SAINT LUCIA'S PRIME MINISTER UNDER MOUNTING PUBLIC PRESSURE TO REFORM CITIZENSHIP BY INVESTMENT (CIP) PROGRAM AND SACK DEPUTY PRIME MINISTER ERNEST HILAIRE FOR CORRUPTION

After ERNEST HILAIRE, the minister in charge of oversight of Saint Lucia's Citizenship by Investment (CIP) passport sales program, flat out refused to disclose the details of missing revenue from sales of passports, amount to a billion US Dollars or more, the United Workers Party (UWP) has demanded, in an open letter to SLC PM PHILIP PIERRE, that he completely reform the program, and relieve the Minister for Investments, Deputy Prime Minister ERNEST HILAIRE for misconduct, forthwith.

The letter's primary complaint is spelled out early on:

"Dear Prime Minister Pierre... The situation with the CIP is particularly egregious. Newly leaked contracts reveal that over 5,000 Saint Lucian passports, valued at US$1 billion, have been allocated under the Galaxy arrangement. Alarmingly, US$600 million of this amount remains unaccounted for, raising serious concerns about transparency and accountability. Additionally, Bemax—a company contracted to construct 66 low-income houses for US$62 million—has been linked to criminal activity, with its principal recently arrested as part of a major organized crime investigation."

The UWP has demanded, in the letter, that the PM, who has been accused of failing to exercise any leadership in the matter, take the following steps immediately:

"1. Dismissal of the CEO of the CIP Programme for failing to uphold the integrity of the programme.

2. Replacement of the CIP Board to restore public confidence.

3. Removal of the Minister responsible for the CIP portfolio to ensure impartial oversight moving forward.

4. An independent investigation, spearheaded by the Director of Public Prosecutions (DPP) and the Auditor General, to uncover the full extent of the mismanagement.

5. Suspension of any further issuance of citizenships related to Galaxy and infrastructure investment until the investigation is completed."

DPM Hilaire, who claimed that to disclose details of the Galaxy transactions would require company approval, as it is privileged information, and then failed to secure that permission, is alleged to have collected millions of dollars, in bribes and kickbacks, from the company, and that is why he is stonewalling his constituents about the missing billion; public calls for his resignation are known to be increasing, amid multiple allegations of fraud, money laundering and corruption.Whether Prime Minister Pierre takes prompt action will most certainly have an effect on the  Saint Lucia Labour Party's chances of remaining in power. 

FORMER BVI PREMIER ANDREW FAHIE OFFERED TO OBTAIN WEAPONS IN COCAINE AND MONEY LAUNDERING CASE

Buried in the prosecution's evidence in the Federal criminal case  against disgraced former British Virgin Islands Premie ANDREW FAHIE, presently serving an eleven year sentence in an American prison after his conviction for cocaine trafficking and money laundering, was some additional information that debunked Fahie's claims that he was an innocent bystander; and showed that he was not entrapped by a US law enforcement agency, in an undercover operation. Although not covered in the articles published in America media, Fahie did indeed offer to supply the Cooperating Individual in his case with weapons, according to BVI media reporting details of the case.

 Additionally, it was reported that Fahie was previously under investigation for  money laundering a decade ago, for having bribe proceeds from corruption involving a construction project smuggled into the United States by associates. Remember, Fahie admitted that the case was not "his first rodeo."

WATCH SAINT KITTS & NEVIS POLITICAL COMMENTARY ANALYZE THE COUNTRY'S PRIME MINISTER, TERRANCE DREW'S PRESS CONFERENCE, AND DETAIL HIS DECEPTION ABOUT THE CITIZENSHIP BY INVESTMENT SCANDAL

 

https://www.youtube.com/watch?v=SFuC89lt_K8&t=4s

CHIEF SUPERINTENDENT OF THE ROYAL BAHAMAS POLICE FORCE, AND OTHER POLICE AND GOVERNMENT, CHARGED IN U.S. WITH SUPPORTING A MASSIVE COCAINE SMUGGLING OPERATION

 

The United States Attorney in New York (SDNY) has charged thirteen defendants, including ELVIS NATHANIEL CURTIS, the Chief Superintendent of the ROYAL BAHAMAS POLICE FORCE, and other Bahamian police officers and government officials, with operating a massive cocaine smuggling operation, that flooded the United States with tons of the drug over a several year period. The cocaine charges, including the possession of firearms in the commission of a narcotics importation conspiracy, which carry a 10-year minimum mandatory sentence, and a maximum Life Sentence upon conviction, included the allegation that the drugs were to be safely stored in the Bahamas and protected, in a manner similar to that of the recent case where former BVI Premier ANDREW FAHIE was convicted in SDFL. Fahie also also conspired with others in an agreement to store drugs in the British Virgin Islands, and give them safe passage through BVI maritime waters.

We note that the case, which involved cocaine of Colombian origin, is being prosecuted by the DOJ National Security Unit, indicating that the illegal operation is considered to be a national security threat to the United States. Some of the defendants have already been arrested in Florida.

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RAISE COUNTRY RISK ON SAINT LUCIA DUE TO SERIOUSLY ELEVATED MONEY LAUNDERING CONCERNS CAUSED BY THE CITIZENSHIP BY INVESTMENT (CIP) SCANDAL

The risk that any significant transfer of funds originating from SAINT LUCIA are the proceeds of crime remain elevated to the extent that we must recommend that Country Risk for that East Caribbean state be elevated to High Risk status. The efforts of both local, as well as American, media, to get to the truth about the full extent of the sale of citizenships at illegally-discounted rates, the location of more than a billion (US) dollars converted and diverted by Chinese actors, and a total lack of cooperation, from both government, as well as the country's principal private financial institution, the BANK OF SAINT LUCIA, requires that compliance officers exercise extreme caution in any financial transaction where Saint Lucia is remitting funds to US banks.

We remind our readers that the country's Deputy Prime Minister, ERNEST HILAIRE, has stonewalled and ignored all public inquiries, regarding the CIP program, and we note that he, as the Minister for Investment, has a fiduciary duty to be totally transparent, making full disclosure, in response to both media and public queries regarding CIP; inasmuch as he has not, we are unable to assume that any CIP funds have been vetted for Source of Funds, and represent a clear and present danger to any US financial institution that accepts them. Compliance officers charged with calculating and assessing Country Risk should govern themselves accordingly.

AMERICAN BANKS HAVE NO CHOICE; THEY MUST NOW RAISE RISK LEVELS ON HONG KONG, OR RISK FACILITATING IRAN & RUSSIA SANCTIONS VIOLATIONS, MONEY LAUNDERING, AND OTHER RELATED FINANCIAL CRIMES THAT HONG KONG IS CLOSING ITS EYES TO IT FOR PROFIT

If you saw the recent statements made by prominent Members of the US Congress, pointing out how banks in Hong Kong are assisting Russia in evading international sanctions, and facilitating payment for illicit Iranian oil shipments, and Hong Kong's quick but terse denials, you know that it's time for American banks to raise risk levels on the former British territory. We completely agree, and also remind readers that both of the Chinese CBI companies that illegally diverted billions of dollars from programs in Saint Kitts and in Saint Lucia, directly to Hong Kong's banks.

If this means you must raise Country Risk on China itself, then do it. otherwise, you increase the chances that your bank will unwittingly fall victim to assisting in the evasion of international sanctions, or something even worse. Those US Congressmen are dead right on this; believe them, and act accordingly if you are a compliance officer at a US bank with substantial international trade clients.

WHY DID THE UNITED STATES AGREE TO PROVIDE $300m IN FUNDING TO A COUNTRY IN CHINA'S SPHERE OF INFLUENCE?

This week's news from the Caribbean included a signing ceremony at the US Embassy in Barbados, wherein America signed together with the Prime Minister of Saint Kitts & Nevis, a Memorandum of Understanding promising to make up to three hundred million dollars in development money available, through the Export-Import Bank of the United States.

Has the American government lost its mind? The St. Kitts PM, and indeed his entire country, is mired in a messy eight figure fraud, money laundering and corruption scandal. Drew himself is alleged to be a central player in the corruption, and any objective observer would conclude that the leaders of Saint Kitts are completely under the influence of the Peoples' Republic of China, which has taken billions out of the country, and appear to have its government under its firm control.

Doesn't anyone at Ex-Im Bank bother to conduct enhanced due diligence before approving financing guaranteed by the United States? There's something dreadfully wrong here; we can only hope that the incoming administration, which appears to be clear-eyed on China as a clear and present danger to the United States, block funding.Otherwise, it's like giving China a credit card, and allowing it to have a shopping spree at Uncle Sam's expense. Wake up, America!

WILL THOSE INDIVIDUALS WHO WERE IN CHARGE OF AML/CFT COMPLIANCE AT TD BANK FACE A RECKONING, OR WILL THEY SIMPLY FIND POSITIONS ELSEWHERE?

The Faces of Evil

As a former career money launderer, my mission is to Keep Coming Straight on at you with the Truth. When MOSSACK & FONSECA self-destructed, and its name partners arrested, I published the names of all the lawyers and paralegals there who had assisted the world's corrupt PEPs in hiding and laundering their bribes and kickbacks in bulletproof BVI corporations. I did that so that these individuals, who were actively concealing their dark past at M & F, would not be accepted at Panama's legitimate law firms, where they might potentially target those firms' clients' assets, using the tricks they learned from their prior employer.

TD Bank's leaders have gone on record to state that there will be "accountability," regarding those individuals who were responsible for years of a completely dysfunctional compliance program. Frankly, given all the spin contained in their carefully parsed public statements, all of which reek of PR origin, and signify nothing, I don't trust the bank to discipline its errant compliance leaders, and their direct superiors in the chain of command. I suspect that they will simply give them glowing recommendations, as they go out the door, only to be hired elsewhere by unsuspecting bankers ignorant of the truth.

The identities of those individuals responsible for the three billion dollar fine will probably never be known to the financial community, unless they are named & shamed. Will TD do it, or must that information appear in another forum?

MONEY LAUNDERING INTO U.S. BANKS THROUGH CARIBBEAN CITIZENSHIP BY INVESTMENT PROGRAMS CONTINUES UNABATED AND IGNORED

For decades, six figure application fees have been paid by dodgy foreign nationals, many from high-risk jurisdictions, into the Citizenship by Investment (CBI/CIP) passport sales programs of the five East Caribbean states, all going into correspondent accounts at America's biggest financial institutions, without any adequate prior AML/CFT compliance being conducted abroad. While we fully understand that those accounts are a lifeline to the developing countries from the Caribbean region, which must import 90% of finished consumer goods for local consumption, and American foreign policy has always been to support those countries in their economic development, the time has come to interdict large amounts of criminal proceeds that are effectively being laundered in our New York and Miami financial centers, because a substantial portion of it goes on to be invested in the United States for  transnational career criminals, corrupt PEPs, foreign tax cheats, and a host of the other Usual Suspects who would never pass a due diligence check should they dare to seek to open an account in an American bank.

Remember, it was the late William (Billy) Herbert, then the Foreign Minister of Saint Kitts & Nevis who, when he invented CBI forty years ago, chose to require that applicants remit their funds in US Dollars, rather than any European or Caribbean currency, which is what started what has become one long continuing money laundering nightmare for those US banks that choose to service the Caribbean through correspondent accounts. That, ladies & gentlemen, is how we have ended up in such a dark place, where AML is consistently ignored by the CBI states, and both Federal law enforcement agencies and our esteemed regulatory agencies sit on the sidelines and let all this dirty money enter our financial structure unmolested and untouched. 

If there is a bright side anywhere for the United States, it is that court decisions construing the Money Laundering Control Act of 1986 have conferred personal jurisdiction of foreign nationals that use our Dollars to commit money laundering, even though they have never entered the United States. The problems is that our law enforcement has utterly failed to use this valuable tool against those who would clean their proceeds of crime through CBI, into our banks. I challenge the incoming administration to step up, and shut down these financial barbarians literally at our gates, block and seize unchecked CBI funds from the Caribbean are entering with zero compliance, start bringing indictments of the bad actors, and if necessary, take whatsoever steps it deems necessary and proper to either reform the CBI programs, or failing that, deny them the ability to deposit what has become a financial obscenity into American banks. 

CONFRONTED WITH INCRIMINATING EVIDENCE AGAINST HIM, ST. KITTS' PRIME MINISTER ATTEMPTS TO CONFUSE THE ISSUES WITH DISINFORMATION

 

Caribbean Galaxy's YING JIN with PM DREW at the United Nations

In the aftermath of MSR Media's PHILIPPE MARTINEZ' podcast confirming that Saint Kitts Prime Minister TERRANCE DREW had approved the processing of illegally-discounted CARIBBEAN GALAXY citizenship, for the Jail Project, and demanding to know where all the Galaxy money was, Drew attempted to divert attention from the $962m unaccounted for. He told a media interviewer a ridiculous story, to the effect that that an unnamed representative of Martinez had demanded a huge monetary sum to settle the pending RICO lawsuit. He also alleged that Martinez' representative had demanded that the money come from the Saint Kitts government. The story was a complete fabrication. Drew did not meet with any authorized representative of MSR Media. Obviously, the purpose of Drew's interview was to create public anger at Martinez, due to the alleged demand for public money, which was completely untrue.

 In truth and in fact, not only was none of Drew's story true, but he had not met with Martinez' only legal representative, Saint Kitts attorney, Damian Kelsick, to discuss the case. According to Kelsick, Drew did not meet with any authorized representative of MSR Media; we have the email confirming that there was never such a meeting. Kelsick's reply to the government lawyer's request for a settlement proposal was no meeting with any MSR representative. Obviously, the purpose of Drew's interview was to create public anger at Martinez.We note that the Government of Saint Kitts is not a defendant in the RICO case, which names Galaxy and several other parties. The Drew interview was designed to distract attention from Martinez' evidence of corruption money paid to officials offshore. MSR Media has transmitted the bank statements to the US Department of Justice as well as the court in Saint Kitts, as Martinez stated in his podcast. It confirms massive corruption, money laundering and fraud, on the part of Galaxy, as well as several individuals, both inside and out of St. Kitts government.

PM Drew again lied to his people by stating he has not approved MSR in the CBI. Drew had signed in November 2023 an agreement between MSR and his government authorizing MSR to shoot and build new movie industry in the country. and become a Public Benefit Option .PM Drew, in his ongoing due diligence, lies; he only stopped the construction of the jail project, which raises questions on whether Galaxy paid in advance the money for the construction or not, but PM Drew, in his ongoing due diligence and despite all the warnings, continued to process the jail project applications under the legal  price set by his own government. Now the biggest questions are where is the $40 million US dollars allocated to build the jail? And why Drew is defending Galaxy ? Who is Drew protecting ?

Martinez, in responding to Drew's interview, stated " Where is the Galaxy money? The evidence we provided to the Saint Kitts courts and the US Department of Justice confirms that passports were sold illegally under the posted price by two sales agents for Galaxy, during the Drew Administration." Furthermore,  he has suggested several times to the Prime Minister, and to SKN Attorney General Wilkin, that Wilkin travel to Washington DC to meet with the Department of Justice, and the Federal agents working the case based upon the evidence provided by MSR Media. The AG has refused to follow Martinez suggestions. In August 2023, Martinez suggested that Wilkin should definitely meet with the US DOJ, so the people of Saint Kitts will know what Caribbean Galaxy is doing with the CBI money.

For his safety, it has been suggested to Mr. Martinez by US law enforcement that he remains in the United States while the investigation is ongoing. In the meanwhile former SKN CIU and Galaxy CEO LES KHAN is nowhere to be found.

SAINT LUCIA'S ARROGANT DEPUTY PRIME MINISTER ERNEST HILAIRE IS THE FOURTH RICHEST INDIVIDUAL AMONG GOVERNMENT OFFICIALS IN THE FORMER BRITISH CARIBBEAN TERRITORIES

As part and parcel of our continuing investigation of corruption in the Citizenship by Investment (CIP) programs in the five East Caribbean states that sell passports, we have been calculating which senior government officials, at the ministerial level and above, have become multi-millionaires through the  illicit payment to them of bribes & kickbacks for each any every citizenship sold in their respective jurisdictions. 

We have taken published government figures, information obtained from confidential sources, and conservative estimates given from industry experts and former insiders, and come up with a short list of the officials who have collected the most cash from their criminal careers as facilitators who have used their authority to approve an obscene number of applications, often in numbers that exceed the total population of the states that they are charged to lead.

While we have decided to defer publishing all our findings of fact and conclusions, for the time being, it has come to our attention that there is one individual who stands out among the rogues' gallery of sinners, whom we wish to bring to the attention of our readers, simply because his illegally-derived wealth is all out of proportion to the small CIP role his country has previously played among the five East Caribbean states; It is Saint Lucia's Deputy Prime Minister, ERNEST HILAIRE, who we have determined is the fourth richest Caribbean government official, in all the English-speaking former British Caribbean territories that are now independent states. His incestuous relationship with former Bank of America banker-turned SKN CIU head, turned-Galaxy CEO, LES KHAN, is one of the principal reasons for his ultra-wealth status, which you will hearing much more about in future articles. Khan is  missing in action, as we have assembled all the facts.

Les Khan

DPM Hilaire, whose extraordinary amount of illicit wealth would frankly shock most readers, has managed to secrete much of his ill-gotten gains abroad, both via investments through shell companies, by using nominees and assignees, and in cold hard cash hoarded overseas. He has accumulated literally a King's Ransom in assets, for the proverbial rainy day when he hopes to quietly leave Saint Lucia forever, and live a life of utter luxury, at the cost of the constituents that he has misrepresented all these years.

So the question becomes this: will the long arm of law enforcement reach out and touch him, before he has the opportunity to spend all that dirty cash in the capitals of Europe, or will he cheat justice? Only certain government officials, who are outside of the Caribbean, know the answer to that question, and they, for the time being, are not talking. 

 

DOES FAILURE TO DISCLOSE THE CURRENT LEGAL PROBLEMS OF THE MIGRATION INVESTMENT INDUSTRY TO BUYERS CONSTITUTE FRAUD?

 

This morning I read a lengthy article by an individual who claims to hold a doctorate, and is in the migration investment industry in Dubai, concerning all the advantages of acquiring a Saint Kitts Citizenship by Investment (CB) passport. The article touted the future construction of a massive performing arts center in Basseterre, touted as being only a small part of the benefits of purchasing an SKN passport. What the article did NOT say is that anyone traveling around Saint Kitts would see unfinished and abandoned construction sites everywhere, all testaments to the systemic problems that the CBI program has, with no solution in sight. Is the failure of the CBI vendors to disclose all the major problems with the Saint Kitts program fraud? Let's discuss.

None of the companies currently selling Saint Kitts or Saint Lucia CBI or CIP are telling prospective purchasers that there is a huge $150m RICO suit filed in the United States, alleging massive fraud, money laundering and corruption. Some of the same companies selling those passports are actually guilty of selling illegally-discounted citizenships, which is a felony under the laws of the jurisdictions that offer them. Does this abject failure to make such required disclosures amount to fraud in the inducement?

Add to this all the other negative aspects of holding a CBI passport: that it can be revoked without any Due Process; that it exposes the holder to being targeted by Western law enforcement agencies simply by virtue of having a passport used by transnational criminals, spies, tax cheats, sanctions evaders, and all the Usual Suspects, and you wonder whether how any court of competent jurisdiction could do anything other than rule against CBI vendors, in a civil, or even criminal, court of law? 

Let's also remember that these Caribbean countries have a long and sordid history of being tax havens, popular destinations for dirty money seeking to escape law enforcement seizure and forfeiture, and were formerly designated as Non-Cooperative Countries and Territories (NCCT) by the Financial Action Task Force (FATF). Do we simply forget that they were global pariahs in the past? That history should be disclosed, in an overabundance of caution, by any seller of a product coming from that region.

Don't be surprised if unhappy CBI purchasers seeking relief through the courts when their precious passports are summarily revoked, or if  they run into serious legal problems, simply because of the passport they present to customs & immigration upon arrival one day.

 

DEA ARROGANCE JUST COST AMERICA ONE OF ITS MOST VALUABLE TOOLS IN THE FIGHT AGAINST DOMESTIC MONEY LAUNDERING

The head of the Drug Enforcement Administration  (DEA) has just suspended the lion's share of its highly successful domestic airport Transportation (Bulk Cash) Interdiction program, after the Office of the Inspector General conducted an extensive investigation, and filed a scathing report. Entitled DOJ OIG Releases Management Alert identifying Concerns with the DEA's Transportation Interdiction Activities,  the report detailed a number of major issues the agency's operation of its program, right after which the program was immediately suspended.

The report, which found that the vast majority of the bulk cash seizures, which have amounted to billions of dollars, did not stop money laundering of the proceeds of crime, but resulted in the detention of legitimate cash in the possession of the civilian population, after which the tedious and time-consuming administrative and legal process they had to endure to recover their assets, did not serve either the public of the ends of justice. In truth and in fact, it was a distraction from the mission, which is to seize criminal proceeds.

The OIG found that:

(1) Individuals administering the program often totally and completely failed to properly document their seizures, a fatal flaw which hampered successful operations, even through this deficiency was previously pointed out to the DEA by OIG, which asserted that it wasn't being done. The truth was it was being ignored, and those leaders responsible for making that statement should be held accountable.

(2) DEA training for properly conducting the seizures, which was a requirement, has been suspended;  again OIG had been incorrectly assured that it was being done. In fact, it has been terminated in 2023.

Forget about the Constitutional issues with the public, consider the impact of the new policy, which requires that there be an active investigation in progress, before an interdiction can be conducted. The vast majority of seizures occur outside an active investigation; this means the program is essentially dead on arrival.

Allow me to explain why money launderers, drug traffickers and all the other categories of criminals engage in domestic bulk cash smuggling, which is not illegal under US law. Money launderers often move bulk cash, which constitute the proceeds of crime, to locations in the Continental United States where they can more easily place it into the American financial structure, for one reason or another. In  some cases, they have co-conspirators who have a specific method of Placement of cash in banks or NBFIs; in others, they take advantage of legal loopholes or weaknesses in the financial system. They depend upon a specific place to dump  that cash, and therefore they must transport it, generally using aviation, although they can use surface transportation, which is often considered too slow to be efficient.

The DEA has now lost that valuable tool, where using profiling, it interdicts bulk cash en route, which takes a bite out of crime, and hurts the war on money laundering. Someone in the DEA leadership allowed this, and there should be accountability for that intentional act.   

CLASS ACTION FILED AGAINST FOUR OF TD BANK'S MOST SENIOR EXECUTIVES FOR DECEIVING THE PUBLIC ABOUT THE BANK'S RAMPANT AND SYSTEMIC MONEY LAUNDERING PROBLEMS

Lost in the extensive media coverage of the $3.09bn penalty contained in the Plea Agreement against TORONTO DOMINION BANK, better known as TD BANK, is the fact that a massive Class Action suit has been filed, in US District Court for the Southern District of New York, against the four most senior officers in the bank, alleging that they deceived the investing public, regarding the size of the money laundering problems that the bank had, how it could be remedied, and how much the penalty would ultimately cost. The damning thing is that these defendants actually made this material misrepresentations of fact, on the record, in telephone conference calls to investors and shareholders of the bank, many of which are actually quoted verbatim in the 35 page Complaint for Violations of the Federal Securities Laws. Their omissions of material facts, spinning of the truth, and outright lies are shocking to most legal observers who have reviewed the transcripts. 

Named as defendants:

(1) BHARAT B. MASRANI, Group President, CEO and Director.

(2) LEOVIGILDO SALOM, Group Head of US Retail, and CEO of TD Bank.

(3) KELVIN VI LUAN TRAN, Group Head, and CFO of TD Bank.

(4) RIAZ E. AHMED, Group Head of Wholesale Banking at TD.                                                                

The Complaint charges, at Count I, violations of §10(b) of the Securities Act, and Rule 10b-5 and at Count II, violations of §20(a) of the 1934 Exchange Act.  Soke of the Office of Comptroller of Currency (OCC) findings of fact were cited in the Complaint, and they are extraordinary:  

"The Comptroller finds, and the Bank neither admits nor denies, the following:

 (1) The Bank failed to develop and provide for the continued administration of a BSA/AML Program reasonably designed to assure and monitor compliance with the BSA and its implementing regulations, in violation of 12 C.F.R. § 21.21. Deficiencies in the Bank’s BSA/AML Program included deficiencies Case 1:24-cv-08032-AS Document 1 Filed 10/22/24 Page 21 of 35 22 related to: internal controls and risk management practices; risk assessments; customer due diligence; customer risk ratings; suspicious activity identification, evaluation, and reporting; governance; staffing; independent testing; and training, among others. 

(2) The Bank had significant, long-standing, systemic breakdowns in its transaction monitoring program.  

(3) Since at least 2020, the Bank processed hundreds of millions of dollars worth of transactions with clear indicia of highly suspicious activity, creating a potential for significant money laundering, terrorist financing, or other illicit financial transactions. The Bank repeatedly failed to take appropriate and timely corrective action to address the highly suspicious activity and failed to properly emphasize BSA/AML compliance. 

(4) The Bank had a systemic breakdown in its policies, procedures, and processes to identify and report suspicious activity, and a pattern or practice of noncompliance with the SAR filing requirement, resulting in numerous violations of 12 C.F.R. § 21.11 (suspicious activity report violations). 

(5) The Bank violated 31 C.F.R. § 1010.312 (currency transaction report violations) on numerous occasions.

 (6) The Bank failed to implement appropriate risk-based procedures for conducting ongoing customer due diligence in violation of 31 C.F.R. § 1020.210(a)(2)(v).

 (7) The Bank recklessly engaged in unsafe or unsound practices related to the Bank’s BSA/AML Program.

 (8) The Bank’s violations and recklessly unsafe or unsound practices were part of a pattern, and caused and are likely to cause more than a minimal loss to the Bank."

Plaintiffs' counsel is the New York office of the law firm of BLEICHMAR FONTI & AULD LLP, which specialises in securities litigation. We will be closely monitoring this case, as well as checking to see whether any bank officers are individually charged with criminal activity, after a very senior Department of Justice official stated that corrupt bank employees facilitated a criminal network's laundering of tens of millions of dollars.

NEW U.S. LEGISLATION THAT WILL AFFECT HOW COMPLIANCE WILL TREAT NONPROFITS AND NGOS PASSED BY HOUSE OF REPRESENTATIVES

 

A bill working its way through the US Congress, H.R. 9495, designated the Stop Terror-Financing and Tax Penalties on American Hostages Act, has passed the House of Representatives, and after its anticipated passage by the United States Senate, will most likely become law. It gives the Secretary of the Treasury the ability to designate any non-profit a "Terrorist Supporting Organization," and strip it of its §501 tax-exempt status, under the Internal Revenue Code.

While the new law creates an additional, and sorely needed, tool in the war against terrorist financing, it by definition raises the bar for compliance officers on non-profits and non-governmental organizations that are tax-exempt under the I.R.C., because such a designation, and labeling, by the Secretary may be the first step to sanctions. it also may create a presumption of terrorist financing that could necessitate the immediate closure of accounts by compliance. Regulators may later ask why such accounts were allowed to continue to remain open after such a designation. Law enforcement agencies and the Department of Justice may also question such actions by a bank, and they may be hold by a court of competent jurisdiction to constitute a failure of effective AML/CFT compliance.

Whether this new law, after its passage, will require compliance officers at financial institutions, as well as NBFIs, to monitor all Treasury Terrorist Supporting Organization designations, to insure that their bank clients have not been added to that list, is a real concern. Will the names be added to databases of high-risk individuals and entities, making that information readily available, or must compliance officers themselves make that determination? We cannot say, but how these issues develop will most certainly be a topic of conversation among compliance officers, as well as their legal advisors, in the near future.

SAINT KITTS CBI FRAUDSTER DAREN LI USED A U.S BANK UNDER CEASE AND DESIST FOR AML DEFICIENCIES

When the Chinese national DAREN LI was defrauding Americans out of millions of dollars, and laundering the proceeds of his organization's crimes through financial institutions from his base in Los Angeles, we was using his trusty Saint Kitts & Nevis Citizenship by Investment (CBI/CIP) passport as identification. The United States Attorney's Office in the Central District actually attached the SKN passport to the indictment, after first having redacted sufficient personal information from the document so as not to run afoul of Federal guidelines about disclosure of such details.

We know from the indictment that Li did, in truth and in fact, present what should have been a huge Red Flag, the SKN passport, to New Accounts staff at DELTEC BANK in the Bahamas, which tells you something about the effectiveness of that bank's compliance department. US law enforcement was able to seize a substantial amount of the criminal proceeds at Deltec, as we have previously reported in prior articles.

Now on to EVOLVE BANK AND TRUST, the other bank involved, and which is located in West Memphis, Arkansas. Look at the FRB Press Release, detailing the Cease & Desist Order for AML deficiencies, that bank management, and legal counsel, signed, earlier this year. Obviously, US regulators know that the bank had serious BSA problems for years, yet allowed it to operate without any enforcement action. the result was that a successful Chinese crew, supervised by Daren Li, was able to successfully clean their criminal proceeds. Did the compliance department at Evolve Bank accept the SKN passport? That important fact is curiously missing from the Li Indictment, and we certainly would like to know if an American compliance department accepted it as proof of identity, given the huge amount of information available, regarding how Kittitian passports are a favorite tool of Chinese white collar criminals. That is, if true, compliance malpractice; We trust that the terms of the C & D will be strictly enforced. 

LET'S NOT FORGET THE ILLEGAL CARIBBEAN INDUSTRY OF SELLING DIPLOMATIC PASSPORTS TO MONEY LAUNDERERS AND OTHER FINANCIAL CRIMINALS

I have long covered the dark Caribbean practice of the region's corrupt leaders selling, for cash (in US Dollars, of course) diplomatic passports, which bad actors use to evade customs inspectors at international airports of entry, but new readers of my financial crime blog may be unfamiliar with this fraud. Perhaps the most egregious example of this method through which senior Caribbean officials, at the highest level was the personal hand delivery, in the UK, by Dominica Prime Minister ROOSEVELT SKERRIT, a diplomatic passport to the corrupt fugitive former Minister of OIL of Nigeria, DIEZANI ALISON- MADUEKE, who then attempted to use the bogus document to evade arrest and detention in the UK for millions she had stolen from the people of Nigeria while in office. And what about the Saint Kitts "Diplomat" who attempted to get a meeting with the Prime Minister of Canada, after buying his diplomatic status for cash, and was summarily rebuffed.

It is an open secret in the East Caribbean among bankers and attorneys that criminals buying Citizenship by Investment (CBI/CIP) passports in the five EC states that sell CBI can easily become "diplomats" if they have enough greenbacks to pass under the table to corrupt officials. Of course, none of these diplomatic passports automatically qualify the holder to be a bona fide diplomat, and none of them fulfill the requirements of the United Nations-approved VIENNA CONVENTION ON DIPLOMATIC RELATIONS, but in the developing world, customs officers are often intimidated into accepting them at face value, and pass the holder through, without checking their bags & baggage, thereby unwittingly facilitating Bulk Cash Smuggling, and the smuggling of financial instruments in aid of money laundering operations, as well as organized international fraud. They may actually pose as working diplomats, but rest assured their true activities are on the wrong side of the law, not in service to their adopted countries.

Readers are invited to search my blog(https://rijock.blogspot.com) where they will find that the corrupt East Caribbean government officials whom we have exposed in the illegal sale of discounted CBI passports to Chinese purchasers intent upon committing crimes and engaging in espionage, have also a long and dirty history of selling their criminal clientele diplomatic identity documents, to further facilitate their activities. Those two countries are "full-service" facilitators of transnational crime, in all its dark variations. You may never look at a diplomat looking to open a bank account again.

THE FINCEN ADVISORY WARNING ABOUT THE USE OF ST. KITTS PASSPORTS TO COMMIT FINANCIAL CRIME REMAINS IN EFFECT

A check of the records of the Financial Crime Enforcement Network (FinCEN) indicates that the agency never revoked or cancelled its 2014 Advisory entitled Passports Obtained through St. Kitts and Nevis Citizenship-by-Investment Program Used to Facilitate Financial Crime,  which we have shown here for those who were engaged in the AML/CFT compliance field in 2014, or who never were aware of its existence. Therefore, it must be considered to still be binding on covered financial entities for AML purposes. 

The Advisory should be read in the context of the current situation, where evidence indicates that thousands of SKN CBI passports have been issued with zero due diligence, to mainly Chinese nationals, who are prohibited by the laws of the Peoples' Republic to hold dual citizenship, under contracts determined to be illegal under Kittitian law, many of whom are now being charged with financial crime, industrial espionage,  FARA violations and other offenses.  

 

THE CONTINUED PRESENCE OF AMERICAN CAREER CRIMINAL PAUL BILZARIAN SHOW US THAT, IN SAINT KITTS, CBI DUE DILIGENCE IS PURE FICTION

 

This is the dodgy American white collar criminal, PAUL BILZARIAN, who moved to Saint Kitts & Nevis after he was approved to purchase a Citizenship by Investment (CBI) passport. At the time he applied, Bilzarian had just served a four year Federal Prison sentence for Securities Fraud, and had an outstanding final judgment entered against him, which now exceeds one hundred and eighty million dollars, with interest. This confirms that the vaunted pre-approval due diligence process conducted by the country's CIU is a total fiction as a simple internet search would have turned up  not only his felony conviction and judgment, but shown his long history as a career criminal in the United States. This is positive proof that the country does not conduct an investigation into the suitability of its CBI applicants. By the way, the US Government has still been unable to collect on its judgment, as Bilzarian is hiding his significant liquid assets through multiple shell companies. 

The more recent announcement, by its Prime Minister TERRANCE DREW, that Saint Kitts now has an agency that is conducting continuing investigation of SKN passport holders, in order to insure that any who engage in criminal activity lose their passport privileges, is also completely bogus and without a basis in fact. In September, Bilzarian was charged in Los Angeles, in a multi-count Federal indictment, on securities fraud, wire fraud, and defrauding the United States, which carry potential sentences that would commit him to prison for the rest of his life. Still, Saint Kitts allow him to keep his prized passport, and remain in the country, thus evading arrest by US law enforcement, and the administration of justice.

This is a clear demonstration that not only is there zero due diligence on CBI applicants, the purported "continuing due diligence' capability that PM Drew promised simply does not exist. How many Paul Bilzarians are hiding in Saint Kitt & Nevis from the long arm of law enforcement in their home countries? We suspect that the number will surprise you. The bottom line for compliance officers is, when presented with a Saint Kitts CBI passport as identification at account opening, to initiate an enhanced due diligence investigation, before approving any movement of funds. To do otherwise might allow yet another career criminal, like Bilzarian, into your bank, with an unacceptable level of risk. watch yourself with SKN passports, please; they are not to be trusted.

DWYER ASTAPHAN OF SAINT KITTS CALLS FOR THE IMMEDIATE RESIGNATION OF THE COUNTRY'S ATTORNEY GENERAL, GARTH WILKIN

Attorney General Garth Wilkin

Dwyer Astaphan, a former senior minister in the Government of Saint Kitts & Nevis, and one of his country's most respected and influential leaders, has called publicly for the immediate resignation of Saint Kitts' Attorney General, GARTH WILKIN, for his gross negligence in allowing two successive governments, and their respective prime ministers, to process thousands of illegally-discounted citizenships for the Chinese company CARIBBEAN GALAXY. Mr. Astaphan warned Saint Kitts that the country was in grave danger of falling under the undue influence of China, and that unless immediate remedial action was taken, the damage to St. Kitts & Nevis could become irreversible.

Mr. Astaphan made these statements during a podcast today, in response to the recent program of Philippe Martinez, which detailed the sordid history of AG Wilkin's complete and total dereliction of duty as his country's chief law enforcement officer, and he called upon the people of Saint Kitts to clean house, regarding the public officials who have been responsible for the current situation, with Mr. Wilkin being the individual who must tender his resignation forthwith.

OUR MOST NOTORIOUS FUGITIVE INTERNET FRAUDSTER, KRISTI ROSS, HIDES FROM THE LONG ARM OF AMERICAN JUSTICE IN NEVIS

KRISTY MARIE ROSS a/k/a KRISTI ROSS, called the Queen of Scareware, who controlled a rogue Belize-based Internet software company that defrauded a million American consumers out of  $163 million, who paid her to fix nonexistent and fabricated problems on their computers, has been evading the long arm of American justice, and  failing to make restitution by paying an outstanding Federal judgment in that amount, by hiding from the authorities in the Caribbean island of Nevis, part of the Federation of Saint Kitts & Nevis, for more than a decade. We are unable to confirm that she holds  CBI citizenship with a SKN passport, but believe that she does. 

The FTC Act monetary judgment against her, which was affirmed in appeal by the 4th Circuit, has never been paid, even in part, because Ross, who has been reviled in the Internet software industry for more than a decade, evaded justice by skipping out to Nevis, where she keeps close company with a cast of dodgy offshore characters who use the island's abusive tax haven laws to operate a bank which has reportedly been closely linked to the Chinese-owned CARIBBEAN GALAXY GROUP.

Ross's associates in Nevis include China-born bank investor BENJAMIN WEY,  and a local banker,  HOWARD A. LEWIS. Both are affiliated with HAMILTON RESERVE BANK, headquartered in Nevis, which should not  be confused with other similarly named financial institutions in the United States. The Nevis-based Hamilton Bank has no offices in America; its only other offices are in Kuala Lumpur and Dubai.

The five CBI-issuing states of the East Caribbean, which includes Saint Kitts & Nevis, rarely if ever permit extradition of those individuals who have purchased CBI/CIP passports, so we must assume that ant efforts to return Kristi Ross to the United States, to face any pending criminal charges, have been unsuccessful, but justice demands that she make restitution to American consumers for her fraudulent acts. Unfortunately, we cannot rely upon government officials in Nevis, who have allowed and permitted her to remain there on an indefinite basis,  to obtain justice for the victims.  Ask Nevis Premier MARK BRANTLEY why she is allowed to live there, given the circumstances of her massive consumer fraud.

THE CARIBBEAN'S DARK SECRET AND THE LAW OF UNINTENDED CONSEQUENCES RUNNING HEADLONG INTO FCPA VIOLATIONS

Last night's outstanding Caribbean Corruption podcast by MSR Media's PHILIPPE MARTINEZ* touched on one of the topics that is only spoken of in hushed tones in East Caribbean government circles; the fact that many corrupt individuals, and those engaged in white collar crime, both in and out of public office, want that elusive right to later reside in the United States, so that they can safely invest & spend the proceeds of their crimes in America, long after they bid goodbye to their Caribbean life. Many corrupt Politically Exposed Persons (PEPs) hold US citizenships; several sitting Prime Ministers have arranged for their children and immediate relatives to be born in the US, which confers automatic American citizenship, and immediate family of US citizens have an easier time themselves becoming citizens, through them. It's all part of a long-term plan to spend their golden years in luxury in a country where they can best enjoy their illicit wealth.

The Foreign Corrupt Practices Act, which proscribes the payment of any type to a foreign official, to obtain, retain or secure any official act involving a government-private business relationship, applies to United States citizens, and has a maximum penalty of 5 years in a Federal Prison, plus a hefty six figure fine. All these fine Caribbean criminals and corrupt former government officers, who had the foresight to obtain US citizenship for what they anticipate will be their affluent, remote future, could end up with FCPA indictments, when it is disclosed that they paid bribes, kickbacks or some other form of direct or indirect compensation, to foreign government officials. What an unpleasant surprise! The Law of Unintended Consequences is alive and well in the corrupt Caribbean, and it can bite individuals who never considered that the prized American citizenship that they obtained might just be the thing that brings them down. 

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*https://www.youtube.com/watch?v=-jB2Z9NW9aA

    

WATCH PIERRE MARTINEZ PODCAST EXPOSE CHINA'S ROLE IN CARIBBEAN CBI CORRUPTION (60 Minutes)

If you have been following our articles about the fraud, money laundering and corruption orchestrated in the Caribbean by China, using Saint Kitts and Saint Lucia Citizenship by Investment (CBI/CIP) passport programs, you will want to watch Pierre Martinez detail how China has used corruption to become a national security threat to the United States.

Watch the podcast here (prerecorded):

https://www.youtube.com/watch?v=-jB2Z9NW9aA

SAINT KITTS CANCELS CONVICTED CHINESE FRAUDSTER DAREN LI'S CBI PASSPORT, BUT THEY LEAVE HIS CITIZENSHIP INTACT; DID GALAXY ORDER THIS?

Media is reporting that the Saint Kitts Citizenship by Investment (CBI) passport-wielding fraudster, DAREN LI, who recently entered a guilty plea in US District Court for the Central District of California, which is Los Angeles, has had his SKN passport cancelled, due to his new convicted felon status.

While we understand that action by the Government of Saint Kitts, and agree that it was the proper thing to do, we note that Li's citizenship, through which he acquired the rights to a passport, was NOT revoked. In a future Saint Kitts government, he therefore has the right to reapply, and receive a new travel document. Did this happen on the orders of CARIBBEAN GALAXY GROUP, whom we understand was the agent for the citizenship application? I think we have our answer.

This demonstrates that the Government of Saint Kitts is firmly under the control of Galaxy, which means the Peoples' Republic of China now rules St. Kitts & Nevis. This confirms that the Caribbean Sea is now well on its way to becoming a Chinese lake. Will the next American Secretary of State please take note.

HERE'S DEPUTY PM ERNEST HILAIRE'S SIGNATURE ON AN ILLEGAL CARIBBEAN GALAXY CIP CONTRACT; HE CANNOT DENY THE EVIDENCE

The people of Saint Lucia have been demanding full disclosure for months from their Deputy Prime Minister, ERNEST HILAIRE, (who is also the Minister for Investment) regarding the facts in the sale of thousands of illegally-discounted Citizenship by Investment (CIP) passports by the Chinese-owned company  CARIBBEAN GALAXY GROUP, only to be told by him either he didn't have the information, or that he was unable to release it, in a public project, due to Galaxy's lack of consent of privileged business information, neither of which was true. DEPUTY PRIME MINISTER OF ST. LUCIA REFUSES TO ANSWER HOW MANY CBI PASSPORTS WERE GIVEN TO CARIBBEAN GALAXY. Anger at Hilaire, and indeed the Saint Lucia government itself, has reached a critical level, as St. Lucians fear the loss of their essential correspondent accounts in American banks, due to the exposure of fraud, money laundering and corruption, to a degree that it now threatens the economic life of the country.

The actual Agreements (Contracts), by and between Galaxy and Hilaire, have been made available to the public by IMPACT WORLD MEDIA, and we are displaying some of the relevant portions here, to demonstrate that the Deputy Prime Minister was the principal St. Lucia government official involved, he actually signed the Agreements, which provide for a a major, and illegal, discount in the prices charged by Galaxy, as well as Saint Lucia, for citizenship & passport sales. Impact's evidence confirms that Hilaire gave Galaxy 11,000 files; that's 45.000 new citizens from China and the Middle East now in Saint Lucia, resulting in revenue diverted by Galaxy of USD$1.6 Billion. All this money never made it into Saint Lucia government treasury accounts. That is fraud on a massive scale, and the people of Saint Lucia demand that their money be returned to them.

 

 This public showing of the evidence establishes, beyond a reasonable doubt, the existence of a criminal conspiracy orchestrated and led by Saint Lucia Deputy Prime Minister Ernest Hilaire. The contracts confirm Misfeasance and Malfeasance in Office, which are grounds for his immediate removal from all positions and portfolios that he holds in government. If the Prime Minister, PHILIP PIERRE, declines to take such action forthwith, he should also be considered to have failed to discharge his sworn duties to his nations, and also be subject to removal by the courts.