THOUSANDS OF CARIBBEAN CBI/CIP CITIZENSHIPS PURCHASED WITH ILLEGAL DISCOUNTS WILL BE CANCELLED, AND THE PASSPORTS ISSUED REVOKED

Geoffrey DuBoulay

As more details emerge, regarding the tens of thousands of economic citizenships that were sold at an illegal discount, and the responsible East Caribbean governments in St. Kitts, Dominica, St. Lucia and Grenada advise that they intend to cancel all illegitimate transactions, the impact upon what is known as the Migration Investment industry is starting to be felt. Some jurisdictions, such as the Commonwealth of Dominica, have already begun cancelling passports, while officials at others, casting blame upon the purchasers for failing to ascertain that buying at greatly reduced rates was illegal, are attempting to shift legal responsibility to those who acquired CBI/CIP. Blame shifting, gentlemen, will not work here; you approved those illegal passport sales.

Apologists at the Citizenship by Investment Unit (CIU) in Saint Lucia, have chosen to deceive their purchasers, many of who now fear imminent cancellation, and total loss of their six-figure investment, by deceptively declaring that local laws provide Due Process, the Rule of Law, and a degree of protection against summary revocation of their prized passports. A legal opinion, authored by local attorney and CIP vendor GEOFFREY DUBOULAY, citing a number of obscure appellate cases, attempts to reassure panicked passport holders. Unfortunately, the illegally-discounted passports are void as a matter of law. Additionally, most passport holders will fear that there could be consequences in their home country, or for other reasons, which would deter them from bringing legal or administrative proceedings to contest revocation.

As international political and legal pressure upon East Caribbean CBI states to initiate, and duly complete, cancellation en masse of the passports, a lack of investor confidence in the industry as a whole may result, as well as litigation brought against entities and individuals alleged to be responsible. Indeed, the validity of CBI passports when presented at international airports of entry abroad may become an issue. Whether the industry will survive this scandal depends upon how promptly the countries involved clean up their mess, and how financial adjustments, if any, are made and disbursed to the members of the public who purchased them in good faith that they were legitimate.

GRENADA ALLOWS DODGY OFAC-SANCTIONED INDIVIDUAL TO SELL ITS ECONOMIC CITIZENSHIPS

                                                                   John Hanafin

The five East Caribbean states that offer Citizenship by Investment (CBI/CIP) schemes all attempt to reassure potential purchasers that the consultancies and vendors whom they authorize to act on their behalf as "licensed" companies and individuals are trusted professionals, much like licensed insurance agents. Often, nothing could be further from the truth, as many are non-professional sales people who are often less than candid about any potential risks that may arise from owning a CBI passport. For example, some of the selling jurisdictions have a dark history of their banks' involvement in international money laundering, resulting in a possible targeting of any passport holders from their countries when engaged in international travel, or making wire transfers to high-risk countries.

A Dubai-based company. known as HURIYA PRIVATE FZE LEE, and its principal, JOHN DESMOND HANAFIN, engaged in the sale of Grenada CBI citizenships, were sanctioned more than a year ago by the Office of Foreign Assets Control, or OFAC, due to multiple violations of international sanctions imposed on Russia due to its invasion of the Ukraine. Our sources have advised that Huriya, which engaged in the sale of illegally-discounted Grenada citizenships through HENG SENG, is now closed, while Hanafin continued to vend illegal citizenships through successor companies. We are presently investigating those entities, and expect to have further identifying information regarding them in a subsequent article

We are unable to locate Mr. Hanafin, as are many others, and there are reportedly multiple creditor claims pending against him for Huriya business debts. Any reader with information about Mr. Hanafin is urged to contact us at: miamicompliance@gmail.com

Hanafin's Grenada CBI offer

The pressing question is: If the Grenada government vets its citizenship vendors and sales consultants, how could it approve an individual, and a company, that were the subject of international sanctions? I have seen a quote from the present head of the country's CIU, that sanctions are not themselves disqualifying for involvement with the CBI program, so we wonder just how many dodgy or unsuitable sales agents who should be barred from offering Grenada citizenships are currently approved to deal with the public?

MONEY LAUNDERING TRADECRAFT; IT'S ALL ABOUT PERMUTATIONS AND COMBINATIONS

During the decade that I was a career money launderer, I often stayed up nights and weekends to brainstorm. The object of this thought process, which is to create a new money laundering technique which will not be easily recognized by either compliance officers or law enforcement investigators, was my central goal. If my adversaries do not conclude that a specific set of facts is, in truth and in fact, a money laundering operation, rather than normal commercial activity, the odds are it will neither be interdicted in real-time, nor subsequently exposed in subsequent analysis.

What one does is take an existing method, which has been successfully used in the past, and either modify it to further increase its changes of success, while in the process disguising it further, or apply it to an industry or business not previously known to be a target of laundrymen. The result is basically, old wine in new bottles, which generally results in a new category of technique, and one which compliance officers will not recognize, and therefore not red flag as potential criminal activity.

Why is this important to understand? Because if a compliance officer is not familiar with the full gamut of advanced money laundering methods in use, he or she will miss the modified technique as simply a new version of an old trick. The new method will be dismissed as some sort of legitimate variation on everyday commerce. One must have acquired the skill set of all the esoteric and obscure techniques to be able to pick up those clever modifications on a theme. You see, it's not about your imagination, it's all about how you are able to see how your opponent has adapted the techniques in his existing tool box in a new way, to fool you into ignoring them. Learn the full spectrum of what has already been used by the laundrymen,so that you can spot their permutations, and thereby respond to new challenges. Continually expand your knowledge to meet new challenges head on.

SAINT LUCIA ATTEMPTS TO RETROACTIVELY LEGITIMIZE ILLEGALLY-DISCOUNTED ECONOMIC CITIZENSHIPS

If you thought that you had heard it all, regarding the sale of 28,000 illegal Citizenship by Investment (CBI/CIP) passports that were neither authorized nor approved by the Parliament of Saint Lucia, it just got worse. The Prime Minister, PHILIP PIERRE, the Deputy Prime Minister, ERNEST HILAIRE, and the country's Attorney General, LESLIE MONDESIR, who are said to be behind this legislation, are now attempting to retroactively validate all the illegal passport sales of The National Infrastructure Improvement program, which was sold by the Chinese-controlled company, CARIBBEAN GALAXY REAL ESTATE LIMITED.

The official Gazette Notice of their efforts appeared today. Note that the approval attempts to legitimize all prior Infrastructure citizenship sales, backdating their approval to a prior date when it should have been made, as required by CBI regulations. This unusual act, which is a belated attempt to confer legitimacy upon what is an illegal sales program, is an obvious effort at remedial measures intended to respond to the potential personal liability of St. Lucia government officials who conspired with Galaxy for monetary gain, and which is one of the subjects of the RICO case in the United States.

PM Pierre

The reason the notice recites that the legislation relates back to January 12, 2024 Is because Galaxy was selling, and authorized agents were processing, applications for the infrastructure project which was not legally in existence at that time. Upon judicial review, a court of competent jurisdiction may very well hold that the legislation violates Saint Lucia's CBI laws, and that such a ruling will be upheld on appeal.

DPM Hilaire

Remember also that all of Galaxy's sales were made at an illegally-discounted rate, which renders them void ab initio. This proposed legislation cannot cure that fatal flaw, but it is evidence of desperation on the part of the drafters, who see accountability for their illegal actions closing in on them as the RICO case moves through the court system.

WHILE AMERICA SLEEPS

The evidence of looming Chinese power in the Caribbean is everywhere; it's not just because more than $3.5bn in Citizenship by Investment (CBI/CIP) funds were stolen and diverted to Hong Kong, in what I can only described as an organized crime operation, facilitated a group of avaricious local government officials. One can see it in the massive Chinese enclave being carved out in a wildlife refuge in Antigua, which will have its own passports, airline and port facilities capable of servicing warships for Mainland China. It can be seen in the huge Chinese embassies in the region, which are obvious listening posts on the United States. It can be seen in the camouflage-clad, and Chinese-equipped paramilitary police in Dominica, riding around in armored cars built in the Peoples' Republic. It is all that and much more.

Although the increasing Chinese financial influence in the East Caribbean has only been a regular topic of late, due its co-opting and domination of the CBI programs of the region, it has been a long time in development. The US, preoccupied with what it deems more strategic issues in Asia, the Middle East and Eastern Europe, has pointedly ignored the region sinc the Grenada invasion forty years ago. Have we forgotten the lessons of Grenada? Apparently so, for the cost of America's benign neglect of the region is coming back to deal a real blow, literally in our backyard.

Although my field is money laundering, and the consequences of failure to interdict it in real-time, and to control it long term, I feel that I must rise these issues now before people watching sunset in the Key West are treated to a look at a Chinese destroyer in American territorial waters, headed north. Wake up, America; The color of the Caribbean is becoming red.

REMEMBERING A FRIEND LOST ON 9/11 IN THE TOWERS

REST IN PEACE

HSBC LOOKING TO PULL OUT OF MALTA; IS IT THE RAMPANT FRAUD, MONEY LAUNDERING AND CORRUPTION, AND ARE AMERICAN BANKS WATCHING?

The Republic of Malta, the sole surviving European Union country to still sell economic citizenships, appears to be losing HSBC's Malta subsidiary; the bank issued a press release describing its "strategic review," a reassessment of its role these, which is bankspeak for a planned pullout. For many years, we have covered Malta's systemic money laundering problems, now complicated by a major corruption scandal, with elements of a massive fraud. No wonder HSBC is seriously considering a complete withdrawal; the risk most likely exceeds the rewards it receives.

Malta, which is fighting a European Commission intent on terminating the country's IIM (CBI) economic citizenship program in the courts, has been selling passports to individuals from high-risk countries with impunity; those prized passports give bad actors visa-free entry into the Schengen Zone, which is the only reason the clients purchase them, and the EU is most likely tired of the resultant increased risk.

We trust that US banks are paying attention, especially those that are still engaged in lucrative correspondent banking business with Caribbean financial institutions located in states that sell economic passports. Malta is also guilty of deliberately ineffective AML compliance in its CBI program, which facilitates money laundering into the EU, and gives the European Union nightmares. Whether American banks see the disturbing parallel here remains to be seen, but we will be watching to see if they are paying attention.

WHY IS THE DEPARTMENT OF JUSTICE ASLEEP AT THE WHEEL REGARDING RAMPANT CITIZENSHIP BY INVESTMENT MONEY LAUNDERING THROUGH U.S. CORRESPONDENT BANKS?

The billions of US Dollars that have been cleaned through the correspondent accounts of several Caribbean banks involved in CBI is only the latest in a never-ending cycle of money laundering that originates from that region. The huge volume of cash that American banks have allowed to enter those accounts with impunity, for years, without any major enforcement action being taken by the Department of Justice, cannot be explained. Since the banks, by and large, have been left to their own AML/CFT programs, they have not, with rare exception, clamped down on the indigenous banks of the Caribbean, whose corruption and ineffective compliance policies have been responsible for allowing massive amounts of criminal proceeds to enter their correspondent accounts in the US.

The present scandal involving the purchase of economic citizenships at illegally-discounted rates, and illicit capital flight of billions to China may have caught the attention of the financial world, but pervasive money laundering, with cash coming from the Caribbean, has been a chronic problem not suppressed by America's Federal prosecutors.Whether we blame America's passive attitude towards corrupt Caribbean governments and their local allies, due to a national policy of non-interference in our backyard, or just a preference to devote attention to regions deemed to have a high priority, due to National Security, America can no longer allow the Caribbean to clean dirty cash through our banks.

We can only hope that the filing of the civil RICO case will galvanize the Department of Justice into action, so that it can commence sufficient enforcement action to interdict the rampant money laundering now infecting our banks from the Caribbean, employing all the tools in its command, including indictments, OFAC sanctions, FinCEN action, and whatsoever additional remedies it deems necessary and proper. Please, DOJ, reign in money laundering coming from our Caribbean neighbors; things are really getting out of hand of late from CBI.

ARE UNEXPLAINED RESIGNATIONS AT THE SAINT KITTS CITIZENSHIP BY INVESTMENT UNIT DUE TO THE FILING OF INCRIMINATING EVIDENCE AGAINST THE CEO AND FORMER CHAIRMAN?

CIU CEO Michael Martin

According to reliable sources, the Chief Executive Officer of the Saint Kitts & Nevis Citizenship by Investment Unit (CIU) MICHAEL MARTIN has abruptly resigned, with immediate effect. He has not given any reason for his action; Is the possible resignation of Michael Martin related to the fact that evidence were presented in court that he has processed applications sold under the legal price for the Galaxy jail project ? Our investigation has revealed that no CBI vendor or consultancy is selling Galaxy for the full legal citizenship price.

Thus far, official government sources have mysteriously been silent regarding Martin's status, and we are unaware whether he remains in Saint Kitts, or has now left the country. Our efforts to contact him to comment on this news, through his official email address, have failed to result in a reply or response. We note that one recent online article about him has curiously been deleted from the site of a major news organization.

Chairman Sylvester Anthony

To add to the ongoing mystery, questions persist as to the real reason that SYLVESTER ANTH0NY, Chairman of the Board of Governors of the CIU, himself strangely resigned his position, again without any public statement from Prime Minister Drew's government. He has not given any reason for his action, although it is widely believed that incriminating evidence against him exists in the RICO case, where he is listed as a conspirator. Will there be an official investigation into the circumstances of these resignations?

GRENADA MAKES A PRINCIPAL CITIZENSHIP BY INVESTMENT VENDOR A SPECIAL DIPLOMAT; WHY?

 

In our coverage of  Chinese consultancies found to be selling economic citizenships at illegally-discounted prices, we have previously detailed the involvement of CHINA HENG SHENG (SINGAPORE) DEVELOPMENT PTE. LIMITED, which continues to process applications for Grenada CBI/CIP citizenships, notwithstanding an industry-wide ban on such transactions. During our further inquiry into Heng Sheng, which often appears as HS, we have learned that the CEO of the company, YUANFA LI, was appointed the Grenadian Ambassador to Singapore. His bilingual business card appears above and below.

We note that the ostensible "Embassy" address in Singapore is within an accommodation office building, where one can maintain a minimal presence, without actually being in residence. In many cases, such as this, the hyphenated suite number generally indicates that it is little more than a post office box, where a group operator will answer the telephone and collect mail for forwarding. The fact that the email address is in Gmail, rather than a special Grenadian government domain, is another red flag,  indicia that the appointment was not for a functioning diplomat but merely a title to be flashed at the appropriate time and place for maximum effect with clients. 

He obviously does not reside there on a full-time basis. We have previously detailed in other articles the requirements of the Vienna Convention regarding who is regarded as a bona fide diplomats, and we will leave that legal determination to the United Nations, but there is a more ominous aspect to this diplomatic appointment; according to Li's business card, he is an AMBASSADOR EXTRAORDINARY AND PLENIPOTENTIARY. a rare diplomatic rank generally accorded only to diplomats accredited to the United Nations, or some other major international organization.

Why is this important?  the Plenipotentiary designation, which can only be granted by a Head of State, which in this case would be Grenada's Prime Minister,  DICKSON MITCHELL, gives Li  the full power of independent action, meaning he can enter into treaties and agreements, which will fully bind Grenada. Remember, he is a Chinese national, although he most certainly has one of those Grenada CBI citizenships. His rank affords him decision-making ability about Grenadian affairs generally only available to Native-born citizens who are senior Cabinet-level or above. the word "Extraordinary" in his title is spot on.

Now we get to what is most likely the underlying reason. Let's take a trip backwards in time, to the advent of CBI, to the first Caribbean country to create economic citizenships back in 1984. it was WILLIAM  ( BILLY) HERBERT, JR., the Foreign Minister of newly-independent Saint Christopher & Nevis, usually called Saint Kitts,  who created CBI, held also the UN, US and OAS ambassadorship portfolios, and was also designated Ambassador Extraordinary and Plenipotentiary. This frankly made him untouchable as a potential criminal defendant in the United States, for the political firestorm that would have ensued, had he ever been indicted in the US, would have been fierce, especially during the Grenada invasion aftermath. 

Yuanfa Li and Grenada PM Dickson Mitchell

Why would this be a concern to US law enforcement? You see, attorney Billy Herbert was both a money launderer for drug traffickers and a facilitator of terrorist financing; I know that because I worked with him, but the US simply could never indict him, his sins notwithstanding. The only thing the United States could do is cause his US ambassadorship status to be disapproved.

Given that there has already been public evidence that HS is engaged in illegal discounted sales of Grenada citizenships, and that the deposit of the proceeds of such criminal acts into American correspondent bank accounts of US Dollars has occurred, it occurs to us that an contemplated criminal prosecution of Grenada's Ambassador to Singapore may be problematic. Does he possess a literal Get-out-of-Jail-Free Card? That question is on my mind, and the Department of Justice may have to weigh in on it, as the CBI discounting scandal spreads throughout the region, right towards Grenada. 

 

FOUR LAWYERS FRANTICALLY PROCESS ILLEGAL SAINT LUCIA APPLICATIONS FOR CARIBBEAN GALAXY, FACILITATING THE FRAUD

Three prominent attorneys, working in St. Lucia at the POLARIS CITIZENSHIP & INVESTMENT CONSULTANCY SERVICES LIMITED, have been reportedly working literally around the clock, to process and complete thousands of Saint Lucia citizenship applications, through the Chinese company, Caribbean Galaxy  Real Estate Limited, all of which contain illegally-discounted prices. Their frantic efforts, coming right in the middle of an unfolding CIP crisis that is the subject of an American RICO lawsuit alleging fraud, money laundering and corruption, are occurring notwithstanding all the media coverage, and all the warnings. These lawyers, GEOFFREY DUBOULAY, BRENDA FLOISSAC-FLEMING, and DIANA THOMAS, are said to be working nonstop to process the maximum number of citizenship files, when the illegal nature of discounted application pricing has been established under Saint Lucian law, and expressly prohibited by the country's Citizenship by Investment Unit (CIU). The applications are all for the Infrastructure Fund,  which was not ratified by Parliament, rendering their sale and processing illegal. 

These three lawyers, who are known to be close associates of former Saint Kitts CIP CEO and Galaxy CEO LES KHAN, have processed thousand of applications during the past 90 days for St. Lucia CBI passports. The fact that their applications have been successfully accepted at the CIU confirm that members of the Unit are implicated in the fraud, that the staff are acting under orders of the CIU head, as well as the country's elected leaders, including but not limited to, Deputy Prime Minister ERNEST HILAIRE, who has the portfolio for CIP in St. Lucia, and McClaude Emmanuel of the CIU.

Thaddeus Antoine

In Saint Lucia, another law firm, TM ANTOINE PARTNERS, owned and led by local attorney THADDEUS ANTOINE, is similarly engaged in fast-tracking illegally-discounted CIP applications. Antoine, who is reputed to be the direct contact with the Chinese officials at Caribbean Galaxy, is said to have his staff  also working at top speed, to process as many CIP applications as possible, fearing that the program which authorizes them will be shut down, either by court order, or by the act of a law enforcement agency .

Both of these illegal operations, brazenly conducted in the face of the continued production of incriminating documents, from the RICO case, from the regulatory action, and from the Defamation proceedings in Saint Kitts, all of which have, through clear and convincing evidence, shown that Caribbean Galaxy's discounted sales program is illegal, demonstrate a total contempt for the Rule of Law, and are part of a continuing conspiracy to defraud the people of Saint Lucia, and part and parcel of the fraud, money laundering and corruption Caribbean Galaxy scandal.

Since the Saint Lucia government leadership itself is part of the fraud, we cannot rely upon them to order the CIU to cease and desist from processing the applications, and the court in Saint Lucia cannot be relied upon to dispense justice in a timely fashion, if at all, the only viable solution may be for all the US banks, through whose correspondent accounts the CIP money flows, to block all transactions, as the Bank of America has done in Dominica. Meanwhile, how can we obtain justice regarding the unspeakable conduct of these lawyers? perhaps FinCEN or OFAC might want to be heard from on that issue, and look into the conduct of GEOFFREY DUBOULAY, BRENDA FLOISSAC-FLEMING, and DIANA THOMAS, as well as THADDEUS ANTOINE. I have been covering the citizenship by investment industry for twenty years, and I have never seen this level of criminality.