CULTURAL LITERACY AND MONEY LAUNDERERS

Further to my prior articles, THE IMPORTANCE OF CULTURAL LITERACY IN AML/CFT COMPLIANCE (December 11, 2024)* and TO BE EFFECTIVE, A COMPLIANCE OFFICER MUST POSSESS CULTURAL LITERACY; THIS REQUIRES AN UNDERGRADUATE LIBERAL ARTS EDUCATION **                ( November 7, 2023), It is important for compliance officers to understand that successful money launderers also possess Cultural Literacy.

While I was what you call an Accidental Money Launderer, having fallen into that dark art to assist some fellow Vietnam Veterans smuggling marijuana, and then becoming a "full-service" landryman for cocaine traffickers, I had come into the job with the necessary skill set, acquired from education, training, experience. I had acquired knowledge of political geography from a number of hobbies during my youth, understood asymmetric and covert conduct from my Vietnam tour, and had not only a liberal arts & a legal education but hands-on experience at an international law firm, where I was working in the banking division. In short, I had all the cultural, academic and vocational background one needs to be considered culturally literate for money laundering operations, where one applies all that knowledge to clean dirty money right in front of compliance, using techniques that are rarely recognized or understood by individuals not blessed with compliance cultural literacy.

While I cannot expect all compliance officers to have such an extensive preparatory background, If you want to catch laundrymen in the act, you must at least have a firm background in advanced Tradecraft, those effective techniques and methods of money laundering that you cannot find in a manual or a seminar. I invite you to attend my three-part January presentation on esoteric, obscure and exotic techniques; it will open your eyes to money laundering on a different level.

For further information: https://titc.io/kenneth-rijock-the-laundry-man

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*https://rijock.blogspot.com/2024/12/the-importance-of-cultural-literacy-in.html

**https://rijock.blogspot.com/2023/11/to-be-effective-compliance-officer-must.html

CHINA'S NEW 2025 AML LAW REVISION GRANTS EXTRATERRITORIAL JURISDICTION; WILL IT BE USED FOR POLITICAL PURPOSES, TO THREATEN WESTERN BANKS?

If you follow new developments in global AML/CFT legislation, you should know that China in November passed a major revision to its "Anti-Money Laundering Law of the People's Republic of China," which takes effect on 1 January, 2025. Hidden in the additional tools available to the PRC is the establishment of Extraterritorial Jurisdiction of its AML laws. This means that, under certain certain circumstances, financial institutions in the West could end up being charged with violation of the PRC's powerful new legislation; Just imagine the effect on their China business.

Unfortunately, the restrictions on use of this expanded jurisdiction are broad enough for Chinese prosecutors to employ to just about any situation:
(1) Threatens China's sovereignty and security.
(2) Infringes on the legitimate rights and interests of Chinese citizens, legal entities and other organisations.
(3) Disrupts financial order in the PRC.

The effect on Western, and specifically US, financial institutions, will be carefully watched, taken in the context of public exposure of the billion dollar fraud, money laundering and corruption scandal that broke in 2024, regarding the five East Caribbean Citizenship by Investment (CBI/CIP). Since this new and impending Chinese legal tool has been known to the Western compliance community for some time, we wonder aloud if it has caused any of the major American banks that provide correspondent banking services to the CBI agencies to refrain from taking any action to close those accounts, due to a well-placed fear that China could respond by charging such a bank with money laundering, purely for political purposes. The half dozen US banks in the correspondent banking category all are engaged in international trade transactions with China.

Such an action would most likely have a serious economic effect on that bank's lucrative China business, and affect its ability to serve its international manufacturing clients. Is this why no major US bank has ignored the CBI scandal, possible loss of major business? This form of economic blackmail, bordering on extortion, may be the reason American banks are asleep on the CBI money laundering issue.

SAINT LUCIA MINISTER RICHARD FREDERICK DENIES HE IS ASSISTING U.S. IN CIP CRIMINAL INVESTIGATION, BUT HIS ROLE IN THE SCANDAL COULD BRING DOWN THE RULING LABOUR PARTY

RICHARD FREDERICK, who serves as Minister for Housing and Local Government, has reportedly now contacted his sources in American law enforcement to make sure that they know of his innocence in the CIP fraud, money laundering and corruption scandal, which implicates both the Prime Minister, and his deputy, Minister ERNEST HILAIRE. Frederick, who is known to have a prior relationship with US agencies, and who has used those connections in the past to avoid arrest, now is being labeled by his Labour Party as the probable Cooperating Individual in the CIP GALAXY/CHINA scandal. See: "Richard Frederick ... is alleged to be a Narcotics Trafficker in U.S. Diplomatic Cable".   https://rijock.blogspot.com/2024/08/saint-lucia-minister-trying-to-divert.html

His fellow ministers, who were reportedly shocked after the revelations contained in the production of the Galaxy CIP contracts, and noting Frederick's support of the PM and Hilaire on his program "Can I Help you?," are concerned that the developing scandal will end the Labour Party's domination of the Saint Lucia political scene. While we do not have any information regarding the identity of the Cooperating Individual in the American CBI/CIP investigation, and are therefore unable to confirm or deny Frederick's role as a CI, we shall continue to seek the truth in the CIP scandal.

BANK OF AMERICA, SARS, THE CITIZENSHIP BY INVESTMENT SCANDAL, CARIBBEAN GALAXY/CHINA AND JEFFREY EPSTEIN

A memorandum prepared for the United States Senate, regarding the unusually late filing of Suspicious Activity Reports, or SARs, by BANK OF AMERICA, which were reportedly filed years after $140m of suspicious payments to JEFFREY EPSTEIN, has recommended that the matter be turned over to the Financial Crimes Enforcement Network (FinCEN), to investigate the bank's conduct. Apparently, the bank failed to file the SARs until six months after his indictment and suicide in Federal Prison, and after a civil RICO lawsuit against Epstein's estate was filed. Who made that command decision, we wonder, Compliance or the executives in charge of the accounts?

If there is a corporate culture at any bank, to delay filing of a SAR for a valued or lucrative client until possible misconduct is publicly exposed, then questions should be raised, regarding the effectiveness of the bank's risk-based compliance program. Were critical compliance decisions being trumped by account executives responsible for for the client, due solely to revenue considerations?

We bring this up because, with the huge amount of publicity over the unfolding fraud, money laundering and corruption scandal over Caribbean Citizenship, the bank continues to maintain correspondent accounts for indigenous East Caribbean financial institutions that service CBI/CIP programs. While the law prohibits us from accessing any information about Sars filed, regarding those accounts, especially whether the reporting of information deemed suspicious is inordinately delayed, if such conduct has occurred regarding CBI accounts, resulting in belated notification to regulators and law enforcement agencies, it should be investigated as a National Security matter, due to China's known involvement. We urge the U.S. Senate to note our concerns.

AMERICA'S CRIMINAL INVESTIGATION INTO MONEY LAUNDERING AND CORRUPTION IN SAINT LUCIA HAS ITS FIRST COOPERATING INDIVIDUAL

It appears that the recent celebration, among government officials implicated in the billion dollar fraud, money laundering and corruption investigation of Saint Lucia's Citizenship by Investment (CIP) passport sales program, after Philippe Martinez dismissed his RICO case, will be short-lived. According to our most reliable source on the investigation, assigned to a major American law enforcement agency, one of the principal government officials in that East Caribbean state has agreed to become a Cooperating Individual (CI) and testify against his associates We understand that he will receive Immunity from Prosecution, meaning that he will not be charged with any of the crimes he committed, regarding his role in the CIP program.

We do not have his identity, and even if we did, to disclose it would put his life in serious danger, as contract murders are known to happen in Saint Lucia, which is presently suffering a major crime wave, with a large increase in homicides, few of which seem to be solved by the authorities. He is slated to testify against others presently sitting in positions in government, after which he will reportedly be placed in America's WitSec, or Witness Protection, program, with a new identity, somewhere in the United States.

We can only venture an educated guess as to his identity, and that would not serve justice, so we will let the matter play out and wait for an indictment. Inasmuch as Federal criminal investigations often take a substantial period of time to conclude, there is no time frame for that to occur, but we will be watching; stay tuned.

REMINDER; ALEX SAAB MORAN IS STILL AN OFAC-SANCTIONED SDN

I am seeing multiple queries about ALEX NAIN SAAB MORAN, the indicted Colombian money launderer exchanged for individuals kidnapped by the Maduro government of Venezuela. Yes, he is STILL a sanctioned target; if for some reason, you see his name coming up in any manner in a financial context, remember well the rules regarding the OFFICE OF FOREIGN ASSETS CONTROL (OFAC) and govern yourself accordingly. Note the date on the OFAC search result; The Clemency granted him does not wipe out OFAC.

MONEY LAUNDERERS AND RED COLLAR CRIME

I was leaving the stage after speaking at an anti-money laundering event, about my decade as a career money launderer, and how laundrymen create new techniques, when I was approached by someone that was most likely a DEA agent attending the event. He asked me whether I knew a certain now deceased Miami lawyer known for having had a large clientele, consisting of Latin American businessmen. Coincidentally, we had both worked at an international law firm in the 1970s, when he chose to go out on his own, as often occurs with young ambitious lawyers in a big city.

He had been found floating face down in Biscayne Bay, and most of us assumed it was suicide, due to the stresses of dealing with difficult, affluent clients, compounded by marital troubles. Apparently, the agent said, that was definitely not the case, as he had  been killed by a client, most likely to cover up any possible future damaging testimony against him, as he felt threatened the lawyer might choose to cooperate, concerning his money laundering activities.

We call this Red Collar Crime, when a violent act is committed to cover up a white collar crime. It happens more often than you think to money launderers whose clients feel threatened that the lawyer-laundryman may choose to avoid prison by rolling over on his criminal client, and render what we call Substantial Assistance. When I was once subpoenaed to appear before a Grand Jury in Florida, I had a lunchtime visit where I was asked about what my testimony might be. Readers know I chose to not testify, which led to my evential indictment for RICO, but I am the exception. Most lawyers don't have the stomach for incarceration, and they are the weak link in any criminal organization.

It might surprise you to know that this conversation with a law enforcement agent, advising me that a lawyer had been killed to cover up his money laundering past has occurred a number of times over the years. Lawyers who launder money for narcotics traffickers are often targeted by paranoid, or simply careful, clients to keep them from revealing where all that client's laundered proceeds of crime are located. Most lawyers never consider that when they begin a life of crime; perhaps they should.

The lesson here for compliance officers is this: when your bank client who is a wealthy lawyer passes away, you might want to confirm the circumstances of his death, and while you are at it, check his accounts. Were there any suspicious transactions? Any indicators of activity inconsistent with normal business practices? What about trust account activities? You do not want a visit, two years down the road, from someone with a subpoena for his law firm records, because that may mean you failed to catch his money laundering for clients.

TODAY'S U.S. TREASURY NARCOTICS SANCTIONS

 

For details on all these individuals and entities:

https://home.treasury.gov/news/press-releases/jy2753                                            

SEALED INDICTMENTS FOR CORRUPT CARIBBEAN OFFICIALS? INDICATIONS FROM THE ANDREW FAHIE FILE PROVIDE US WITH CLUES

Andrew Fahie in custody.

Reporting on financial crime, in depth, with analysis, requires not just a legal education, but experience. There are often ongoing activities that prosecutors wish to keep out of the public eye, but deem necessary in the exercise of their function, which is to charge and convict the guilty. There are Red Flags, which indicate that something is going in behind the scenes, that they would prefer remain nonpublic for the time being.

ANDREW FAHIE , the former Premier of the British Virgin Islands, who was convicted of money laundering and narcotics trafficking, with his two co-defendants, are all serving their sentences in Federal Prison, which should be the end of the case, but there's something more one can glean from the docket: Six of the recent docket entries are sealed documents; why, if everyone has been convicted, is this the case?

Second, Oleanvine Pickering-Maynard, Fahie's co-defendant, does not appear anywhere when you seek to learn her whereabouts in the Federal Prison System. Would she be in a country jail somewhere, or some other temporary facility, and for what reason? It is customary to be designated a location where one serves one's sentence after a conviction. Where is she now? She didn't testify against any threats to her safety which would require her placement in a secure, unknown corrections facility.

Third, we recall that she told undercover investigators that Fahie had prior experience in criminal activities in the BVI and the Caribbean ( a"little criminal"), and he himself said the case was not his "first rodeo." We all expected he would render Substantial Assistance to law enforcement before trial, to mitigate his ultimate sentence. He once admitted that he had first-hand information about others in the region who also engage in corrupt activity. has he changed his mind about cooperating, given his long sentence? Perhaps he has decided that he doesn't want to spend a decade behind bars.

Therefore, in my humble opinion, either there are sealed indictments against other corrupt government officials elsewhere in the East Caribbean, or the US Attorney is very close to securing them. Let the story play out, and we shall see if my deduction is correct.

SAINT LUCIA CITIZENSHIP BY INVESTMENT PROGRAM, CEO MCCLAUDE EMMANUEL, AND OBSTRUCTION OF JUSTICE BY THE CIU

Saint Lucia Citizenship by Investment (CIP) Chief Executive Officer MCCLAUDE EMMANUEL recently had a meeting in Washington, D.C., with federal prosecutors and law enforcement agents, where issues involving the sale of illegally-discounted citizenships by CARIBBEAN GALAXY, and administered by Emmanuel's CIU, were discussed. We are advised that he did not take responsibility for the actions of the unit, and blamed others in positions of leadership in Saint Lucia.  Immediately after that meeting, the CIU CEO returned to Saint Lucia, and his agency staff, which operates under his direct orders, took steps that appear to violate the U.S. Obstruction of Justice statute.

Reliable sources advise that these actions commenced immediately after Emmanuel's return:

(1) The CIU went into an operational frenzy, processing pending Galaxy citizenship applications as rapidly as possible. This involved longer working hours by staff, and swift completion of files, including

 clearly risky transactions, which were approved by Risk Manager, PATRICIA PHILIPPE. How much she shares with her father, the prime minister,  such that he must be aware of all the internal dealings of the CIU, is an issue which deserves further inquiry.

(2) Rumors abound that staff at the CIU commenced destroying and deleting all internal correspondence, communications and documents that connected the agency with Galaxy CEO LES KHAN, and several other Galaxy officials. We do know that all the information on the agency's website, was taken down and modified extensively, before being reposted.

(3) Emmanuel communicated to Les Khan the information that he learned at the D.C. meeting, where we believe information in the possession of American law enforcement regarding Khan's central role in the discounted citizenship sales was explained to him. Immediately thereafter, Khan disappeared from the Caribbean, and he has been concealing his whereabouts and location ever since he spoke with Emmanuel. Emmanuel also alerted Minister ERNEST HILAIRE and Galaxy' executive YING JIN about his meeting.

The Obstruction of Justice statute, 18 USC §1501 et seq, makes it a felony to destroy or alter evidence and to tamper or affect witness testimony. We interpret the CIU's wanton and thorough deletion of documents and files, and Emmanuel's tipping off of Khan, so he will not be available, as clear violations of Federal criminal law. The maximum punishment for this offense in five years in Federal Prison, with the possibility of a longer sentence if the offender is found to have obstructed justice by impeding the investigation or prosecution of his or her crimes.

Whether the aforesaid actions of the CIU constitute violations of Saint Lucia laws or regulations, civil or criminal, is outside the scope of this article, and should be directed to legal professionals there who are competent to render an opinion under those laws.

As information into ongoing criminal investigations conducted by Federal law enforcement agencies cannot be obtained, we are unable to advise the status of any and all investigations into the Saint Lucia CIP program, the CIU agency, or McClaude Emmanuel, but we shall closely monitor the situation, and update our readers on all developments regarding any public statements or press releases that may be issued in the future regarding criminal charges.

SOME OF THE SUSPECTS IN THE CARIBBEAN CBI SCANDAL ARE U.S.CITIZENS OR PERMANENT RESIDENTS; HOW WILL THAT WORK OUT FOR THEM?

SLC CIU Risk Officer Patricia Pierre, US citizen

One of the ways that corrupt Caribbean leaders game the system is to make very sure that they will, ultimately, be able to eventually reside in the Continental United States with their ill-gotten gains. Once their bribes & kickbacks have been artfully laundered into investments and bank accounts in America, they generally wish to fade into affluent oblivion somewhere in the U.S., far from the constituents that they purportedly served, while lining their pockets with filthy lucre. They can, of course, thank their money launderer for cleaning, and thereafter, investing in income-producing assets anonymously, somewhere in the world's biggest economy.

Former B of A VP, SKN CIU head Les Khan; US citizen

Their foresight, in positioning themselves through acquiring American citizenship or residential privileges, for their themselves or a close family member, so they can better facilitate their status later, may have now just come back to bite them, as individuals in Saint Kitts & Nevis, and in Saint Lucia, have unwittingly facilitated any eventual criminal indictment by doing so. Their own US citizenship, or legal residency, could actually facilitate charging decisions about venue. Every time these targets enter the U.S.A., spend their proceeds of crime while enjoying their illicit wealth, they potentially give Federal prosecutors an additional District to charge them, as well as a supplemental criminal act or two.

Confident to politicians and to China; Hartley Henry; lawful Permanent Resident

Whether US citizenship or Lawful Permanent Residency result in their earlier indictment, which might be in a District they won't be especially enthusiastic about being detained, or tried in, depends upon the individual, but they may quickly regret their pre-planning citizenship to grease in their eventual Miami residency, after being booted out of office.