DID YOU CATCH THE ARTFUL USE OF A SHELL COMPANY IN THE HEZBOLLAH PAGER ATTACK IN LEBANON?

While we are constantly hammering home the abuse of shell companies, shelf companies, bogus virtual charities, paper foundations and other entities that only exist for the use and benefit of the laundrymen who employ them successfully, time & time again, to deceive compliance officers, today's news about the simultaneous explosion of thousands of pagers in the hand of Hezbollah terrorists contained a reference that compliance officers should have immediately picked up on.

The Hungarian company that had the license from the Taiwanese pager manufacturer was located at an accommodation address, when media sought to find it. The company, BAC, also curiously had no profile for manufacturing, which is strange, because it was supposed to the maker of the pagers that we now know contained very small amounts of powerful explosives. Can you say shell company loud enough?

When I was a money launderer, obtaining shell companies in the British Territory of Anguilla, and in the British Virgin Islands, I could not help but noticing that the intelligence services of the world were also clients of the lawyers and accountants vending them to me. Compliance officers should be aware that there may come a time when you identify a transaction as part of a money laundering scheme, but can neither connect a well-funded operation to any individuals that are operating it, nor finding a criminal purpose for the activity.

The intelligence services of the world often use the same tradecraft as i used as a money launderer to disguise the origin of funding that they are distributing to recipients, in furtherance of a country's national policy; they must obscure the origins of that funding, to achieve plausible deniability. So if you find a transaction that simply doesn't make sense, it may very well not be conventional money laundering at all, but something else entirely. Think about that, next time you have questions but no answers.

CALLS FOR THE RESIGNATION OF THE GOVERNOR OF THE EASTERN CARIBBEAN CENTRAL BANK FOR WILLFUL BLINDNESS TO MONEY LAUNDERING IN CITIZENSHIP BY INVESTMENT INCREASE

Public pressure upon TIMOTHY ANTOINE, the Governor of the ECCB, to tender his resignation, after an interview during which he repeatedly evaded answering direct questions about illegal activities of the financial institutions at member banks which constitute money laundering, and could result in major loss of correspondent banking access in the region, has now spread to Saint Kitts & Nevis, where the regulatory agency has its headquarters. A media report just released brutally excoriated Antoine for professing ignorance of what has become a desperate situation where essential correspondent banking is literally hanging by a thread, and the ECCB is pointedly ignoring the problems, which threaten the economies of the EC states that offer CBI/CIP. Antoine has become the face of the problem.

Many observers believe that Governor Antoine is following strict orders of the members of the Board of Directors of the ECCB, all of whom are closely linked to their respective countries' prime ministers, who are themselves alleged to be recipients of illegal compensation from companies engaged in CBI sales, and that this widespread corruption is the root cause of the problem. Antoine's recent interview demonstrated his intentional avoidance of the rampant money laundering problem, which could result in the loss of the three principal US banks which currently offer most of the correspondent banking access to EC banks. He claimed not to be aware that Bank of America had terminated acceptance of CBI money originating in Dominica, and that real threats of the loss of correspondent banking elsewhere, from ECCB Member banks was a real possibility, thereby losing public confidence in his leadership ability.

We call upon Governor Antoine to tender his resignation with immediate effect, and for the immediate appointment of a qualified administrator, from outside the region, so that the problems can be addressed forthwith, before the economies of the countries in the region are severely damaged by the loss of access to the American financial structure, as US banks choose to De-Risk, rather than face major possible fines and penalties from regulatory agencies for failure to rein in massive money laundering from the Caribbean.

REMEMBER, THE US STATE DEPARTMENT TRAVEL ADVISORY ON MAINLAND CHINA NOW ALSO CAUTIONS YOU ABOUT HONG KONG AND MACAU

If you are a compliance officer conducting due diligence in the field regarding Chinese companies, please use local assets instead of in-country visits. You may unwittingly uncover information deemed by China to be a STATE SECRET, and be detained, and it's all downhill from there. Stay out of China, for your own safety. No job is worth a stint in a Chinese prison.

ALERT ON COMPANIES LINKED TO JOHN HANAFIN, OFAC-SANCTIONED DUE TO RUSSIA VIOLATIONS, AND A SELLER OF ILLEGALLY-DISCOUNTED CITIZENSHIP BY INVESTMENT FOR CARIBBEAN GALAXY

Due to JOHN HANAFIN'S OFAC status, for violating international Russian sanctions,
we are listing all companies that are known to be linked to him, or owned by him, for the benefit of American citizens and companies that might come into contact with them, as such as prohibited by law.

HANAFIN has six current positions, including Founder and CEO at Knightsbridge Legal Consultants, Founding Partner at Maine Investment AG, and Ambassador at Soneva. Additionally, John D. Hanafin has had one past position as the Non Executive Director and Consultant at Saffery Champness.

Knightsbridge Legal Consultants, UAE
Founder and CEO
Mar 2022

Maine Investment AG
Founding Partner
Jun 2021

Soneva
Ambassador
Jun 2021

Vanuatu Trade Mission UAE
Director - Foreign Direct Investment
Jun 2020

The Ritz-Carlton, Vienna
Head Of International Sales
Oct 2019

Huriya Private, UAE (Closed)
Founder and CEO
Oct 2021

WILL GOVERNOR TIMOTHY ANTOINE, THE HEAD OF THE EASTERN CARIBBEAN CENTRAL BANK, RESIGN DUE TO THE CBI SCANDAL?

 

ECCB Governor Timothy Antoine

The East Caribbean Central Bank, which is the sole regulator for the region's financial institutions, and is responsible for monitoring all the members o the currency union, has utterly failed to control the corrupt administration of the Citizenship by Investment (CBI/CIP) programs operated by five EC states, by not stopping the illegal discounted sale of citizenships, which has led to the serious situation where a major American correspondent bank has blocked all CBI payments through its accounts, bringing construction to a swift halt in the country where that action was taken, Dominica. Is this the shape of things to come, throughout the region?

Governor Antoine's recent interview on DBSTV was a unmitigated disaster; he denied knowing about the blocking of CBI payments by a correspondent bank, as well as the widespread illegally-discounted sales of citizenships, notwithstanding the huge amount of media coverage in the region, including press conference of the area's prime ministers. He appeared, during the interview, to be totally unaware of the gravity of the current situation regarding De-Risking of correspondent accounts, insisting the everything was under control and in good hands. He cannot be so ignorant of what have become an untenable situation; the only possible reason is that he has been pressured by corrupt senior leaders to do nothing.

 Clearly, the ECCB is not exerting one iota of leadership and control over both the discounted citizenship and correspondent banking crises, which threaten the stability of the economies of the member states. Whether the Central Bank's inaction has rendered it liable to the people of the East Caribbean states, who have lost billions of dollars in CBI revenue that the ECCB failed to control, is a question now being raised in connection with a proposed Class action against the EC banks who accepted illegal CBI payments. Will the ECCB end up as an additional defendant in that action? It seems inevitable.

We call upon Governor Antoine, who has been grossly negligent in providing ECCB guidance to,  and regulatory control, over the member banks, to tender his resignation forthwith, and for the Central Bank to engage a qualified professional, with extensive central banker experience, to deal with the imminent financial dangers facing the region's banks. He should be from outside the region, so that there will be no question of undue influence from the area's political leaders, who are believed to have interfered with the Governor's independence, regarding chronic problems with the CBI programs. We note that the head of the Saint Kitts & Nevis CIU has now resigned, due to the scandal; Antoine should follow his lead.

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.