing and other information. One offer letter for Iranian oil that Luft received noted that the “origin” of the oil was “Iranian / It can be presented as UAE origin without Iranian papers.” He also assisted in setting up meetings between Iranian representatives and a Chinese energy company for the purpose of discussing oil deals. During a voluntary interview with U.S. law enforcement in which he was asked about his role brokering deals in Iranian oil, Luft made multiple false statements, including that he had tried to prevent oil deals with Iran and had not been present during meetings with the Chinese energy company and Iranians.

Luft is charged with the following offenses, which carry the maximum prison terms listed below. A federal district court judge will determine any sentence after considering the U.S. Sentencing Guidelines and other statutory factors.

Count	Charge	Maximum Prison Term
One	Conspiracy to violate the Foreign Agents Registration Act	Five years
Two	Conspiracy to violate the Arms Export Control Act	Five years
Three	Violation of the Arms Export Control Act (relating to Libya)	20 years
Four	Violation of the Arms Export Control Act (relating to the United Arab Emirates)	20 years
Five	Violation of the Arms Export Control Act (relating to Kenya)	20 years
Six	Making false statements	Five years
Seven	Conspiracy to violate the International Emergency Economic Powers Act	20 years
Eight	Making false statements	Five years

The FBI New York Field Office and FBI’s Counterintelligence Division are investigating the case, with valuable assistance provided by the IRS-Criminal Investigation (IRS-CI) and the Justice Department’s Office of International Affairs.

Assistant U.S. Attorneys Daniel C. Richenthal and Catherine Ghosh for the Southern District of New York and Trial Attorney Scott Claffee of the National Security Division’s Counterintelligence and Export Control Section are prosecuting the case.

If you have any information about Luft’s whereabouts, please contact your local FBI office or the nearest American Embassy or Consulate. Tips can be reported anonymously and can also be reported online at tips.fbi.gov.

An indictment is merely an allegation. All defendants are presumed innocent until proven guilty beyond a reasonable doubt in a court of law.

Updated July 10, 2023

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July 10, 2023

PRESS RELEASE

Former FBI Analyst Sentenced for Retaining Classified Documents

A former analyst with the Kansas City Division of the FBI was sentenced in federal court today for illegally retaining documents related to the national defense at her residence.

June 21, 2023

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