ILLEGALLY DISCOUNTED CBI PASSPORT PAYMENTS WERE FUNNELLED DIRECTLY TO HSBC'S HANG SENG BANK, TO AN ACCOUNT CONTROLLED BY CARIBBEAN GALAXY'S OWNER, ZHANG KUAN

 

An estimated USD$2.5bn, representing application fees for Citizenship by Investment (CBI/CIP) Passports issued by Saint Kitts and Saint Lucia, which were illegally discounted by the CBI consultancy CARIBBEAN GALAXY REAL ESTATE LIMITED, were paid into Galaxy accounts at HANG SENG BANK, which is part of the HSBC Banking Group. The documents show that the individual who controls those accounts is ZHANG KUAN, the owner of Galaxy. Reportedly, none of those funds can be accounted for in the accounts of Saint Kitts and Saint Lucia.

 Galaxy is a major defendant in the $150m civil RICO lawsuit filed in Federal Court in the United States by MSR MEDIA against a number of individuals who are present or former government officials , which alleges that the company discounted the minimum legal purchase price of CBI citizenship and passports, that it was given thousands of files which are employed to file passport applications, and which were used to fraudulently issue passports sold for a fraction of the authorized price, which damaged other stakeholders in the CBI program, as applicants would be much more likely to choose to purchase an economic citizenship at a seriously reduced rate.

The role of Hang Seng Bank, HSBC Bank and Zhang Kuan, will now become a major focus in the American RICO case. In addition, Their potential exposure to claims of other CIP stakeholders, and to liability for possible violations of Federal criminal laws, are all issues which we shall analyze in future articles.

  

ISRAEL ATTACKS THE HEZBOLLAH LEADER WHO ORDERED THE ATTACK ON A CHILDRENS' FOOTBALL GAME IN ISRAEL

 

Believed to have been killed by Israel, FUAD SHUKR was wanted by the United States for his role in the 1983 attack on the US Marine Corps barracks in Beirut.

SAINT KITTS REFUSES TO ACCEPT ONE OF ITS CBI PASSPORT HOLDERS BEING DEPORTED AFTER A MONEY LAUNDERING CONVICTION IN SINGAPORE

(identity obscured by Singapore Government)

It appears that the Government of Saint Kitts & Nevis is trying to pretend that those individuals who bought economic citizenship at an illegal discount, through the Chinese-owned company, CARIBBEAN GALAXY REAL ESTATE LIMITED, have no right of return and residence in their adopted country. ZHANG RUIJIN, sentenced to fifteen months' imprisonment and $118m forfeiture for money laundering and forgery of instruments, was deported to Cambodia after serving his sentence, rather than St. Kitts, which it is obligated to accept him under international law. It seems that the St. Kitts government wants to pretend that the thousands of SKN CBI passport holders who acquired citizenship illegally do not exist. Is that because millions of dollars in bribes and kickbacks were paid to government officials to approve those applications?

The country's Prime Minister, TERRANCE DREW, who has himself been accused of approving dozens of illegally discounted CBI citizenship applications during his administration, and has who stated publicly that all such "new" Kittitian citizens are entitled to Due Process when it comes to passport revocation, has not taken any public action on any of the illegal passports, which means that his government is legally obligated to accept Ruijin, notwithstanding his felony convictions.

Obviously, the Government of Singapore privately sought to return him to Saint Kitts, but was rebuffed. What are the law enforcement agencies of the world to do with all the Chinese nationals who purchased discounted economic citizenships, and are subsequently arrested, convicted and imprisoned on felony charges? We have already seen a number of such cases in the United States and United Kingdom, and there will most certainly be more in other jurisdictions; they all are to be deported after serving their sentences. It would appear that St. Kitts is hiding its head in the sand when it comes to the consequences of permitting Caribbean Galaxy to break the very laws that authorize and regulate CBI in that country. Does anyone in Saint Kitts Government follow and obey their own laws?

CHINA'S PLANS FOR ITS ENCLAVE IN ANTIGUA COULD RESULT IN MASSIVE FINANCIAL PROBLEMS FOR THE UNITED STATES

Cultural Literacy, which I consider mandatory for any effective compliance officer, must include a good Liberal Arts education. That education should feature among other things, a well-rounded study of World History, including Asian History, which is sadly missing these days among those who will become our future compliance directors.

Our problems with China run deep; they go back to the Opium Wars and the large European Spheres of Influence imposed upon China by the Colonial Powers, who wished to exploit the country for windfall profits. Hong Kong & Macau were merely the tip of the financial iceberg Europe extracted from Asia, and China has never forgotten it. One must look past official PRC attitudes towards the West, to see an emerging autocratic superpower that is now extending its own sphere of influence on a global basis, whether it is Belt & Road, or Citizenship by Investment, China is on the move, and the West had better pay attention. Antigua has become a Treaty Port of China, reversing history and playing a bitter trick on the West.

Whereas most observers watching China build its Special Economic Zone, in the center of Antigua's supposedly protected wildlife preserve see economic development, I also see plans for an offshore bank, internal passport issuance capability, an international airline, an improved deepwater port, local law enforcement and immigration, and even a local version of the Chinese Coast Guard to keep out potential problems.

When completed, it will be a totally self-contained state, with the resources and facilities to project its financial and yes, even political, influence throughout the region. Will legacy AML/CFT safeguards protect North America from China's long-term plans and designs for the Western Hemisphere? Will compliance officers be completely outmatched when attempting to staunch the flow of Chinese funds of unknown provenance?

While some Americans fear that they may soon see warships from the Chinese Peoples' Liberation Army Navy off the Florida Keys, I worry about highly organized money laundering, resulting in Chinese ownership and control of our financial structure, which could be so massive as to overcome any efforts to rein it in.

it all starts by allowing China to build its own version of Hong Kong in what has been, for decades, an American lake. Where's the Monroe Doctrine when we need it?

THE UNINTENDED CONSEQUENCES OF HAVING YOUR CBI PASSPORT CANCELLED CAN BE SEVERE

Longtime readers of my articles know that I spent many years working for two companies that maintain databases of high-risk individuals and entities that are used by compliance officers at financial institutions, and for that reason I am familiar with the process through which court records, sanctions lists, and other information will cause someone to appear on those lists, which is often a major reason that a banker will decline to open an account, or why others conducting due diligence for a client will veto a proposed transaction or business relationship. Those databases are quite highly regarded in the compliance world, and they serve a necessary purpose for risk managers.

You should already be familiar with the litigation over the unfolding scandal in the five East Caribbean CBI states, where a Chinese passport vendor is alleged to have sold thousands of St. Kitts and St. Lucia citizenships with accompanying EU-friendly passports at major discounts. See MSR MEDIA vs. LES KHAN, Case No.: 24-cv-01248-KKM-AAS (M.D. FL.). Those sales violated the CBI laws of the jurisdictions which issued them, and many were issued based upon bogus and counterfeit identification.

Many EC jurisdictions have now gone on record to declare that they will cancel all such fraudulent passports; Dominica has already announced that a number of them have been revoked, and we must assume that the reason was that they were purchased at an unlawful and unauthorized discount.

The point has been raised, with concern, that the public notices of passport cancellation will all be picked up by the commercial database industry, and duly entered therein. Most compliance officers will judge these entries to constitute negative information, and we foresee them denying or closing bank accounts, based upon the fact that the passports were obtained in violation of the laws regarding their issuance. Also, due diligence inquiries may also turn up the cancellation, and result in a report to a client to avoid the individual. Whether it also affects employment prospects, credit rating, or credibility in some other forum we cannot say, but one must assume it to be of some consequence.

These Unintended Consequences of saving money by purchasing at a discount, should be considered by anyone considering applying for a CBI citizenship & passport anywhere. As a matter of fact, this is but one more reason to retain the services of a competent, experienced attorney to represent you, before entering into ANY contract for economic citizenship. Do not rely upon the so-called "legal experts" at the CBI consultancy, for they are not admitted to practice law in the countries where you are considering citizenship. Get your own lawyer, please, or risk problems which you may not have been made aware of when you acquired that prized passport. Caveat emptor, please.

READ THE NEW FINCEN NOTICE ON BENEFICIAL OWNERSHIP REPORTING REQUIREMENTS AND DEADLINES

 

CHINA'S EXPLOITATION OF THE CARIBBEAN'S DYSFUNCTIONAL ECONOMY AND RAMPANT CORRUPTION TO EMBED ITSELF IN EAST CARIBBEAN CBI PROGRAMS HAS INCREASED FINANCIAL CRIME AND THREATENS NATIONAL SECURITY

If you want to blame anyone for the financial problems facing the East Caribbean states, economists and historians tell us it sits squarely on the shoulders of the United Kingdom, which granted independence to its colonial Caribbean territories which, outside of some tourism, had economies that were not prepared to support national governments, with all the agencies and other trappings of a nation-state, including providing government services to all the citizens.

As the direct and proximate result, many of these small democracies evolved into what can only be described as one-party states, with powerful, and legally bulletproof, leaders whose arrogance rivals those of some of the world's most powerful autocrats. After all, they believe that they are the leaders of sovereign nations, and if financial opportunities come their way, they should have the right to take advantage of them. Hence rampant and systemic corruption, which has infected the region since the early days of independence, which is Strike One.

Finally, forty years ago a government leader in the region, himself engaged in financial crime on a grand scale, created a scheme to relieve some of the financial distress being suffered by the East Caribbean, whose nations were in debt, and without any significant American assistance. The Citizenship by Investment (CBI/CIP) programs, providing funding in exchange for a passport from a jurisdiction whose citizens could freely enter most of the developed world, were seen as the solution to EC financial needs. Unfortunately, the region's corruption immersed itself in CBI; Strike Two.

Enter the expanding, autocratic Peoples' Republic of China,which finds the still cash-poor East Caribbean an easy target for its billions, and sees that becoming embedded in the CBI programs will allow it to gain both influence bordering on domination, as well as funding, provided by the world's wealthy, who want the privileges and immunities that come from a new nationality from a low risk jurisdiction whose citizens have carte blanche entry rights into Europe and elsewhere. Strike Three and Out.

So now, in 2024,we have a resurgent China essentially calling the shots in many capitals of the East Caribbean states, by virtue of its local financial strength, by being deeply integrated into each of the five CBI programs, due to the quantity of Chinese clients, and by illegally diverting literally billions in revenue to itself, through Chinese-controlled companies. Transnational criminals increasingly use the passports for their illicit purposes; China rakes in cash, and a National Security threat looms for not just the region, but the United States as well which has now, belatedly, noticed.

Things in the East Caribbean are about to get ugly; stay tuned.

GREEDY CBI VENDORS BRAG ABOUT THE EXTENSION ANTIGUA GAVE THEM ON UNDERPRICED PASSPORT SALES THEY HAWK ON LINKEDIN

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... And, even though they are NOT supposed to tout visa-free entry into the Member countries of the European Union, look at this bloody advert on today's Linkedin! Have they no shame? Antigua said they needed the extra 30 days, to obtain "Parliamentary Approval," notwithstanding that they have had since mid-March to do so. Remember the Memorandum Antigua signed back then? Its Parliament was too busy with important pressing affairs to address the issue for 90 days?

Before they became CBI vendors, most of these people were busy trying to sell refrigerators to the eskimos. Note the location of the vendor: UAE.

ISA CYRIL, BOARD SECRETARY AND LEGAL COUNSEL TO ST.LUCIA'S CIP UNIT, RESIGNS HER POSITIONS

ISA CYRIL, who now serves as Lead Counsel for the country's beleaguered CIP Unit, and is also Secretary of its Board of Directors, resigned her position today, after both local and foreign media approached her for comment on recent events regarding the CIP vendor CARIBBEAN GALAXY REAL ESTATE LIMITED scandal. She sits on Board meetings together with McClaude Emmanuel and Christopher Paul. We applaud her action; it is expected that there will be other resignations in short order, as the CIP unit has stonewalled all requests made by the people for full disclosure in the Galaxy scandal.

The Board, led by Lorne Theophilus and McClaude Emmanuel, was responsible for approving the real estate contract with Caribbean Galaxy, while Deputy Prime Minister Hilaire signed the Infrastructure Fund contract. Galaxy collected over Two Billion Dollars (USD$2bn); None of the funds have been accounted for by the CIP program. Those fraudulent payments, which transited correspondent accounts in American banks, could be considered predicate acts for criminal money laundering charges in the U.S. Whether any of the American banks what accepted billions in what might ultimately be considered the Proceeds of Crime  remains an open question. 

We await further information on the expected resignation of a number of other Board members, whose contingent liability has become an issue, given the recent disclosures of information indicating possible Board misconduct.

IN THE AFTERMATH OF A SUCCESSFUL TWO BILLION DOLLAR MONEY LAUNDERING OPERATION, SINGAPORE'S ANTI-MONEY LAUNDERING UNIT REMINDS THE COUNTRY'S FINANCIAL INSTITUTIONS ABOUT SOURCE OF WEALTH BASICS

After enduring what has now become a global scandal, Singapore finds itself in repair mode, as its competitors in the offshore arena are most certainly taking advantage of its abject failure to detect, and interdict, the massive Chinese money laundering operation whilst it was in progress. How much international financial business it loses we cannot say, but we do note an important new step the government has taken to mitigate future money laundering schemes.

We have previously reported on increased attention being paid to the improper acceptance of passports from low-risk jurisdictions, after Singapore's compliance officers freely accepted fraudulent St. Kitts CBI passports as identity from Chinese nationals, who reportedly did not speak any English whatsoever, in a clear case of compliance malpractice. Readers who are not familiar with the dangers that such passports present are urged to read our prior articles regarding the subject. as well as the American litigation in progress.

The country's Money Laundering Department, part of the Monetary Authority of Singapore, has released to its banks a detailed Circular explaining the basics of Source of Wealth. Frankly, there should not be any need to explain to the financial institutions the nuts & bolts of SOW due diligence, but it is welcomed nevertheless. Let us hope that there will be no further invasion of the country's financial structure by money launderers for Chinese illegal gaming entities, proffering passports known to be suspect, due to the circumstances surrounding their illegal acquisition, and containing aliases. Any compliance officer who now unquestionably accepts St. Kitts passports should be terminated for malpractice.

Our thanks to Linkedin member Ajay Shamdasani for bringing the matter to our attention.

POST-HURRICANDE BERYL, LOOK FOR ANOTHER PERFECT STORM TO ARRIVE; EXPECT MONEY LAUNDERING THROUGH CITIZENSHIP BY INVESTMENT EXPLOITING THIS NEW TARGET OF OPPORTUNITY

Money launderers are constantly scanning global news, seeking to exploit unfolding events; they regard the world as a financial battlefield, in which they can choose to enter and attack specific vulnerabilities that appear, and Acts of God (natural disasters) often present them with time-sensitive opportunities. I have previously written about how laundrymen set up bogus charities and NGOs, to serve as cover for transnational movement of the Proceeds of Crime, under cover of armed conflict, natural disaster, public health nightmare, and any number of emergencies where effective compliance takes a backseat to saving lives and property.

Hurricane Beryl, which destroyed a substantial number of structures in Grenada and the Grenadines, offers an emerging Target of Opportunity, to borrow a military term. Grenada's CBI program,already tainted with both intentionally uncompleted construction projects that allowed Stakeholders (and the Government) to take lucrative fees, so long as the applicants received the passports which could qualify them later to enter the united States, will be flooded with new money, upon which, trust me, due diligence efforts will be cosmetic only, and not effective. Public pressure within Grenada for construction projects will fuel the easy entry of dodgy capital. Expect sanctioned Russian funding to find a circuitous way to gain entry; Russian CBI investors have been attracted to Grenada for many years, and don't expect that they will let such a small thing as international sanctions to stand in their way. The E-2 treaty Investor Visa for the United States for Grenada citizens says it all.

The East Caribbean CBI citizenship & passport industry, now under attack for corruption, fraud and money laundering in two other EC states, continues, in its many different Caribbean iterations, to provide fertile ground for professional money launderers seeking to place their clients' money where it disappears into the local economy, and is not under threat of seizure and forfeiture, as it is in a convenient (and corrupt) jurisdiction.

COMPLIANCE OFFICERS, REMEMBER THAT THE THREATS FROM CHINESE CAREER CRIMINALS WIELDING CARIBBEAN CBI PASSPORTS ALSO COME FROM ST. LUCIA

While the media focuses upon the scandal surrounding the issuance of thousands of St. Kitts CBI passports, through Caribbean Galaxy, the Chinese company alleged to have knowingly accepted bogus identification from Chinese nationals, some of whom have already been arrested in the US, UK, Singapore and elsewhere, a good compliance officer instinctively knows that money launderers generally carry multiple forms of valid identification while engaged in international travel, to disrupt any possible subsequent criminal investigation, and to eliminate the establishment of a pattern which a sharp compliance officer might tumble to, during a due diligence query. When I was engaged in money laundering I, like the individuals that are cleaning cash today, was careful to employ this trick routinely, to cover my tracks. It is standard operating procedure.

You can expect these same Chinese career criminals whose activities have been facilitated by their possession of those St. Kitts passports, to not only have more than one, under different aliases, but they will also have CBI passports from that other East Caribbean jurisdiction whose CIP unit has also literally been in bed with Caribbean Galaxy, the East Caribbean state of St. Lucia. If you read Caribbean news, you know that the country's Deputy Prime Minister is so afraid of his Chinese masters, that he has ignored his constituents' pleas to disclose the actual number of passports issued through Caribbean Galaxy.

Therefore, you can expect that, now that the negative global publicity about SKN CBI passports has alerted compliance officers to the criminal abuse of St. Kitts passports, all those Chinese laundrymen, sanctions violators, narcotics traffickers, intelligence agents, and other of the Usual Suspects, are trotting out their St. Lucia CBI passports during their operations; Watch for them. It's not just about St. Kitts anymore. Try to think like a money launderer if you want to catch them in the act.

THE MONEY LAUNDERERS' NEW BEST FRIEND: SWISS CBI CONSULTANCY WILL TAKE YOUR CYBER CURRENCY AND GET YOU A NEW PASSPORT

A Swiss company that sells economic citizenships is now advertising online that it will accept your Bitcoin, and then secure one of those prized Citizenship by investment (CBI/CIP) passports so necessary in these visa-obsessed times. Since all five of the East Caribbean states that offer CBI require US Dollars (USD$) for payment of those six-figure treasures, this means that the Swiss company intends to convert your soon-to-be untraceable cyber currency into Dollars. What's wrong with this picture? Are any other CBI consultancies doing this covertly?

I see nothing on the company's website about how much Due Diligence, Know your Client, Source of Funds & Source of Wealth will be done internally. I am certain that the world's active duty money launderers are just rubbing their hands together with delight, because this Swiss company will be fronting nicely for their criminal clients' dirty money.

Where are Swiss law enforcement agencies in all this? We are wondering just how many months they will take to investigate, analyze, and then shut down this obvious Laundrymans' friend, lest the Swiss reputation for facilitating money laundering be further tarnished by this very obvious effort to defeat anti-money laundering efforts of the world's financial institutions.

It is curious that, precisely at a time when American financial institutions that bank CBI deposits for those same five East Caribbean CBI-selling countries have come under the microscope for allowing dodgy money to pass through their portals, and a U.S. District Court in Florida has approved the service of subpoenas against three of the largest ones. See IN RE APPLICATION FOR AUTHORIZATION TO CONDUCT DISCOVERY FOR USE IN FOREIGN PROCEEDINGS, PURSUANT TO 28 U.S.C. §1782, Case No.: 24-CV-20492-RKA ( S.D. FL). Every compliance officer at American financial institutions that offer correspondent accounts needs to read that Order today and share it with bank cousel.