ISRAEL SANCTIONS CROWDFUNDING PROGRAM FOR HEZBOLLAH TERRORISTS INJURED IN PAGER OPERATION

Israel's Defense Minister, Israel Katz, has announced that he has imposed economic sanctions upon all crowdfunding and fundraising activities that are currently active, designed to send money to the Hezbollah terrorists who were injured or maimed in Lebanon by the exploding pagers and walkie-talkies on 17-18 September, which were detonated by Israeli intelligence. Many Hezbollah agents lost fingers and hands, and sustained injuries to their face and eyes, when Israel sent a specific text message, which was responded to by frontline Hezbollah terrorists. The sanctions were recommended by Israel's NATIONAL BUREAU FOR COUNTER TERROR FINANCING (NBCTF).

WHO LENT MILLIONS OF DOLLARS TO CUBA'S MILITARY TO BUILD TOURIST HOTELS? REPAYMENT OF THOSE LOANS EXPOSE AMERICAN BANKS TO MAJOR U.S. SANCTIONS

Recent investigative articles in the media, which expose the fact that, in a supposedly financially destitute Cuba, where life saving medication is not available, the damaged national electrical grid fails regularly, and essential consumer supplies are not imported, the country's military is sitting on a hoard of USD$4bn. A number of major corporate entities in Cuba, officially stated to be civilian, are in truth and in fact controlled by the country's military, which takes the hard currency, US Dollars, sent from abroad as remittances, and doles out Cuban Pesos to recipients.

Engaged in a major tourist hotel construction operation, and apparently not using its own money to finance construction, it is suspected that the military is receiving loans coming from abroad. Which European banks are involved? As Cuba remains a designated State Sponsor of Terrorism in the United States, and powerful sanctions have been in place for decades, repayment of those loans, in Dollars, must transit the American financial structure, which exposes those U.S. banks processing those transfers to major American sanctions. The front companies, claimed by Cuba to be under civilian control, but which are actually managed by the military, are somehow moving loan repayments right under the nose of American banks. What's wrong with this picture?

Compliance officers at U.S. financial institutions may want to look for any transactions where any of these Cuban entities appear, even as only references. Many of them are under American sanctions:

(1) GAESA- Grupo de Administración Empresarial S.A.
(2) GAVIOTA
(3) ALMEST
(4) CIMEX
(5) HABAGUANEX
(6) ETECSA
(7) GRUPO PALCO
(8) ALMACENES UNIVERSAL

(9) FINCIMEX

(10) ORBIT

SANCTIONED SYRIAN OFFICIALS AND SENIOR MILITARY, INCLUDING RIFAAT AL-ASSAD, FLEW TO DUBAI VIA BEIRUT AIRPORT

Rifaat Al-Assad

Compliance officers at EU banks with clients having close relationships with the UAE please note that there are reports that a number of senior officials from the deposed Assad regime in Syria have evaded capture by entering Lebanon, and subsequently flying to Dubai from Hariri Beirut International Airport. Included in conflicting reports is the news that Assad's uncle RIFAAT AL-ASSAD, a sanctioned war criminal, was one of those who manages to escape to the UAE. Other Assad relatives are also believed to have fled Syria through Lebanon. Other officials were allegedly detained at the frontier, and returned to Syria by Lebanese Armed Forces, but this information has not been confirmed. Senior Syrian intelligence officers also are said to have escaped into Lebanon.

Considering the vast amount of wealth that the Assad family accumulated, including profits from narcotics trafficking, one must expect that they intend to transfer some of those illicit funds into EU banks, and therefore a heightened level of due diligence should be observed in early 2025, on any new and significant transfers from the UAE. Any new affluent clients appearing in major European banks, speaking Syrian Arabic, especially the Damascus dialect, should be subject to enhanced due diligence.

IRS OBTAINS COURT ORDER AUTHORIZING 'JOHN DOE" SUMMONSES FOR RECORDS RELATING TO U.S. TAXPAYERS WHO MAY HAVE USED NETWORK OF OFFSHORE SERVICE PROVIDERS TO HIDE ASSETS AND EVADE TAXES

Compliance officers: read this portion of the Press Release issued on December 23, 2024, by the US Attorney's office in the Southern District of New York:

:

RAMPANT CORRUPTION REPORTED AT LOWES INC

CULTURAL LITERACY AND MONEY LAUNDERERS

Further to my prior articles, THE IMPORTANCE OF CULTURAL LITERACY IN AML/CFT COMPLIANCE (December 11, 2024)* and TO BE EFFECTIVE, A COMPLIANCE OFFICER MUST POSSESS CULTURAL LITERACY; THIS REQUIRES AN UNDERGRADUATE LIBERAL ARTS EDUCATION **                ( November 7, 2023), It is important for compliance officers to understand that successful money launderers also possess Cultural Literacy.

While I was what you call an Accidental Money Launderer, having fallen into that dark art to assist some fellow Vietnam Veterans smuggling marijuana, and then becoming a "full-service" landryman for cocaine traffickers, I had come into the job with the necessary skill set, acquired from education, training, experience. I had acquired knowledge of political geography from a number of hobbies during my youth, understood asymmetric and covert conduct from my Vietnam tour, and had not only a liberal arts & a legal education but hands-on experience at an international law firm, where I was working in the banking division. In short, I had all the cultural, academic and vocational background one needs to be considered culturally literate for money laundering operations, where one applies all that knowledge to clean dirty money right in front of compliance, using techniques that are rarely recognized or understood by individuals not blessed with compliance cultural literacy.

While I cannot expect all compliance officers to have such an extensive preparatory background, If you want to catch laundrymen in the act, you must at least have a firm background in advanced Tradecraft, those effective techniques and methods of money laundering that you cannot find in a manual or a seminar. I invite you to attend my three-part January presentation on esoteric, obscure and exotic techniques; it will open your eyes to money laundering on a different level.

For further information: https://titc.io/kenneth-rijock-the-laundry-man

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*https://rijock.blogspot.com/2024/12/the-importance-of-cultural-literacy-in.html

**https://rijock.blogspot.com/2023/11/to-be-effective-compliance-officer-must.html

CHINA'S NEW 2025 AML LAW REVISION GRANTS EXTRATERRITORIAL JURISDICTION; WILL IT BE USED FOR POLITICAL PURPOSES, TO THREATEN WESTERN BANKS?

If you follow new developments in global AML/CFT legislation, you should know that China in November passed a major revision to its "Anti-Money Laundering Law of the People's Republic of China," which takes effect on 1 January, 2025. Hidden in the additional tools available to the PRC is the establishment of Extraterritorial Jurisdiction of its AML laws. This means that, under certain certain circumstances, financial institutions in the West could end up being charged with violation of the PRC's powerful new legislation; Just imagine the effect on their China business.

Unfortunately, the restrictions on use of this expanded jurisdiction are broad enough for Chinese prosecutors to employ to just about any situation:
(1) Threatens China's sovereignty and security.
(2) Infringes on the legitimate rights and interests of Chinese citizens, legal entities and other organisations.
(3) Disrupts financial order in the PRC.

The effect on Western, and specifically US, financial institutions, will be carefully watched, taken in the context of public exposure of the billion dollar fraud, money laundering and corruption scandal that broke in 2024, regarding the five East Caribbean Citizenship by Investment (CBI/CIP). Since this new and impending Chinese legal tool has been known to the Western compliance community for some time, we wonder aloud if it has caused any of the major American banks that provide correspondent banking services to the CBI agencies to refrain from taking any action to close those accounts, due to a well-placed fear that China could respond by charging such a bank with money laundering, purely for political purposes. The half dozen US banks in the correspondent banking category all are engaged in international trade transactions with China.

Such an action would most likely have a serious economic effect on that bank's lucrative China business, and affect its ability to serve its international manufacturing clients. Is this why no major US bank has ignored the CBI scandal, possible loss of major business? This form of economic blackmail, bordering on extortion, may be the reason American banks are asleep on the CBI money laundering issue.

BANK OF AMERICA, SARS, THE CITIZENSHIP BY INVESTMENT SCANDAL, CARIBBEAN GALAXY/CHINA AND JEFFREY EPSTEIN

A memorandum prepared for the United States Senate, regarding the unusually late filing of Suspicious Activity Reports, or SARs, by BANK OF AMERICA, which were reportedly filed years after $140m of suspicious payments to JEFFREY EPSTEIN, has recommended that the matter be turned over to the Financial Crimes Enforcement Network (FinCEN), to investigate the bank's conduct. Apparently, the bank failed to file the SARs until six months after his indictment and suicide in Federal Prison, and after a civil RICO lawsuit against Epstein's estate was filed. Who made that command decision, we wonder, Compliance or the executives in charge of the accounts?

If there is a corporate culture at any bank, to delay filing of a SAR for a valued or lucrative client until possible misconduct is publicly exposed, then questions should be raised, regarding the effectiveness of the bank's risk-based compliance program. Were critical compliance decisions being trumped by account executives responsible for for the client, due solely to revenue considerations?

We bring this up because, with the huge amount of publicity over the unfolding fraud, money laundering and corruption scandal over Caribbean Citizenship, the bank continues to maintain correspondent accounts for indigenous East Caribbean financial institutions that service CBI/CIP programs. While the law prohibits us from accessing any information about Sars filed, regarding those accounts, especially whether the reporting of information deemed suspicious is inordinately delayed, if such conduct has occurred regarding CBI accounts, resulting in belated notification to regulators and law enforcement agencies, it should be investigated as a National Security matter, due to China's known involvement. We urge the U.S. Senate to note our concerns.

AMERICA'S CRIMINAL INVESTIGATION INTO MONEY LAUNDERING AND CORRUPTION IN SAINT LUCIA HAS ITS FIRST COOPERATING INDIVIDUAL

It appears that the recent celebration, among government officials implicated in the billion dollar fraud, money laundering and corruption investigation of Saint Lucia's Citizenship by Investment (CIP) passport sales program, after Philippe Martinez dismissed his RICO case, will be short-lived. According to our most reliable source on the investigation, assigned to a major American law enforcement agency, one of the principal government officials in that East Caribbean state has agreed to become a Cooperating Individual (CI) and testify against his associates We understand that he will receive Immunity from Prosecution, meaning that he will not be charged with any of the crimes he committed, regarding his role in the CIP program.

We do not have his identity, and even if we did, to disclose it would put his life in serious danger, as contract murders are known to happen in Saint Lucia, which is presently suffering a major crime wave, with a large increase in homicides, few of which seem to be solved by the authorities. He is slated to testify against others presently sitting in positions in government, after which he will reportedly be placed in America's WitSec, or Witness Protection, program, with a new identity, somewhere in the United States.

We can only venture an educated guess as to his identity, and that would not serve justice, so we will let the matter play out and wait for an indictment. Inasmuch as Federal criminal investigations often take a substantial period of time to conclude, there is no time frame for that to occur, but we will be watching; stay tuned.

REMINDER; ALEX SAAB MORAN IS STILL AN OFAC-SANCTIONED SDN

I am seeing multiple queries about ALEX NAIN SAAB MORAN, the indicted Colombian money launderer exchanged for individuals kidnapped by the Maduro government of Venezuela. Yes, he is STILL a sanctioned target; if for some reason, you see his name coming up in any manner in a financial context, remember well the rules regarding the OFFICE OF FOREIGN ASSETS CONTROL (OFAC) and govern yourself accordingly. Note the date on the OFAC search result; The Clemency granted him does not wipe out OFAC.

MONEY LAUNDERERS AND RED COLLAR CRIME

I was leaving the stage after speaking at an anti-money laundering event, about my decade as a career money launderer, and how laundrymen create new techniques, when I was approached by someone that was most likely a DEA agent attending the event. He asked me whether I knew a certain now deceased Miami lawyer known for having had a large clientele, consisting of Latin American businessmen. Coincidentally, we had both worked at an international law firm in the 1970s, when he chose to go out on his own, as often occurs with young ambitious lawyers in a big city.

He had been found floating face down in Biscayne Bay, and most of us assumed it was suicide, due to the stresses of dealing with difficult, affluent clients, compounded by marital troubles. Apparently, the agent said, that was definitely not the case, as he had  been killed by a client, most likely to cover up any possible future damaging testimony against him, as he felt threatened the lawyer might choose to cooperate, concerning his money laundering activities.

We call this Red Collar Crime, when a violent act is committed to cover up a white collar crime. It happens more often than you think to money launderers whose clients feel threatened that the lawyer-laundryman may choose to avoid prison by rolling over on his criminal client, and render what we call Substantial Assistance. When I was once subpoenaed to appear before a Grand Jury in Florida, I had a lunchtime visit where I was asked about what my testimony might be. Readers know I chose to not testify, which led to my evential indictment for RICO, but I am the exception. Most lawyers don't have the stomach for incarceration, and they are the weak link in any criminal organization.

It might surprise you to know that this conversation with a law enforcement agent, advising me that a lawyer had been killed to cover up his money laundering past has occurred a number of times over the years. Lawyers who launder money for narcotics traffickers are often targeted by paranoid, or simply careful, clients to keep them from revealing where all that client's laundered proceeds of crime are located. Most lawyers never consider that when they begin a life of crime; perhaps they should.

The lesson here for compliance officers is this: when your bank client who is a wealthy lawyer passes away, you might want to confirm the circumstances of his death, and while you are at it, check his accounts. Were there any suspicious transactions? Any indicators of activity inconsistent with normal business practices? What about trust account activities? You do not want a visit, two years down the road, from someone with a subpoena for his law firm records, because that may mean you failed to catch his money laundering for clients.

TODAY'S U.S. TREASURY NARCOTICS SANCTIONS

 

For details on all these individuals and entities:

https://home.treasury.gov/news/press-releases/jy2753                                            

SEALED INDICTMENTS FOR CORRUPT CARIBBEAN OFFICIALS? INDICATIONS FROM THE ANDREW FAHIE FILE PROVIDE US WITH CLUES

Andrew Fahie in custody.

Reporting on financial crime, in depth, with analysis, requires not just a legal education, but experience. There are often ongoing activities that prosecutors wish to keep out of the public eye, but deem necessary in the exercise of their function, which is to charge and convict the guilty. There are Red Flags, which indicate that something is going in behind the scenes, that they would prefer remain nonpublic for the time being.

ANDREW FAHIE , the former Premier of the British Virgin Islands, who was convicted of money laundering and narcotics trafficking, with his two co-defendants, are all serving their sentences in Federal Prison, which should be the end of the case, but there's something more one can glean from the docket: Six of the recent docket entries are sealed documents; why, if everyone has been convicted, is this the case?

Second, Oleanvine Pickering-Maynard, Fahie's co-defendant, does not appear anywhere when you seek to learn her whereabouts in the Federal Prison System. Would she be in a country jail somewhere, or some other temporary facility, and for what reason? It is customary to be designated a location where one serves one's sentence after a conviction. Where is she now? She didn't testify against any threats to her safety which would require her placement in a secure, unknown corrections facility.

Third, we recall that she told undercover investigators that Fahie had prior experience in criminal activities in the BVI and the Caribbean ( a"little criminal"), and he himself said the case was not his "first rodeo." We all expected he would render Substantial Assistance to law enforcement before trial, to mitigate his ultimate sentence. He once admitted that he had first-hand information about others in the region who also engage in corrupt activity. has he changed his mind about cooperating, given his long sentence? Perhaps he has decided that he doesn't want to spend a decade behind bars.

Therefore, in my humble opinion, either there are sealed indictments against other corrupt government officials elsewhere in the East Caribbean, or the US Attorney is very close to securing them. Let the story play out, and we shall see if my deduction is correct.