UNMASKING AFRICA'S FINANCIAL UNDERWORLD

My concerns about the total absence of current information about the unique money laundering problems of the African continent were reinforced last year after I attended DECODING FINANCIAL CRIME, and fielded questions from attendees about the need for effective solutions to their financial crime issues. Therefore, I am presenting this two-part seminar in February, where I will analyze those region-specific AML/CFT problems, and offer my solutions, from my unique perspective as a former practising money launderer who used many of the techniques that presently plague African-based compliance officers, accountants, auditors and law enforcement agencies. Learn how to identify and interdict, in real-time, money laundering operations as they are currently being conducted against African banks and businesses.

If you are in United States, the seminars begin at 8:00AM EST on the dates listed below. I hope to see you there.

For further information:

https://titc.io/kenneth-rijock-webinar-africa-special

WILL THERE NOW BE ADDITIONAL INDICTMENTS IN THE BVI MONEY LAUNDERING CASE OF ANDREW FAHIE?

All three of the defendants in former British Virgin Islands Premier ANDREW FAHIE's money laundering and narcotics trafficking US Federal criminal case in South Florida have been convicted, sentenced and are currently serving their sentences; so why now are we seeing sealed filings in the docket in Fahie's case ? Obviously, there is further activity, regarding additional indictments. Remember that it has long been known that Fahie possessed first-hand knowledge of criminal activity of OTHER Caribbean government leaders, but that he stubbornly refused to cooperate with US law enforcement, insisting that he go to trial, but now that he is dealing with a long prison sentence, perhaps he has changed his tune.

After his initial arrest, there were rumors that he had boasted he had incriminating evidence against a certain senior government official in Antigua & Barbuda, and that he was going to cooperate; we waited for that to occur, but he held fast with demanding to go to trial. Was he threatened with retaliation? We cannot say, but these back-to-back sealed filings in his District Court case suggest he may have changed his tune; we note that his Release Date on the BOP website is July 4, 2033. We will continue to monitor his case. Is someone perhaps losing sleep over in Saint John's, the capital of Antigua, these days, we wonder?

WILL M23 REBEL FORCES THAT HAVE CAPTURED GOMA IN THE DRC RELEASE THREE CHINESE JUST SENTENCED THERE TO SEVEN YEARS FOR MONEY LAUNDERING?

Bin Laden and Mustafa Setmariam Nasar in Afghanistan

Sentenced to seven years in prison in Goma in the Democratic Republic of the Congo, for money laundering and other crimes and fined $600,000, three Chinese nationals that were arrested in possession of $400,000 and ten bars of gold, could be released, as M24 Rebels, supported by neighboring Rwanda, have captured the city in a fierce battle, as part of their campaign to control the mineral-rich Eastern Congo region. Rebel groups frequently open prisons, freeing all the inmates, believing them to be opposed to the sitting government. It is feared that this will be the case.

I recall when the start of the civil war in Syria resulted in the unanticipated release of MUSTAFA SETMARIAM NASAR, the leading theoretician of Al-Qaeda, and the brains behind the Madrid Train Bombing of 2004. Nasar, a close associate of Osama Bin Laden, (see attached photo) has been quietly placed there by the CIA for indefinite incarceration. His arrest in Venezuela, early on in the Global War on Terrorism, was not disclosed to the American public, who were unaware of the presence of senior terrorists in the Western Hemisphere that posed a clear and present danger to the United States. I was personally involved in the surveillance operation that resulted in Setmariam's capture, otherwise the story would never be told.

WHEN IS A NIGERIAN FRAUDSTER NOT A NIGERIAN? WHEN HE IS POSING AS A WEST INDIAN, WIELDING A PASSPORT FROM AN EAST CARIBBEAN CBI STATE, AND FURTHER EXPLOITING NORTH AMERICANS AND EUROPEANS WITH HIS BOGUS NATIONALITY

I am extremely disturbed by CHRISTIAN NESHEIM's comment on Linkedin, boasting that there are twenty-four companies in Nigeria selling Citizenship by Investment (CBI/CIP) passports to Nigerian nationals. Nigeria is the epicenter for African-based financial crime, which targets victims in North America and in Europe. Who else do you think has the US Dollars to pay a six figure fee for a CBI passport, Christian? Those citizenships are financially out of reach for most Nigerians. Believe me, the last thing the West needs is more Nigerian fraudsters, hiding behind a Caribbean passport to perpetrate their scams.

Nigerian nationals can travel visa-free to a very small number of countries, especially those in the developed world, in large part because of significant financial crime abroad being conducted by Nigerian nationals, a small portion of the population, but extremely active in romance fraud, pig butchering, investment fraud, sextortion and other types of white collar crime that exploits unsophisticated victims. EC CBI states that alter places of birth, names and birthdates on economic citizenships make the tasks of law enforcement in identifying the criminals much more difficult.

Given that Nigerians can freely travel visa-free, to the five East Caribbean CBI states that have passport sales programs, it is strongly suggested that those few wealthy, legitimate Nigerians in need of a second passport journey there in person, and that the obscene number of passport vendors and consultants be closed down by Nigerian law enforcement agencies as threats to National Security, and knowing facilitators of criminal activity. Nigeria's criminal elite should not have the ability to disguise themselves from being identified through dodgy economic citizenship passports.

CHINA'S HANG SENG BANK, IMPLICATED IN $ 2.5bn CARIBBEAN CBI PASSPORT SCANDAL, NOW FINED USD$8.7MILLION BY HONG KONG REGULATORS FOR CHURNING INVESTOR ACCOUNTS

The Hong Kong Securities & Futures Commission (SFC) has fined HANG SENG BANK USD$ 8.7m, for influencing bank clients into making "frequent and excessive transactions" in the purchase and sale of securities by the bank on their behalf, between 2014 and 2023. For those readers not familiar with securities laws, that is an illegal technique known as CHURNING, where the broker convinces the client to make multiple transactions, which may not benefit him, or be part of any rational investment objectives, but which generates lucrative commissions for the broker. It is, of course, also illegal in most jurisdictions, including the United States. As a young lawyer representing brokerage houses in Miami, I saw a number of Churning cases, where the stockbroker convinced the investor to engage in many transactions, where there was obviously no investment strategy, but were intended to line the pockets of the broker with commission payments; This is what Hang Seng is being fined millions for.

Hang Seng has been the subject of a number of articles on our financial crime blog recently; Let us draw your attention to IS HSBC-OWNED HANG SENG BANK LIABLE ...? https://rijock.blogspot.com/2024/08/philippe-martinez-is-officer-at-msr.html  The bank reportedly received repeated payments made by applicants for Citizenship by Investment (CBI/CIP) who paid illegally-discounted fees for passports, which it later funnelled to NATIONAL BANK OF ST. KITTS-NEVIS-ANGUILLA and BANK OF SAINT LUCIA, which has been alleged to constitute money laundering on a grand scale. 

See also: https://rijock.blogspot.com/2024/07/illegally-discounted-cbi-passports.html                                                                                                                                 

THE ONE THAT GOT AWAY

Henry Browne KC

A number of readers who read my recent article CONFESSIONS OF A MONEY LAUNDERER have requested further details on what happened when I moved millions of dollars of my clients' narco-profits into Saint Kitts. Back in the 1980s, when I was smuggling their criminal proceeds out of the Continental United States, and into the tax havens of the East Caribbean, I was using the services of the Kittitian attorney William (Billy) Herbert, Jr., then the Ambassador Plenipotentiary serving the newly independent state of Saint Kitts & Nevis, but working with me mainly from his chambers in nearby Anguilla; Only rarely did I work out of Saint Kitts.

There came a time when Billy Herbert became compromised by the DEA and SCOTLAND YARD, who threatened him with dire consequences if he failed to cooperate, resulting in law enforcement being given the names of all his American clients with dirty money in a local bank in which Dr. Herbert had an ownership interest. A magistrate judge ordered all those illicit funds frozen forthwith, and Attorney Herbert dashed off to a holiday abroad, while all his files were being opened and examined in his office. The clients had twelve million dollars at risk.

St. Christopher-Nevis-Anguilla flag

A few short weeks later, reportedly after the DEA failed to produce incriminating evidence as promised, the magistrate unfroze the money, and the bank's president called me in my Miami office, asking urgently for instructions. Following existing orders I had once received from Dr. Herbert, I ordered all the accounts there of American drug traffickers, including those whom I no longer represented, but who had substantial wealth there, to a Saint Kitts bank account of attorney HENRY BROWNE, who I knew had a relationship with Billy.

St. Kitts flag until September 1983

When I next visited Basseterre to make arrangement to transfer the funds, Browne demanded one-third from every account that I had transferred there, plus USD$5000 from each. There was, of course, no prior arrangement for that amount of "attorney's fees," but given that my clients could not go into court in Saint Kitts to contest fees over drug profits, I grudgingly allowed him to take what was what lawyers refer to as a clearly excessive fee. Of course, my clients were extremely unhappy, but knew there was nothing they could do about it, without needlessly incriminating themselves; Browne knew that.

William Valentine Herbert, Jr.

I was forced to initially transfer the money to Saint Kitts, due to Dr. Herbert's betrayal of the attorney-client privilege, and Browne took full advantage of my predicament. Billy never lived to spend the twenty five million dollars I believe he earned from working with drug traffickers and terrorist financiers; Henry Browne KC was never charged in any American drug trafficking cases, to the best of my knowledge. Whether he also cooperated with US and UK law enforcement back in the day I cannot say, but I did always wonder why he is the One that Got Away. 

PRESIDENT TRUMP'S DESIGNATION OF NARCOTICS TRAFFICKERS AS TERRORIST ORGANIZATIONS COULD AFFECT CORRUPT CARIBBEAN CITIZENSHIP BY INVESTMENT PROGRAMS AS WELL AS PASSPORT HOLDERS

Upon taking office, Donald Trump on January 20 issued an Executive Order designating Narcotics Cartels as terrorist organizations and SGDTs. While this Order is primarily intended to give American law enforcement additional tools with which to fight the Chinese-manufactured and Mexican-distributed drug Fentanyl, which has been deemed a National Security threat, within fourteen days from that Order, American agencies will be naming those other organizations that they consider direct or indirect threats.

I have been involved in the dark business of money laundering, on one side or the other, for more than half a century. I began as a young bank attorney, watching as America ignored rogue Caribbean tax havens launder the proceeds of Colombian drug crime with impunity. Next, I spent a decade as a career money launderer, concentrating my operations in those same offshore financial centers. Then, after serving time for RICO, I trained and advised a number of law enforcement agencies and the intelligence community in North America, assisting them in catching people like me. After 9/11, and to the present day, I have functioned as a Financial Crime Consultant, assisting the financial sector combat money laundering, which is a central tool of financial crime.

I was, fate will have it, present at the birth of the Citizenship by Investment (CBI/CIP) industry forty-two years ago, and not only am I aware of the intent of its creator that it was intended to assist narcotics traffickers evade detection, arrest and conviction, but that I participated in some of the initial sales of economic passports to prominent leaders of Colombian narcotics cartels. I also became aware that money launderers working for the cartels used CBI passports to travel unimpeded, clean the proceeds of crime, and facilitate the smuggling of illegal drugs into North America. Corrupt Caribbean leaders, intent on maximizing their profits and personal wealth, sold passports to anyone with US Dollars, including those working for the cartels. America, for one reason or another, ignored this illicit activity, and largely stayed out of the Caribbean, affording corrupt actors the opportunity to continue to support organized crime's laundering efforts.

Therefore, the question is when, not if, US law enforcement now will use the tools available in the law for Countering the Financing of Terrorism, against the five East Caribbean states with CBI programs, as well as by directly targeting those laundrymen holding economic passports, especially those Chinese nationals holding EC CBI passports, who use them to move and clean the proceeds of drug crime. It is high time to clean up that financial nightmare in America's backyard.

SYSTEMIC LAND FRAUD BY BARBADOS' AVARICIOUS ATTORNEYS CONTINUES UNCHECKED, BUT ONE VICTIM IS FIGHTING BACK

For years, we have detailed how the legal profession in Barbados, swollen with an excess of lawyers that far exceeds the amount of legal business available to support them, has exploited uneducated landowners by stealing their valuable oceanfront property during probate proceedings, or taking their sales proceeds after a closing occurs. The country's disciplinary procedures regarding lawyers is unable or unwilling to rein in the illegal practice, so land owned by a family for centuries is stolen, and sold to a European developer, as a bona fide purchaser having no notice of the fraud, and who believes good time was conveyed. Neither the Barbados government, nor the courts, have provided remedies for the many victims. Unscrupulous lawyers have become rich off their probate and real estate client's assets, and they end up in the Barbados government, so of course they will not assist in reform of the situation.

Now, however, we are seeing stirrings of action among the victims; JOHN WAYNE SCANTLEBURY, refusing to allow a developer of a residential housing project (FUSTIC GARDENS) to take advantage of his family's patrimony, has secured counsel, and sent the attached Cease & Desist notice to the Minister of Housing, the Prime Minister, Registrar of Titles, Minister of Finance, and several other government officials including the country's Supreme Court. (We note the receipt by the Registrar of Titles, which should serve to put any prospective purchasers on actual notice of defects in the real estate title.)

It is high time that the practice of unemployed lawyers in Barbados feeding off their clients' real estate holdings; these professionals should all be in prison for their sins and transgressions. We can only hope that the courts wake up and put them there. All the other victims should now follow Mr. Scantlebury's example and move against the dirty lawyers who stole their property or real estate sales proceeds.

AMERICA'S DESIGNATION OF MEXICAN DRUG CARTELS AS TERRORIST ORGANIZATIONS INCREASES THE RISK THAT COMPLIANCE OFFICERS COULD BE INDICTED FOR PROVIDING MATERIAL SUPPORT TO A TERRORIST ORGANIZATION

This week's action by the Trump Administration, in designating narcotics cartels as terrorist organizations, could have some serious unintended consequences for compliance officers at international banks which engage in significant business with Mexico and Mexican banks. The toolbox available to charge compliance officers that approve funds transfers of what is later determined to be the proceeds of drug crime back to the Mexican drug cartels is greatly expanded when the recipient is a Specially Designated Global Terrorist organization (SDGT). Inept, lazy or sloppy compliance officers may soon find themselves indicted, as part of a massive drug case, as unwitting or negligent players in a money laundering operation.

That sounds like America's new government, now unfortunately led by non-lawyers who haven't considered all the implications of their acts, has run headlong into the Law of Unintended Consequences. There may be victims who were simply ineffective compliance officers, caught up as a small cog in a large narcotics wheel now named as a terrorist operation. Perhaps this is a sign that compliance officers whose skill levels are below Banking Best Practices had better become more effective, or face the possibility that some zealous Assistant U.S. Attorney will drop them into a huge drug case, now listed as a counter-terrorist operation. Watch yourselves now, gentlemen.

THE USE OF CARIBBEAN CITIZENSHIP BY INVESTMENT PASSPORTS BY TERRORISTS AND TERRORIST FINANCIERS

We have been expanding our investigation involving the use of Citizenship by Investment (CBI/CIP) by financial criminals into their use in terrorist financing. Previously, we have noted the connection between the use of CBI passports from Malta by terrorist financiers employing Bitcoin to finance HAMAS before October 7, but we have now expanded our inquiry into the potential use of East Caribbean CBI passports, especially from Saint Lucia and Saint Kitts, which have the most corrupt CIUs, by terrorists and terrorist financiers.

We note with serious concern that BLUEMINA CITIZENSHIP AND RESIDENCY/IMMIGRATION, an Amman, Jordan-based CBI consultancy includes, among its offices abroad, a facility for the sale of CBI/CIP in RAMALLAH, in the Palestinian Territories. Bluemina, which reportedly has such a close relationship with Chinese-owned CARIBBEAN GALAXY GROUP, that it functions as a virtual subsidiary of that consultancy, now alleged to be part of a global sales campaign of illegally discounted CBI passports, is known to be funneling bribes and kickbacks to a number of East Caribbean officials, including but not limited to Saint Lucia Minister for Investment ERNEST HILAIRE, whose ties to Bluemina are well known in Saint Lucia, for reasons which will be explained here in a subsequent article.

St. Lucia Minister Ernest Hilaire

Given the multiple spelling variations permitted when transliterating names from Arabic to English, not only terrorist financiers, but violent and militant Palestinian terrorists as well, could receive CBI passports, which would permit them to pass into Jordan, and from there to anywhere in the world. We have also learned that counterfeit and fraudulent birth certificates, using aliases in place of the legal names of the applicants are being sold, making identification of terrorists impossible by immigration officials and bank compliance officers admitting travelers or those seeking to open bank accounts.

As we continue our investigation into the use of CBI passports by terrorist financiers, we intend to identify the responsible parties, as well as the individuals employing those identification documents, as well as the global terrorist organizations involved. We are especially interested in whether the Palestinian terrorists or terrorist financiers released to the West Bank (a/k/a Judea & Samaria) during the extended prisoner exchange with HAMAS end up with Saint Lucia CBI passports, enabling them to travel abroad.

IS SAINT KITTS & NEVIS' NEW PRE-ARRIVAL SCREENING PROCEDURE FOR VISITORS INTENDED TO BLOCK CRIMINALS HOLDING SKN CBI PASSPORTS?

The Federation of Saint Christopher & Nevis, more commonly known as SAINT KITTS, has announced a new program, ELECTRONIC TRAVEL AUTHORISATION, or eTA, a pre-screening, pre-arrival requirement for all visitors to the two island nation. It is the only East Caribbean country to have such a program, and given the context, sounds suspiciously like the government is seeking to block those Chinese holding SKN Citizenship by Investment (CBI) passports, and who have engaged in money laundering, fraud, and various other types of financial crime in North America and Europe, from relocating to Basseterre, the capital of Saint Kitts, where they are immune from extradition.

Tens of thousands of CBI passports, which afford the holders the absolute right of residence, have been sold in Asia by the CARIBBEAN GALAXY GROUP, at an illegal discounted rate. A large number of individuals have artfully employed their SKN CBI passports to facilitate criminal conduct in the West, which Kittitian government officials have pointedly ignored. It is telling that the official who made the public announcement about the unveiling of eTA was Calvin St. Juste, Chairman of the St. Kitts and Nevis Citizenship by Investment Unit, known as the CIU. His agency has no authority over the protection of its borders, the specified reason he has stated in the recent press release, leading us to conclude that there is a well-placed fear CBI passport holders engaged in transnational crime, returning "home" in large numbers would not only be politically disruptive to Government, but taint Saint Kitts as a safe haven for career criminals.

Also, I don't buy the border protection excuse. In truth and in fact, Saint Kitts, which greatly relies upon expanding tourism, will most likely drive away potential visitors from abroad, who will far more easily decide to take their Caribbean holidays elsewhere, And what about the cruise ship passengers? Will it cause cruise lines to avoid Saint Kitts altogether?

Saint Kitts is, as Calvin St. Juste stated, "protecting national interests" all right, by reserving the right to block all those bad actors holding their passports, and who purchased them in violation of the law, from ever setting foot in the country at Robert Bradshaw International Airport. This way, the CIU thinks it has kept them at bay. We wonder how all this will unfold, and we will be watching. Is Saint Kitts underestimating all their dodgy CBI citizens, Mr. Juste?

IS ANYONE RENDERING COMPETENT ADVICE TO INVESTORS ABOUT THE COMPLEX WORLD OF CITIZENSHIP BY INVESTMENT PROGRAMS?

Ahmad Abbas, Editor IMI

If you troll the Internet, seeking advice on making an educated investment in an economic citizenship, which is obtained through a purchase through Citizenship by Investment (CBI/CIP) programs, which are offered by a number of online publications professing to dispense wisdom on the subject, it is doubtful that you will find accurate advice, as those who are offering it have neither the educational background, professional training, and work experience to cover all the major issues. The online material available is often contains disinformation and and misinformation that falls short of being full and comprehensive disclosure, and only serves to mislead the investor, who unfortunately learns far to late that his six figure investment not only could be at revoked at will, but could expose him to risks that, had he known about them up front, would have been a factor in his decision to invest in CBI in the first place.

We note with concern that neither the Editor nor the owner/CEO of Immigration Migration Insider Daily (IMI) is an attorney licensed in any of the five East Caribbean states, and Malta, and therefore cannot accurately render a legal opinion on several aspects of those CBI/CIP programs, regarding the laws which regulate those economic citizenships, how they interact other local laws, and what legal risks purchasers must assume by buying citizenships and using the issued passports. Also, is dual citizenship even legal where they come from, and they risk loss of their original nationality? These questions require professional opinions.

Christian Nesheim, CEO IMI

Additionally, I note that neither gentlemen are graduate accountants, qualified to render tax advice to international clients whose tax liabilities could be affected in both their original home countries, their new nationality, and even third countries where they may have citizenship or residency issues. How can investors made educated decisions about their future tax situation potentially in multiple jurisdictions without competent tax advice?

Finally, as there have been allegations of widespread fraud in connection with CBI purchases, facilitated through vendors and consultancies but also exposing unwitting investors, does the purchase require a consultation with a criminal defense attorney, to rule out any possible exposure on that front, and are certain CBI purchases really a scam? Industry media promote all of them, without exception.

Now you see why I am troubled when unqualified individuals offering to give a trouble-free estimate of the benefits of a CBI investment. Investors are advised to seek out, and obtain outside advice, and completely ignore the oversimplified advice dispensed by industry media; Caveat Emptor.