SPONSOR BANKS SHOULD CONDUCT LOOKBACKS ON ALL NEW FINTECHS THEY BRING IN, TO INSURE THAT THERE ARE NO MONEY LAUNDERING SKELETONS IN THEIR CLOSET

If you have any friends or family working in the financial technology industry, you may know that a 2025 study concluded "Nearly three-quarters of financial technology startups fail within their first three years due to preventable regulatory compliance issues, according to a new industry report released today." The staff of your new fintech client, and perhaps even the owners, come from prior business failures, in a highly competitive industry where the inability to bring a groundbreaking product to market occurs more often than not, and where a lack of regulatory experts contributes to the high failure rate.

Sponsor bank, are there leaders in your newest startup fintech client who have a prior history where compliance failures helped doom a venture, and were those failures linked to money laundering or financial crime? In your haste to bring in a potentially lucrative fintech, has your legal counsel thoroughly researched the work history of its ownership? It is humbly suggested that this be the rule, rather than the exception, for valid risk reduction purposes.

A final note; sometimes such "shortcomings" are being concealed. Therefore, dig a bit deeper, meaning industry news resources as well as social media, to insure that your new fintech's leadership has no compliance skeletons that they are hiding from you.

Read my old article warning the financial community about the individuals who hid the fact that their prior position had been with a firm that collapsed due to an international scandal over money laundering and shell companies owned by corrupt PEPs, and where they were named co-defendants. Don't be the bank whose fintech principals are very publicly arrested for prior sins and legal violations.
WE NAME THE 27 CO-DEFENDANTS IN THE MOSSACK & FONSECA MONEY LAUNDERING TRIAL UNFOLDING IN PANAMA THIS WEEK
https://lnkd.in/eU88i3Xg

SPONSOR BANKS SHOULD UNDERSTAND THAT FINTECHS WHICH ARE STARTUPS CAN BE TARGETS FOR MONEY LAUNDERERS

Sponsor banks may want to pay special attention to fintech clients for Banking as a Service that are new business enterprises, regarding elevated money laundering issues. As new ventures, and even with experienced compliance officers handling AML/CFT during customer identification, as well as transaction monitoring, there will be an initial period when compliance staff, becoming familiar with the new startup's business model. commercial goals, and business culture, absorbs the company's style, and becomes sufficiently effective, to recognize and deter financial crime, particularly money laundering.

Second, as the new fintech struggles to create, market and sell a product, and become profitable, the sometimes desperate search for stopgap funding, to keep the company operating before a product launch, might temp ownership to not look too closely at a Source of Funding offered to them, which could later insist that they take shortcuts in compliance, as a reward for the money. What if the real purpose of being a finding source was to insist later that certain business be accepted, which in truth and in fact was money laundering? What anxious and needy fintech performs enhanced due diligence on their funding?

Finally, The focus of a startup fintech is zeroed in on becoming a success, and an effective compliance program, which can be considered an excessive expense by owners cutting costs to the bone costs, might be ignored for budgetary reasons. Therefore, sponsor banks should govern themselves accordingly, when onboarding startup fintechs, and seek to guide their new compliance departments in building an effective program, while at the same time paying special attention to the client business they process through their bank.

THE USE OF AN ECONOMIC CITIZENSHIP PASSPORT TO ENGAGE IN TERRORIST FINANCING

The upcoming citizenship by investment passport sales event in Beirut reminds me that working terrorist financiers, working for Hezbollah, might be inclined to attend that seminar, looking to acquire that valued Grenada passport advertised in the brochure. It is not only money launderers for narcotics traffickers that choose to conceal their nationalities when moving money for an illicit purpose, by employing low-risk CBI and CIP passports sold by the five Eastern Caribbean nations, SAINT KITTS, SAINT LUCIA, ANTIGUA, DOMINICA and GRENADA. Such passports generally do not raise any red flags in Europe, where much terrorist financing fundraising by Hezbollah, as well as its ongoing criminal ventures, occurs.

We can only trust that the attendees at this event, which begins Thursday, include members of the world's intelligence services, and that they are taking ample photographs of the participants therein, especially those who appear to be engaged in making applications for EC citizenships and passports.

https://executive-bulletin.com/real-estate-2/real-estate-and-citizenship-by-investment-expo-9th-edition-between-lebanon-and-the-world-all-opportunities-await-at-rcpie-beirut-2025

DID RIF TRUST ENGAGE IN A BULK SALE OF ASSETS TO EVADE PAYING THE VICTIMS OF ITS ILLEGALLY-DISCOUNTED PASSPORT SALES?

There are credible reports that RIF TRUST INVESTMENTS LLC., the UAE entity said to be owned by MIMOUN ASSRAOUI, has engaged in a Sale of Bulk Assets to an unnamed Portuguese entity. If this is confirmed, then such a sale will leave the limited liability company with no ability to compensate those of its clients whom it sold SAINT KITTS and SAINT LUCIA economic citizenships at illegally-discounted prices, and it is generally considered under the law to be a fraudulent transfer, which a court can set aside as a fraud on victims. Additionally, selling passports at a discount constitutes a felony under Kittitian criminal law.

The Government of Saint Kitts has already ordered any purchasers of its passports for fees less than the legal minimums to pay the difference directly to it, making RIF Trust, and its officers, strictly liable to reimburse the victims, and potentially for money damages as well. RIF has been banned from further sales of St. Kitts citizenships as the direct result of its misconduct.

Will criminal charges be filed in Dubai, against the company's officers and directors? we cannot say at this point, but we will be watching unfolding developments, and will report back to our readers shortly.

WILL DUBAI FIND LATITUDE LIABLE FOR RIF TRUST'S MISCONDUCT, DUE TO THE FACT THAT A PARTNERSHIP EXISTED DURING THE PERIOD IN WHICH RIF EXECUTIVES ENGAGED IN FRAUDULENT ACTS?

If you have read our recent article, MEET THE AMERICAN EXECUTIVE AT RIF TRUST WHO ALTERED APPLICATIONS, FORGED SIGNATURES AND STOLE CLIENTS' APPLICATION FEES, WHILE PROTECTED BY COMPANY MANAGEMENT AND CARIBBEAN GALAXY https://lnkd.in/ennebKhc then you know that we possess what appears to be conclusive, incriminating evidence that RIF TRUST engaged in unlawful conduct, with respect to some of its clients, who were applying for CBI and CIP passports from SAINT KITTS & NEVIS and SAINT LUCIA, and they were defrauded.

We have been reviewing that evidence, and have discovered that the relevant contracts feature both RIF and UK-based LATITUDE logos on the signature page; both companies were reportedly engaged in a partnership during the period in which massive consumer fraud occurred at the joint offices in Dubai. Although that partnership is known to have been subsequently terminated, it was in full force and effect at that time.

(Portion of contract)

While we do not profess to be knowledgeable, regarding the laws of the United Arab Emirates, which is the chosen venue as well as applicable law specified in the contracts, in the event any dispute arises, general partnership law would appear to impose strict liability on The Latitude Group and/or LATITUDE CONSULTANCY HOLDINGS LIMITED. We shall be closely following the victims' claims, and will cover any future decision by a court of competent jurisdiction, as the matter unfolds.

MEET THE AMERICAN EXECUTIVE AT RIF TRUST WHO ALTERED APPLICATIONS, FORGED SIGNATURES AND STOLE CLIENTS' APPLICATION FEES, WHILE PROTECTED BY COMPANY MANAGEMENT AND CARIBBEAN GALAXY

DENNIS MICHAEL GUTTIG JR., an American citizen residing in the United Arab EMIRATES, has been identified by his victims as the executive at Dubai-based RIF TRUST INVESTMENTS LLC, a seller of economic citizenships and passports, who was the primary fraudster at the company in a campaign of document alternation, client signature forgeries, and theft of RIF customer passport application fees. Guttig, who is a former CEO of the Chinese-owned and controlled CARIBBEAN GALAXY GROUP, named as the principal entity that sold ten of thousands of Eastern Caribbean CBI & CIP passports from SAINT KITTS and SAINT LUCIA, without any due diligence, to Chinese career criminals, reportedly acted with impunity during his career at RIF, due to the fact that he was the senior company rainmaker, bringing in lucrative business, which afforded him protection by the firm's owner, MIMOUN ASSRAOUI.

Mimoun Assraoui, CEO RIF Trust 

Efforts by the victims to recover their losses for the thefts, which were admitted and acknowledged by Guttig in writing, were unsuccessful, as were requests for restitution made directly to Caribbean Galaxy in SAINT LUCIA. Guttig actually made partial payments, which are further evidence of his criminal activities, but the bulk of the victims' losses have never been repaid. We have admissible, documentary evidence of all the statements made in this article, and in the coming weeks, we intend to prove all these claims, in further installments of this disturbing story, which illustrates the inherent dangers applicants face, when dealing with international entities that are vendors in the investment migration industry, Many of whom are charlatans masquerading as "legal experts," when they are neither practising lawyers, nor competent to render advice in complex transnational legal and tax matters, and exist in a totally unregulated sector.

Additionally, we shall be directing our attention to Mr. Guttig's specific criminal method of operation, how his fraud was supported by RIF Trust, and his sordid history in the investment migration industry; stay tuned.

SPONSOR BANKS: MAKE PERIODIC, UNANNOUNCED VISITS TO YOUR FINTECH PARTNERS TO AUDIT THE ACTUAL EFFECTIVENESS OF THEIR COMPLIANCE DEPARTMENTS

We have recently been covering a number of important aspects of the duty off sponsor banks to insure that their fintech clients are maintaining effective AML/CFT compliance departments, even suggesting that, if necessary, they donate the necessary programs in customer identification and transaction monitoring, to get the job done. Remember, the compliance shortcomings of your fintechs can cause you major problems with regulators if they surface during a criminal investigation of targets exploiting them.

While your fintechs may have all the compliance bells & whistles necessary to run a clean shop, how can you be assured that they are actually employing them consistently, day after day? How do you know they don't just add staff to their compliance function, on the days you show up to check on them?

The solution is to have an experienced, trained member of your own staff make repeated, but unannounced, visits to each of your fintechs, to audit their compliance programs in action. That individual should know what the red flags of an ineffective or half-hearted compliance program look like, and file a written report to your bank management after each visit, so that demands for remedial action, if needed, will be swift, with subsequent checks for actual implementation.

I cannot emphasize enough the strict liability that regulators have assigned to the obligation of sponsor banks of seeing that their fintechs maintain a sufficient compliance regime to reduce the risks that money launderers will penetrate their client base, and be allowed to move the proceeds of crime through your bank. The compliance sins of your fintechs will be deemed to be your responsibility; audits are a method of catching them early on, and taking action to eliminate them, before you are called on the carpet by regulators.

THE ARREST OF RIF TRUST HEAD MIMOUN ASSRAOUI FOR FRAUD REMAINS PENDING IN DUBAI UAE

                                                                    

 MIMOUN ASSRAOUI, of RIF TRUST, was arrested earlier this year, by the authorities in Dubai, UAE, in connection with his company's repeated sale of illegally-discounted economic citizenships of Saint Kitts & Nevis, and Saint Lucia (CBI/CIP). Continued social media postings, by third parties in Saint Lucia, which attempt to constitute Mimoun's unsworn denial that he was indeed arrested, are bogus. To be precise, the defendant does not come out and affirmatively say he was not arrested by UAE authorities; he dances around it, trying to convince the public that his online appearance means he wasn't. Not true, ladies and gentlemen. The arrest did occur, based upon allegations by a victim that the company sold illegally-discounted Citizenship by Investment passports. RIF Trust has been blacklisted by the government of Saint Kitts & Nevis, and can no longer sell SKN economic citizenships of that Eastern Caribbean state.

In truth and in fact, Assraoui was simply released on bond; he reportedly cannot travel outside the Emirates without express permission, and he is currently under court supervision. The case remains a pending criminal proceeding; there has not been any ruling adjudicating his guilt. We will continue to monitor the case and report back to our readers when there is a notice of a trial date. 

 Most Internet users are fully aware that social media information is never to be taken at face value; ignore it. If you haven't seen the original articles ab

Further information can be found on my blog:https://rijock.blogspot.com  

WHERE IS AL-QAEDA'S MOST DANGEROUS TERRORIST LEADER?

MUSTAFA SETMARIAM NASAR, also known as ABI MUSAB AL-SURI, a red-headed Syrian national, is Al Qaeda's leading theoretician (author of the organization's 1600 page treatise) and the intellectual author of the MADRID TRAIN BOMBING and one other terrorist attack in Spain. Captured by the Central Intelligence Agency in Venezuela, after a manhunt led by retired FBI agent ROBERT LEVINSON, he was spirited away to Pakistan, where a cover story alleging that ISI had captured him there appeared, concealing the fact that he had actually been living in the Western Hemisphere. He was subsequently interrogated at an American black site in DIEGO GARCIA, and later transported to, and imprisoned, in Syria. 

Our sources advise that he was released during the confusion surrounding the chaos of the Syrian civil war; his location after that remain a mystery, although a mainstream media article claims he was executed by the Assad regime while in custody. Given his prominent role, as a close Bin Ladin associate, and the fact that his presence in Venezuela, where he was protected by the Chavez government, was never publicly disclosed, it is possible that he is still operational with Al-Qaeda.

Perhaps it is now time for the United States to declassify the circumstances of his capture and removal from Venezuela, and to answer the questions regarding whether this action American authorities was the reason for the subsequent kidnapping and detention of Robert "Bob" Levinson, in Kish Island, Iran, who was held for decades by the Government of Iran. Levinson's communications with Venezuelan agents were intercepted in Caracas at CANTV headquarters by Cuban Intelligence, and perform unauthorized duties for CIA researchers, which information may have been in the possession of Iran when he arrived there to interview an American fugitive. It is time for the truth regarding the Bob Levinson case to be known; his family deserves no less.

COMPLIANCE OFFICERS MUST PLAY THE LONG GAME, IF THEY WANT TO PROTECT THEMSELVES, AND THEIR BANK, WHEN THE PENDULUM SWINGS BACK ON ENFORCEMENT

Consider this article a totally non-political reality check; professional guidance during a period of governance that may later be judged harshly. Compliance officer, protect thyself.

If you are one of those people feeling relieved, as the present administration stops enforcing FCPA violations on American citizens, and relaxes AML regulations across the board, think again. Enforcement will most likely swing back under the next US government, and you and your bank may be left holding the bag on what you thought was safe, but has now become the subject of regulators and law enforcement making an example of. In short, expect a tightening of regulatory action in the not so distant future, and don't get caught out in the cold.

The Statute of limitations will not have run out in 2029 on criminal violations arising during the next three years, and our conspiracy statutes will fit the gap on those that do. My advice is to continue to operate your AML/CFT compliance program under 2024 rules; to do otherwise invites a future visit from newly zealous regulators or law enforcement agencies, operating under zero tolerance rules; Govern yours

AML FOR SPONSOR BANKS STARTS BY CONDUCTING ENHANCED DUE DILIGENCE ON THE FINTECHS YOU BRING ONBOARD

With all the concerns about the lack of an effective AML/CFT compliance program, on the part of sponsor bank fintech clients, we need to go back one critical step, when we create a program designed to reduce the risk that their new fintech is unwittingly allowing money launderers to feed the proceeds of crime into the deposits it is moving through accounts at your bank. That is the satisfactory completion of a thorough enhanced due diligence program on fintech ownership and control, prior to allowing it to open operating accounts.

Fintechs must rely upon the injection of sufficient capital to both commence operation, as well as to sustain themselves while seeking to become profitable, and their owners are often literally desperate to raise funds to prevent abrupt shutdown. Do their owners do a deep dive own the background, Source of Funds and Source of Wealth of their funding? Does a drowning man question the bona finder of his rescuer? As a reformed money launderer, owning a fintech, and using it to clean dirty money, sounds like something that laundrymen would love to engage in.

We are concerned about not only the initial funders, and the short-term funding that a fintech reaches out for when it is ongoing, but still not yet profitable, as those sources could influence its owners to accept clients who are, in truth and in fact front for money laundering, but sponsor banks must also understand that criminal elements themselves might also be the beneficial owners. Only if you rule out such events through enhanced due diligence, up front, can such nightmares be avoided. True anti-money laundering starts with the identity of your fintech client's owners and funding sources. Do not take shortcuts on this risk reduction measure, or you might find yourself later regretting that you ever took on a fintech who subsequently got your sponsor bank into serious hot water with regulators or law enforcement; watch yourselves on this issue.