ACCOUNTABILITY FOR CARIBBEAN CBI CORRUPTION; THE INEVITABILE OFAC SANCTIONS ARE COMING

As he stated in his most recent podcast, MSR Media's Philippe Martinez will be forwarding his list of fifty (50) individuals who evidence confirms are the primary bad actors responsible for fraud, money laundering and corruption, in the Caribbean Citizenship by Investment (CBI/CIP) scandal in Saint Kitts & Nevis and in Saint Lucia, in the coming week. Not only will the list, which reportedly includes a substantial number of senior government officials from those two East Caribbean states, but also others closely associated with them abroad, including in the United Arab Emirates, and China. Mr. Martinez asks that they be banned from ever entering the US again and be denied the use of the US dollar for any purpose, indefinitely. You can expect this to happen, swiftly and quietly, in 2025.

We note that the USDOJ is not the only U.S. Government agency slated to receive this information; the Financial Crimes Enforcement Network, or FinCEN, a division of the Department of Treasury, is also a named recipient. FinCEN's original Advisory on Saint Kitts CBI, which warned of the potential for the abuse of the program for money laundering and financial crime, although published a decade ago, remains relevant, and was curiously never retracted. What precisely FinCEN will do with the information it receives is not known, but historically it has turned to what is probably the most effective tool in its enforcement arsenal, a referral to the Office of Foreign Asset Control, or OFAC, another Treasury division, which can specially designate some or all of the named individuals, effectively blocking them from the American financial structure, directly or indirectly and banning all Americans and US-based companies from any transactional contact or financial relationship.

We welcome OFAC SDN designation on these individuals, and their controlled entities, government or private, as they have for far too long infected the American banks that maintain correspondent relationships with them, with rampant money laundering. While denying them entry into the United States will be personally painful for them, OFAC sanctions will impact their illicit financial assets on a global basis, interfere with their ongoing laundering operations, and prevent any US investments, while blocking those that now exist, and are located. We wish the fifty a miserable and financial disastrous New Year, which we believe is not only well deserved, but the precursor to U.S. Federal criminal charges to come.