THE MACAU MYSTERY: WHAT ILLEGAL SAINT KITTS AND SAINT LUCIA CIP ACTIVITY WAS CARIBBEAN GALAXY ENGAGED IN THERE?

The term Deceptively Similar describes certain tradecraft that money launderers employ to deceive the financial sector as to the pedigree of their criminal clients' companies, so that they are erroneously mistaken to be linked to, or owned by, prominent, legitimate and accepted companies in the global marketplace, therefore above reproach, and most likely even trusted. There are a number of proven techniques, some of which I have featured in articles, from time to time, especially when one is successful in misleading, confusing and defeating compliance officers.

Back in the day, I indulged in this drafting technique, which generally results in the company controlled by a criminal client being accepted for the purposes therein intended. One time, at a meeting with lawyers in Washington, my clients' shell company was erroneously linked to Continental Grain, though nothing could have been further from the truth. You don't always succeed with these ploys; once, a Caribbean corporate registrar caught on that my choice of a limited liability company would have caused others to believe it was linked to the British Royal Family, and disapproved it. Readers for whom details of this technique might be important for AML/CFT purposes, kindly contact me directly.

LESLIE KHAN a/k/a LES KHAN

So, when, in connection with the new disclosures that appeared yesterday, in connection with a court filing in Saint Kitts & Nevis, in the MSR Media defamation case, regarding a Macau company named SKIPA INVESTMENT MACAU LIMITED, and that such a company paid LES KHAN, USD$1,359,200, after he left the St. Kitts CIU. Since Skipa is listed as owned by Caribbean Galaxy Real Estate limited, and administered by Galaxy CEO YING LIN, I paid attention. The reason is that Skipa is a well-known acronym used by the ST. KITTS INVESTMENT PROMOTION AUTHORITY, an SKN government agency that offers "investment opportunities." The Macau Skipa will, of course, be confused with the real government entity; not an accident, to be sure. Deceptively similar, of course. And what about Skipa's activities in Saint Lucia, where it also maintains an address? What role did it play there?

This raises a number of issues which require further investigation: (1) Was the Macau Skipa used to pay bribes and kickbacks, disguised as legitimate payments?, (2) What is the real purpose of the bogus Skipa?, (3) Was the Macau Skipa an artifice for money laundering? and, (4) Was it used to sell St. Kitts & St. Lucia Citizenships in Macau, posing as a real government agency?, and (5) Inasmuch as Skipa also has an address in Saint Lucia, what activities was it engaging in on behalf of the St. Lucia CIU in Macau? We hope that all these questions will be answered in time, during the course of the litigation, and the mystery solved.

BANK OF AMERICA RECORDS INDICATE THAT LES KHAN RECEIVED OVER THIRTEEN MILLION DOLLARS, INCLUDING TEN MILLION AS COMPENSATION, PLUS DIRECT PAYMENTS FROM GALAXY AND DUE DILIGENCE FIRM

In an extraordinary turn of events, Damian Kelsick, as attorney for MSR Media, defendant in the Saint Kitts Defamation case, filed damning information, taken from accounts showing that former Saint Kitts CIP CEO LES KHAN received a total of USD$13,403.989.16 in his Bank of America account, The funds included over $10m, amazingly paid as compensation for his position as CEO of the Saint Kitts Citizenship by Investment (CBI/CIP)program, plus $770,000 curiously paid to him, after his departure from the SKN position, by HONG KONG BAI SHENG AN LIMITED, which was owned by a Galaxy Vice President, LI MUSHENG, and $320,000 paid to Khan by Caribbean Galaxy, while he was head of the CIU Unit in St. Kitts. These figures comes from documentary evidence, a portion of which was released today, after filing in court in the court of Saint Kitts and Nevis, in a press release made by MSR Media.

These disclosures, which will most certainly rock the global CBI industry to its foundations, demonstrate that obscene amounts of what are alleged to be bribes, kickbacks, and sweetheart compensation schemes, all of which enriched Mr. Khan to an extent that will shock the people of Saint Kitts & Nevis, the sole legal beneficiaries of the CBI program. While there is much more to report, we are rushing this story into publication, so that the public learns immediately of the extent to which corruption in the SKN CBI program existed, and which is painfully evident from the Bank of America records.

While there are many questions raised by these figures, the one which immediately comes to mind is how Bank of America, which was the correspondent bank for the St.Kitts CBI program, failed to monitor such unusual transactions, failed to make timely inquiries about the circumstances of large transfers from third parties, and failed to take any action whatsoever to insure that no illegal activities were being facilitated by the bank. This and many more major questions need to be answered forthwith, in a forum other than the Saint Kitts defamation case.

ARE THERE MORE UNQUALIFIED PEOPLE AT SAINT LUCIA'S BELEAGUERED CITIZENSHIP BY INVESTMENT UNIT?

If you read our recent article, Was it Nepotism or Corruption, at Saint Lucia's CIP unit, that was Responsible for the Issuance of  Thousands of Fraudulent Passports?*(August 23, 2024), you know that we have identified the CIP Unit's Risk Profiler as an individual who does not appear to have the education, training or experience for that critical position. That article, which has not resulted in the public production of any evidence to the contrary, but drawn Government efforts to censor news about the Unit and its staff, reminds us that there is no publicly-available information about the qualifications of the other approximately ten staff members who process, and ultimately approve, CBI economic citizenship and passport applications.

Given that the RICO case alleges that literally thousands of applications, featuring deeply-discounted illegal sales prices, have been processed and approved by the Unit, does not then the Saint Lucian public, as well as the correspondent banks in the United States that accept CIP deposits, deserve to know whether those other staff members have the necessary professional and vocational qualifications to work in a CIU? Given that there are reports indicating that the Unit has not disapproved any of the applications sent in by CARIBBEAN GALAXY  REAL ESTATE LIMITED, is it not time to examine the CIU personnel, to determine if minimal professional industry standards are being observed and followed?

At the very least, the situation demands that the names, qualifications, including relevant work experience, of each and every CIU staff member, as well as supervisory personnel be made public.a s well as the term of their contracts, and salary and benefits. These are publicly-funded government positions and the people of Saint Lucia deserve to know what they are getting for their money. Transparency at the CIU must now be the order of the day, given the serious allegations of fraud, money laundering and corruption in the pending RICO case.

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https://rijock.blogspot.com/2024/08/was-it-nepotism-or-corruption-at-saint.html

THE PRIME MINISTER OF SAINT KITTS DANCES AROUND THE TRUTH ABOUT HIS COUNTRY'S BILLION DOLLAR CITIZENSHIP BY INVESTMENT SCANDAL

The Prime Minister of Saint Kitts and Nevis, TERRANCE DREW, when asked direct questions this week, during an interview conducted by local media, dissembled and deceived on details of the CBI/CIP Prison Project, in which close to a billion US Dollars from illegally-discounted economic citizenship sales funds was diverted to China. He failed to admit that no escrow account was required by the Timothy Harris administration for the jail project and that Caribbean Galaxy Real Estate Limited received the money in Asia without any government control. Drew falsely claimed, in response to a direct question from the interviewer, that an escrow account existed for the project. He said that no major construction on the jail is under way presently, because the government is looking at the nature of how the contract was given to Galaxy.

He stated that a Government inquiry was in process, but was vague about any details. He did admit that some funds had been received to date, but that more funds still needed to be received. He did not detail how Saint Kitts expected to recover the balance of those funds, seemingly passing the responsibility for the matter of collection to the country's Attorney General, Garth Wilkin. While he admitted that that the prison project cost was projected to be $40-60m, Drew evaded giving a direct answer, when pressed to explain why the Harris administration gave Galaxy 5,500 shares at $175 k, resulting in almost $1bn worth of passport money. He repeatedly claimed that the Government was "distilling" the information, an ambiguous phrase which he failed to further explain or define.

MSR Media, one of the stakeholders in the St. Kitts CIP Project, is suing a number of individuals and entities for $150m, alleging fraud, money laundering and corruption, in civil RICO litigation in Federal Court in the United States regarding the prison project.The case has roiled the economic passport industry throughout the region, as allegations of rampant illegally-discounted passport sales in other East Caribbean states that offer similar programs have surfaced.

WHEN YOUR "LAWYER" IS NOT YOUR LAWYER

Amid all tumult and the shouting surrounding the noise over the validity of the CBI/CIP passports illegally issued at a deeply discounted rate, and the moves by East Caribbean states to cancel and void those identity documents, it is important to remember that anyone who chooses to invest six figures of his money in an economic citizenship ought to engage the services of a competent attorney, before entering into any contract to purchase an economic citizenship.

We have found that very few clients actually hire a lawyer for what is a very important transaction. The reason, as best we can determine, is that many of the passport consultancies assure prospects that some of their people are extremely knowledgeable "legal specialists" and therefore, by implication they are fully protected. We note that, even where these individual are lawyers, they are (1) not admitted to the practice of law in the jurisdictions where they want to sell you the passport, and therefore are not competent to advise you of both the advantages and disadvantages under local law, (2) Are not fully familiar with the extent of corruption and fraud that may taint that specific program, and (3) Have no genuine professional license and regulatory agency which you can go to later with complaints or claims.

Please, and I direct this to anyone who contemplates purchasing an economic citizenship, retain, in advance, the services of a competent attorney who is familiar with the jurisdiction, the program, the individuals and entities involved, and the risks you may be shouldering by the purchase itself. Not only your entire investment may be at risk, that passport may serve to paint a bull's-eye on your back, for reasons that were never explained to you by the people who sold you that citizenship.

HAVE YOU ANTICIPATED THAT LEBANON WILL BE PLACED UPON THE FATF GREY LIST, WITHIN YOUR RISK-BASED COMPLIANCE PROGRAM?

All the preliminary signs are that the Financial Action Task Force, the FATF, will designate the Republic of Lebanon a Jurisdiction under Increased Monitoring, its dreaded "Grey List."This action, which will be based upon the sad fact that a designated global terrorist organization, HEZBOLLAH, which basically runs the country from a political, as well as military perspective, operates a parallel economy that is outside the regulated Lebanese financial structure. the Terrorist group operates an entity that is, in essence, an unlicensed bank with zero AML/CFT capability, AL-QARD AL-HASAN, a US-sanctioned entity.

Although a number of other Arab countries are objecting to Lebanon being grey-listed, the circumstances support such a move by the FATF; the question is merely when, and not if, such a designation will be entered. Your risk-based compliance program should take note of this likely impending event, and make the appropriate modifications regarding an increase in internal due diligence procedures ahead of the FATF action. Whether that means that enhanced due diligence will be required on international trade transactions, funds remittances, loan repayment, and wire transfers should be based up your updated risk assessment, and whether you can conclusively rule out any possible terrorist financing factor during transaction monitoring, given customer history.

WILL PROPOSED FINCEN PERPETUAL RISK ASSESSMENT REQUIREMENT BE THE DEATH KNELL FOR CORRESPONDENT BANKING AS WE KNOW IT?

Much has been written of late regarding the future FinCEN requirement mandating creation of a continuing risk assessment capability at your bank, which would be charged with effectively, and perpetually, evaluating risk as events unfold. Nowhere is such a duty as critical as currently exists, regarding correspondent accounts maintained by US banks for indigenous Caribbean financial institutions and NBFIs. Risk levels for those specific types of accounts have been known to approach dangerous levels, due to rampant suspected money laundering, deposits of suspected corrupt Politically Exposed Persons (PEPs),funds believed to represent the Proceeds of Crime, possible terrorist financing, CBI deposits, and a host of other categories of payments that have a habit of originating in the Caribbean, where effective in-house AML/CFT compliance often does not meet Banking Best Practices minimum standards.

It is feared that this new, elevated requirement will result in abrupt and permanent De-Risking, meaning closure of correspondent accounts with Caribbean banks deemed ineffective as gatekeepers, and which thereby expose American banks to civil fines & penalties, or worse, for suffering the AML violations observed by the new Risk Assessment team. Whereas before, the threat did not directly require immediate action, how can a US bank that sees the problem not now be forced to act?

I am wondering how the eventual mandatory implementation of the independent Risk Assessment team can result in anything other than a crackdown on the region's dodgy banks, where political considerations, the profit motive, and a smug feeling that the current American regulatory policy which discourages De-Risking even when it is richly deserved, may now find out, the hard way, that their sub-standard compliance department has cost them their valuable correspondent accounts in New York and Miami. I frankly see no other probable outcome. What will 2025, and the effective date of those new FinCEN rules bring? If I am a senior executive at a Caribbean bank, I am surely afraid of the answer.

WAS IT NEPOTISM OR CORRUPTION, AT SAINT LUCIA CIP, THAT WAS RESPONSIBLE FOR THE ISSUANCE OF THOUSANDS OF FRAUDULENT PASSPORTS?

Philicia Pierre

During our recent investigation of the Saint Lucia Citizenship by Investment (CBI/CIP) program, we have learned that corruption might not be the only reason that thousands of passports were issued to Chinese nationals who used fraudulent and bogus identification cards, with the knowledge and consent of the vendor, CARIBBEAN GALAXY REAL ESTATE LIMITED. The ugly taint of nepotism may have further stained the application process. It seems that the PHILICIA PIERRE. who is the daughter of the country's Prime Minister, PHILIP PIERRE, just happens to be employed there as a Risk Profiler at the CIP.

A Risk Profiler at any government agency that investigates, and approves, Economic Citizenship applications must be a highly experienced individual, because of the heavy responsibility which that individual must carry. He or she is usually a former compliance officer at a local financial institution, with decades of frontline experience in risk assessment, in addition to being competent to perform enhanced due diligence on applicants, having learned that skill set through both education, training and experience on the job.

We have received information that all the duties and responsibilities of Risk Profilers at the CIP are being discharged by other staff members at the CIP, and also that she is reportedly receiving a salary from Caribbean Galaxy at the same time she has been on the payroll at the CIP. We asked Ms. Pierre twice to comment on these statements, but she has never responded to our inquiries. 

We are unable to find any record of such academic or vocational training or experience in Risk Management for Miss Pierre, either in Saint Lucia or abroad. Given the fact that several Chinese nationals, possessing Caribbean CBI passports issued by the CIP, with aliases, through applications submitted by Caribbean Galaxy, have been found to have engaged in a wide variety of financial crimes, especially money laundering, around the world, and been arrested for those crimes, carrying those same passports, we wonder whether her inexperience was a factor. Alternatively, was she instructed by her father, the PM, to pass and approve all such applications for citizenship, notwithstanding that they were based upon completely bogus identification, which were obviously fraudulent?  Did she "rubber stamp" those Galaxy applications on the orders of her father, the Prime Minister?

We call for an independent audit and investigation of the Saint Lucia CIP, and for each and every application processed for Caribbean Galaxy to be examined, and if found to be fraudulent, revoked and cancelled forthwith, as void ab initio, from the date of their issuance.

SAINT LUCIA PRIME MINISTER ATTEMPTED TO PAY OFF CBI RICO PLAINTIFFS WITH TAXPAYER FUNDS, AND COVER UP SCANDAL THROUGH INSISTING ON RETRACTION FROM VICTIMS

PHILIP PIERRE, the Prime Minister of St. Lucia, after first declaring that he was not in any way involved in the massive billion dollar fraud, money laundering and corruption scandal, then tried behind the scenes to settle the litigation for his corrupt ministers and CIP Board, by offering taxpayer funds, coupled with a demand that the damaging allegations of the RICP case be publicly retracted, which would result in a cover up of the painful truth about the country's Citizenship by Investment program.

The whole sordid episode started when attorneys for RICO case defendant MCCLAUDE EMMANUEL, CIP CEO, requested a figure from plaintiffs, seeking to achieve a quiet, out-of-court, settlement of the claims against Emmanuel. When the plaintiffs' counsel responded, All of a sudden it was disclosed that he also represented Pierre, who is not a party to the proceedings, nor is the Government of St. Lucia. Whether this dual representation of the two clients constitutes a Conflict of Interest is an issue to be discussed in another forum.

At that point, Pierre, acting now on behalf of the Government of St. Lucia, replied, through counsel, that his government could not pay a significant amount, and that the figure would have to be negotiated, implying that the funds would come from a government account, meaning that it was to be taxpayer money. He also arrogantly demanded that, as a condition of the settlement, plaintiff would be forced to publish a retraction of the allegations in the RICO case. The plaintiffs advised that they refuse to accept taxpayer money to settle the exposure of individual defendants

Pierre's insinuation of himself, and therefore the Government of St. Lucia, in paying off the personal exposure of his corrupt ministers and CIP Board, is morally and ethically wrong, and illegal, in more ways than we can count. Whether he will be removed from office for cause, or by some other operation of law, we cannot say, but the international reputation of Saint Lucia has most likely now taken a major hit, as well as the assessment of Country Risk by banks in the United States, especially those who maintain correspondent accounts for indigenous Caribbean financial institutions, and all who must maintain risk-based compliance programs.

A CLASS ACTION SUIT TO BE FILED AGAINST ASIAN AND MIDDLE EASTERN BANKS IN THE BILLION DOLLAR CBI/CIP FRAUD SCANDAL

                         

The RICO lawsuit, alleging fraud, money laundering and corruption on a grand scale in the CBI programs of St. Kitts and St. Lucia has created a shock wave in most of the East Caribbean states that offer CBI/CIP citizenship & passport programs. The recognition of the loss of $3.5bn in needed revenue, as well as illegal discounted contracts, has galvanized not only the citizens of Saint Kitts and Saint Lucia, whose economic passport programs are named in the litigation, but those of Dominica and Grenada as well, to seek to be added to the roll of plaintiffs in a potential Class Action lawsuit, because it appears that programs in all the East Caribbean states were victims of illegal discounting of the cost of Citizenship by Investment. Over one thousand EC citizens have written to MSR Media, the lead plaintiff in the RICO case, inquiring about the details in a future Class Action proceeding, and requesting to participate as party plaintiffs. 

The prospect of filing such a case, which is currently under examination by lawyers in the United States who are experienced in Class Action litigation, appears to be assured, judging by the information available from our sources close to MSR leadership. Potential defendants include, but are presently not limited to, all the financial institutions in the United States, the Caribbean, Asia, and the Middle East that accepted CBI application deposits without confirming that they were for the legal price, and were therefore complicit in the fraud, as well as the agents, vendors, consultancies and promoters who advertised, marketed and sold the illegally-discounted citizenships, all of which were paid in US Dollars. 

Banks in Hong Kong, Macau, Dubai, Jordan and Abu Dhabi have been mentioned. It is claimed that there was a total lack of compliance by banks in those countries, as the legal price of the citizenship was not paid; in most cases the funds transited through the correspondent accounts of  Bank of America. Corrupt government officials that facilitated the widespread fraud across the industry are also said to be likely to be named as defendants.

We have confirmed that law firms in the United States that have experience in successfully bringing large Class Action cases have been consulted by MSR, and have rendered a favorable opinion on the outcome of such litigation. They are reportedly focusing on what they see as the primary liability of the financial institutions that accepted the discounted payments, due to the fact that they allegedly failed to conduct effective due diligence on the circumstances of the applicants' purchases, which provided for deeply discounted prices, far below the legal minimums required by the laws that created the schemes. 

The goal of the region's CBI programs, which is to help local government meet budgetary goals, provide needed services, and raise the quality of life for all citizens, has been handicapped by the illegal acts of those who chose to break the laws that govern these programs, to the damage and detriment of those who they were designed to aid, and all those who were responsible for the illegal discounting must be held accountable for their conduct; a Class Action suit appears to provide a suitable remedy, and the victims demand justice. 

Last night, during an interview on Saint Lucia television, Philippe Martinez of MSR media announced that the Class Action will move forward, in the name of all the ordinary citizens of the East Caribbean states, who will be the plaintiffs.

FUGITIVE FINANCIAL CRIMINALS WHO ADROITLY RELOCATE TO THE CARIBBEAN CAN OFTEN DELAY EXTRADITION AD INFINITUM

I used to think that the corrupt court system of the Republic of Panama was the worst; one could easily pay there to "lose" a court file, have a case reassigned, or do any one of a number of things if you were a native-born Panamanian who new how to reach out to the judges with bribes, even those at the Supreme Court of Justice, but now I have concluded that the courts located in the former British Territories in the East Caribbean are, without question, the best place to indefinitely delay court proceedings, especially, extradition of a foreign national who has successfully obtained safe harbour in one of these island republics. The East Caribbean courts, which give new meaning to the term "Dilatory,' can, for the right price, delay a proper extradition request indefinitely, if you have a large enough bank account, or sufficient political clout.

Remember LEROY KING, the crooked Antigua. financial regulatory agency head, who reportedly swore as "Blood Oath" at midnight, exchanging fluids, with Allen Stanford, at a darkened airfield? He delayed his extradition for a full ten years before the Department of Justice was able to remove him to the United States, where a Texas Federal judge gave the maximum sentence, and banished him to a Federal Prison medical complex, to live out what is left of his life.

And what about India's Most Wanted Man, MEHUL CHOKSI, still evading extradition after six long years? How does this real-life "Jabba the Hutt" do it? Simple:

(1) Pay off the judiciary, so that assigned judges are frequently changed, supposedly necessitating tike for the new judge to become familiar with the case.
(2) Have your lawyer unavailable for a substantial period of time, due to, for example, trying a lengthy case in another jurisdiction.
(3) The Court fails to hold hearings in the case for months at a time, and when they do, delay ruling for additional months, dragging into years. Perhaps you change the lawyer prosecuting the case in the local Attorney General's office for good measure, meaning still more delays.
(3) Appealing adverse High Court decisions to the East Caribbean Court of Appeal, and then on to the Judicial Committee of the Privy Council in London, the Court of Last Resort.
(4) Appeal to the International Court of Human Rights, which further muddies the legal waters.
(5) File bogus Constitutional challenges to the extradition laws themselves.

Years pass in the country where the fugitive was wanted; witnesses die, governments change, the political climate and national mood for justice fades, or any number of things happen domestically, and perhaps a decent plea arrangement is offered; the fugitive might achieve his goal of receiving only a slap on the wrist, due to his efforts. Is all this cynical? As they say, justice delayed is justice denied; ask Mehul Choksi, as he games the system.

FAHIE AND MARTELLY; AMERICA'S NEW TAKE-NO-PRISONERS PROGRAM REGARDING CORRUPT CARIBBEAN OFFICIALS ENGAGED IN MONEY LAUNDERING THROUGH U.S. BANKS

If you were surprised to see the U.S. State Department sanction the former President of Haiti, MICHEL MARTELLY, after America had studiously ignored the systemic corruption in that beleaguered Island nation for decades, pay attention. It appears that there's a new attitude toward the large group of utterly corrupt Caribbean officials officials who are the rule, rather than the exception, these days.

Look at the recent case of disgraced former BVI Premier ANDREW FAHIE, if you want further proof; the U.S. Attorney in Miami, in a motion filed before sentencing, sought to increase Fahie's Offense Level to that where the Court would very well sentence him to Life in Prison, a sentence which currently does not allow for any Gain Time, and therefore where he would die in custody. Remember, Fahie's case was an undercover sting; there was actually no cocaine or dirty money involved. So why seek life?

I think the answer is the fact that American financial institutions, many of whom in New York and Miami, maintain correspondent accounts for indigenous Caribbean banks, allowing corrupt Caribbean officials to freely abuse them to deposit the proceeds of crime, are all committing money laundering offenses in the process. Whether it is the proceeds of corruption (bribes and kickbacks) from closing their eyes to drug trafficking, cash paid to facilitate illegal CBI passport sales, or some other criminal activity, it certainly looks like the United States is putting its legal foot down on geedy, amoral Caribbean leaders, to protect its banks.

Perhaps the low-key hands-off Caribbean approach that America has pursued since it got a black eye in the region for the invasion of Grenada, which was seen as "gunboat diplomacy," by West Indians, has finally ended. If this is the case, we welcome it, for far too many US banks are now caught between anti-money laundering compliance requirements and our government's pressure to resist de-risking in the Caribbean region. Indict and arrest those smug, arrogant officials, who think that their government position makes them legally bulletproof in the United States; go get 'em, DOJ.