SAINT LUCIA STANDS AT A CROSSROADS

PM Philip Pierre and Nicolas Maduro

On Monday, national elections will be held on the Eastern Caribbean island of SAINT LUCIA, a state whose ruling Saint Lucia Labour Party (SLP) has taken the existing Citizenship by Investment (CIP) passport sales program, and turned it into a hot mess of corruption, fraud and money laundering, while openly affiliating the nation with Venezuela, Cuba and the Peoples' Republic of China, all declared adversaries of the present American administration under President Trump. SLC Prime Minister PHILIP J.PIERRE has such a close personal relationship with Venezuela's dictator, NICOLAS MADURO, that we are surprised we cannot find a photo of PJP kissing Maduro's ring, during their amicable meetings in Caracas.

Given the aggressive counterdrug approach the United States has taken towards Venezuela in 2025, moving its omnipotent military assets into the Caribbean, and using them, with talk of further action, The love affair that the current Saint Lucia government has with Venezuela, now a declared American enemy, may have serious consequences in the future, should SLC remain in power, for every Saint Lucian, with the imminent threat of the loss of USA visa privileges, and the imposition of economic sanctions, including tariffs, if the country's foreign policy does not change forthwith.

Enter the Opposition in the upcoming election. the UNITED WORKERS PARTY, or UWP, previously in power, but unseated in a prior election marred by bribery, massive election fraud, SLP intimidation of voters, and a host of human and civil rights violations. Our readers certainly remember the photograph of local attorney THADDEUS ANTOINE, paying off voters from the cab of his truck on election day, as well as similar election fraud committed by attorney LORNE THEOPHILUS. That was far from a free and fair election; we trust that Saint Lucian voters will abstain from taking cash and the promise of privileges, in exchange for voting SLP, or refraining from voting UVP last time.

Thaddeus Antoine

Voters must now choose between a dark future with Labour, which will personally affect each and every one of them in a negative manner after the expected American response to a continued Saint Lucian foreign policy favoring America's Caribbean opponents, and CIP reform, coupled with a new and friendly relationship with the United States by UWP. For the sake of Saint Lucia's future, we trust that that will make the right decision.c

SPONSOR BANKS NOTE: EUROPEAN FINTECH SCANDAL SPOTLIGHTS COMPLIANCE SHORTCOMINGS

If you missed this week's fintech scandal, involving a group of Turkish companies, the article included a number of important bullet points regarding systemic compliance issues, which deserve your attention if you are at a sponsor bank, working to increase the effectiveness of your fintech partners.

1. Fintechs often operate under lighter regulatory burdens, compared to traditional banks.
2. Most fintechs lack the extensive compliance infrastructure built into larger financial institutions.
3. Even when fintechs implement robust anti-fraud measures, criminals can exploit loopholes, use shell companies, manipulate KYC procedures, or exploit high-volume transaction flows, to mask illicit funds.

It was also pointed out to me by a friend who also reviewed the article that many fintechs seem to hire inexperienced compliance officers, who perpetuate these shortcomings. His opinion is spot on. Knowing these issues assist sponsor banks, and the professionals who advise and assist them, to devise effective workarounds to systemic industry problems.

HAVE COMPLIANCE OFFICERS FORGOTTEN ABOUT TERRORIST FINANCING IN 2025?

As we approach twenty five years since the events of 9/11, and as time moves on from 3/11 and 7/7, terrorist financing seems to move into the background in the world of compliance, even though Hamas funding through Canada and Malta, as well as Iran's payments to Hezbollah flow through Iraq and Turkey, remain in the news in 2025. If the Global War on Terrorism. declared by President George Bush is not a hot topic any longer, terrorist financing continues with impunity.

Additionally, with the passage of time, younger compliance officers, who were not working professionals on 9/11, do not have the life experiences from that period, when Countering the Financing of Terrorism was a central concern. Perhaps it is time to remind everyone to continue to be vigilant, as terrorist financing remains a threat, and is alive and well. Let this be a reminder this holiday season to give terrorist financing the same amount of concern that you give to money laundering and fraud.

'TIS THE SEASON TO MOVE THE PROCEEDS OF CRIME

As we approach the first major American holiday of the season, compliance officers would do well to remember that professional money launderers target every potential vulnerability at financial institutions, when choosing to move and clean criminal proceeds. They know that senior compliance staff often take additional vacation days when their children are out of school; some travel, others welcome visiting relatives. In short, the experienced compliance people at a bank who actually are the backbone of its AML/CFT gatekeeping ability are off duty.

That's when opportunistic money launderers strike; they try to move dirty money at the end of a business day, just before a holiday or weekend, because they also know that compliance directors, with all that seniority, and being the department head, often think nothing about leaving work early on those day, to get a jump on the rush hour traffic bound for the suburbs; Think about that. They bank on human foibles and shortcomings.

Therefore, don't let your senior compliance talent skip out, without leaving someone who know how to spot money laundering tradecraft, in real time, and  block those clever transactions, that only the best people in your office will recognize.

AMERICAN BANKERS: IS YOUR NEW CANADIAN CLIENT A HAMAS LEADER ENGAGED IN TERRORIST FINANCING?

Canadian media are reporting that an estimated 450 Hamas terrorists now hold Canadian passports, and since Canadian citizens generally do not need a visa for most temporary visits to the U.S.and can enter with a valid Canadian passport for up to six months for tourism or business, there is a definite risk that your new affluent Canadian "businessman" opening an account is bent on using your bank to facilitate terrorist financing, masquerading as import/export.

The dual Canadian-Lebanese national, Usama Ali, who has reportedly sat on Hamas’s powerful Shura Council since 2019, is sanctioned by the U.S. Treasury and is reported to also head Hamas’s Turkey-based Investment Office, managing at least $500 million in assets through significant real estate sales and major construction companies.In addition to posing as Lebanese, Hamas agents have obtained Canadian passports in the past by claiming to be Syrians fleeing that country's civil war. compliance officers must therefore, seek to identify the passport holder's place of birth, to determine whether he or she is possibly a Palestinian, which should trigger an enhanced due diligence investigation, prior to account opening, to rule out terrorist links. This is suggested for risk management, and does not constitute discriminatory action when it is conducted for CTF reasons. If you have any reservations, you should confirm this policy with your bank's legal counsel.

You do not want to onboard any new Canadian client who takes advantage of Canadian banks' poor record on interdicting terrorist financing to allow fellow Hamas operatives to move their funding through a US financial institutions.

ARE MORE CARIBBEAN MONEY LAUNDERING AND NARCOTICS TRAFFICKING INDICTMENTS COMING OUT OF THE ANDREW FAHIE INVESTIGATION?

Matthias Krull

It has been noted in Caribbean media that the two lesser co-defendants in the money laundering and narcotics trafficking case in US District Court against disgraced former British Virgin Islands Premier ANDREW FAHIE received extraordinary reductions in their sentences, and were quietly, and without publicity, released from Federal Prison. Given that the only other time we have seen such major sentence reductions in SDFL in recent years was just once, in the case against the money laundering Swiss banker MATTHIAS KRULL (of Julius Baer Group Ltd.), we must assume that their Substantial Assistance reached a level of facilitating subsequent indictments of other offenders.

Reza Zarrab a/k/a Risa Sarraf

Given that these additional defendants would currently all be residing outside the United States, any indictments handed down by a Grand Jury would be sealed pending their apprehension. Remember when the Iranian sanctions evader REZA ZARRAB arrived in Miami with his family, intent upon a visit to Disney World, only to find himself arrested due to a sealed indictment? Expect the same thing, in spades, should any of these targets deign to enter America. We shall be watching for news of such "unexpected" arrests again.

ACCUSED INDIAN FRAUDSTER MEHUL CHOKSI'S LAST APPELLATE ATTEMPT TO CHEAT JUSTICE WILL BE HEARD IN BELGIUM ON DECEMBER 9; A FUTILE EFFORT?

MEHUL CHOKSI, the poster child for the abject corruption present in Caribbean Citizenship by Investment (CBI/CIP) passport sales programs, has one more appellate remedy available to him, to avoid justice in his native India, Belgium's highest court, the COURT OF CASSATION, which will hear his case on December 9. A known career criminal, under active investigation investigation in India for nearly the equivalent of $2bn in fraudulent transactions, the granting of a CIP citizenship & passport by Prime Minister GASTON BROWNE's ANTIGUA & BARBUDA government forever stained the Caribbean economic citizenship industry, which is now under direct threat of extinction by a present American administration, on the grounds of national security.

Choksi's last ditch appeal, which by law only involves question of law and procedure, and not factual issues, is not expected to be successful, given the well-reasoned findings of the Antwerp Court of Appeal on October 17, as legal experts who have reviewed the case believe that ruling was proper. Eight long years after Choksi fled to avoid criminal prosecution for his alleged criminal activities, India is now closer to holding him to account for his sins and transgressions. India's own Jabba the Hutt will most likely be coming home to face the music.

SPONSOR BANKS: TO UNCOVER MONEY LAUNDERING OPERATIONS BEING CONDUCTED THROUGH YOUR FINTECH PARTNERS, YOU SHOULD USE THE LAUNDRYMAN'S GOLDEN RULE AGAINST HIM

Financial technology (fintech) firms are at a distinct disadvantage when it comes to AML; Fast-moving businesses that rarely have any face-to-face contact with clients, focus on building their customer base, and lack of any legacy compliance history, especially in startups, equals increased risk that career money launderers are able to exploit those weaknesses, and consistently run the proceeds of crime into, and through your bank.

In my opinion, smart sponsor banks should use what I call the money launderer's Golden Rule against them. Laundrymen typically continue to employ traditional tradecraft of one known technique or another, so long as they remain undetected. They quickly abandon those that are unsuccessful, either at the customer identification stage, or during transaction monitoring; they stick with whatever you are unable to identify and interdict or deter.

Good compliance officers can usually identify the unsuccessful money laundering techniques that fintech compliance officers face, because compliance rejects those attempts. Logic indicates that the fintech is NOT catching specific other techniques, as they are not being interdicted in real-time.
Those are the methods you need to now search for, both in the present, and in a look back of several months. to ferret out the successful tradecraft. In short, what techniques are you not seeing? Do you know what to look for?

This means that the sponsor bank compliance team check out their fintech partners must be have a detailed knowledge of all the specific money laundering techniques in the laundryman's toolbox.They are looking for indicia of techniques not found by your fintech compliance staff, and thus could be the successful methods in use.

The question becomes: how well trained are your sponsor bank compliance officers on money laundering tradecraft specific to fintechs? If you can't affirmatively respond, then you need to properly train them to recognize the broad range of money laundering techniques known to be in use. You catch the laundrymen by identifying their techniques, but first, be sure that your compliance people know what they are looking for.

WATCH THE BANKS OF CARIBBEAN LEADERS PERSONALLY ALLIED WITH VENEZUELA'S MADURO, AS AMERICA PUSHES FORWARD TOWARDS REGIME CHANGE

 

Dominica's PM ROOSEVELT SKERRIT with Maduro

If I am a compliance director at one of the half dozen U.S. banks that still maintain active correspondent relationships with SAINT KITTS & NEVIS, SAINT LUCIA, ANTIGUA and BARBUDA and THE COMMONWEALTH OF DOMINICA, I should be briefing my frontline staff to increase their surveillance on those accounts with any financial institutions in those three Caribbean states, as the American moves against Venezuela may cause the rapid flow of US dollars controlled by Venezuela into, or through cooperating Caribbean banks, to safe destinations abroad, to prevent their seizure by a future Venezuelan government.

Antigua's PM GASTON BROWNE and Maduro

That "flight capital" will be transiting the New York financial center, and since its transfer will most likely constitute money laundering, compliance officers should now be on increased alert for it, in order to detain it upon arrival and receipt. If you wonder who specifically I am referring to, look at these images.

ST. LUCIA PM PJP and Maduro.

SPONSOR BANKS: WHAT CAN YOU DO TO INSTILL A CULTURE OF COMPLIANCE IN YOUR FINTECH PARTNERS IN 2026?

While compliance officers working at financial technology (fintech) companies are generally known to complain about their issues with firm leadership, which often sees their function as a nonproductive hurdle to company growth, it is incumbent upon sponsor banks to aid their fintech partners in creating a culture of compliance, as a risk reduction measure.

Yes, we are well aware that fintechs, whose leaders don't come from the banking sector, and have no history of working with compliance, often place commercial pressures upon their compliance team, to facilitate the success of the company, and compliance officers therefore walk a narrow tightrope, sponsor banks must foster the development of an effective AML compliance program. This might mean contributing software that will assist with customer identification procedures and transaction monitoring, as well as conducting training to upgrade the skillsets of fintech compliance officers.

Sponsor bank compliance officers, who themselves often feel unappreciated by their leaders, have a special duty to assist their fintech compliance brethren in navigating the commercial realities that they face, while striving to always continuously upgrade their compliance effectiveness, through direct assistance, journeying to the fintechs' offices, to suggest solutions and workarounds. Give the fintech compliance officers the tools they need to do their jobs, and if necessary, train them on how to use them.

THERE'S MORE THAN ENOUGH GUILT TO GO AROUND IN RIF TRUST/LATITUDE/LU GOLD CBI SCANDAL

Lucious Gab-Umoden, LU GOLD CEO

We have been throughly covering the pending scandal, involving the theft of an applicant for a SAINT LUCIA Economic Citizenship (CIP) submitted fees. 

Dennis Guttig, ex-GALAXY, ex-RIF/LATITUDE

We have detailed how DENNIS GUTTIG, an American senior sales executive at RIF TRUST/LATITUDE, then a partnership, stole a client's deposit through fraud and forgery. 

Mimoun Assraoui, RIF TRUST/LATITUDE

Eric Major, RIF TRUST/LATITUDE

We have also shown that LUCIOUS GAB-UMODEN, the founder and CEO of RIF sub-agent LU GOLD, had applied for citizenship on behalf of his company's client, at an illegal discount of less than 50% of the minimum sales price, and finally that CARIBBEAN GALAXY GROUP, the Chinese-controlled company at the had of the program, failed to refund the stolen application fees on demand.  

Zhang Kuan, president CARIBBEAN GALAXY GROUP

The total and complete lack of supervision and regulation of the migration investment industry, notwithstanding that sector's slick global marketing campaign claiming otherwise, was responsible for allowing this consumer to become a victim, and then for declining to assist him with restitution. It is humbly suggested that any investor thinking of purchasing an economic citizenship retain the processional services of a competent attorney, to conduct due diligence in advance of any payment submission, and to assist them at every step in the transaction, for this is an unregulated industry, full of fraudsters and charlatans, and you may end up a victim, and lose your entire investment. 

BRITAIN'S CANCELLATION OF INTELLIGENCE SHARING IN THE CARIBBEAN WITH THE UNITED STATES IS NOT GOOD NEWS FOR THE WAR ON MONEY LAUNDERING

The surprising appearance in reports on major UK media, that British cooperation in intelligence sharing with the US, regarding maritime drug trafficking shipments in the Caribbean, shows that the UK government is very unhappy with the current American administration's policy of attacking possible smuggling vessels, without any actionable intelligence confirming narcotics transport. Unfortunately, this cancellation of intelligence sharing also means bulk cash smuggling, via air and sea, is also not being passed on, for both methods are used to move cash destined for the same Caribbean offshore financial centers that have been employed for that purpose since the 1960s. Bulk cash exported from North America often takes circuitous routes to reach Caribbean banks whose officers don't ever ask about Source of Funds, and unwittingly, the new aggressive American military activities, which may be illegal, have made our European allies nervous, with good reason

As we are well aware, the Law of Unintended Consequences has again reared its angry head, and both narcotics, as well as bulk cash, smugglers are most likely pleased that the United States can no longer depend upon its allies' actionable intelligence regarding illicit Caribbean activity. Score another one for the money launderers who consistently operate in the Caribbean with impunity, employing locally-owned financial institutions which the United States chooses to ignore for reasons of diplomatic convenience. America just made it a little easier for the laundrym

THE MOST IMPORTANT NATIONAL ELECTION IN THE CARIBBEAN, SAINT LUCIA, NOW SCHEDULED FOR DECEMBER FIRST

EDMUND ESTEPHANE, DPM ERNEST HILAIRE & PM PHILIP PIERRE

Seeking to remain in power, the Saint Lucia Labour Party (SLP), facing international outcry over its corrupt, Chinese-controlled Citizenship by Investment (CIP) programme, has now scheduled national elections for December 1, 2025, nearly one year ahead of schedule. As you can see from the attached photo, SLP supporter EDMUND ESTEPHANE, openly packing a firearm at an SLP meeting attended by both the Prime Minister and Deputy PM ERNEST HILAIRE, it is anticipated that there will be widespread voter physical intimidation, voter fraud, buying of votes, and other illegal methods to insure that SLP, which is under fire domestically and abroad, including the United States, can steal the election, by any means, and deny Saint Lucians the right to elect honest leaders, and not what is literally an organized crime crew bent on stealing from them.

The reason for SLP election panic: if the Opposition Leader, ALLEN CHASTANET, wins, he has promised to end the rampant fraud, corruption and money laundering in the CIU, the agency that operates the CIP, and has declared his intention to seek to recover the billions of US dollars illegally diverted from the programme by CARIBBEAN GALAXY GROUP, with the active assistance of the sitting Saint Lucia government.

It is believed that such action by one Eastern Caribbean state will spread to all five of The CBI & CIP jurisdictions, and end the corruption that has infected the region, and become worse with the domination of Chinese-owned passport sales companies, who have stolen billions of dollars CBI law intended to benefit the constituents of the nations that offer economic citizenships, and sold passports, without any effective due diligence, to transnational white collar criminals, money launderers, spies and industrial espionage agents.

We call upon the international community and the United Nations to send election observers to Saint Lucia, to monitor the upcoming elections, and by their presence, stop the expected election misconduct by the Saint Lucia Labour Party. Insure fair & free elections in Saint Lucia.