SAINT LUCIA PARTNERS UP WITH CONTROVERSIAL OFFSHORE BANK; BIG MISTAKE?

The announcement, that the Government of Saint Lucia has accepted a sponsorship from Nevis-based HAMILTON RESERVE BANK, which has become embroiled in nasty litigation with an American bank client, and which has a number of serious consumer complaints** against it on the Internet, will not endear this economic passport-issuing Eastern Caribbean state to the American banking community, given its risk-adverse nature.

Hamilton, which reportedly requires a large minimum initial deposit to open an account, has allegedly failed to disburse deposits of clients upon demand, and was the subject of major litigation*, filed on behalf of an US-based company that claims it did not receive a request to disburse twenty seven million US Dollars from its account. Whether Hamilton is insolvent, as the case meets the traditional test of being unable to meet its obligations as they come due, remains an open question. Similar complaints by other bank clients can be viewed on whst appear to be consumer websites. Under the circumstances, compliance officers at international banks may have concerns regarding whether a relationship now exists, between Hamilton Reserve Bank, and Saint Lucia's rogue Citizenship by Investment (CIP) program, which has been accused of involvement in fraud, corruption and money laundering, and the diversion of an estimated USD$1.3bn, by Chinese-controlled CARIBBEAN GALAXY REAL ESTATE LIMITED. Saint Lucia's CIU, the agency that operates the CIP program, has correspondent banking relationships with American financial institutions, which could now be accessed by Hamilton. Alternatively, economic citizenship deposits for Saint Lucia could be routed though Hamilton. Considering that American banks are required to maintain a risk-based AML/CFT compliance program, issues with Country Risk could be the subject of concern. We shall be watching for any indication that these concerns are well taken.

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WILL NEPAL MEET ITS AML CHALLENGES, AND SUCCEED IN BEING REMOVED FROM THE FATF GREY LIST IN 2027?

If you have been following recent political developments in the Federal Democratic Republic of Nepal, you know that the country has gone through rioting, and an election of late, while its remittance-assisted economy continues to labor under the consequences of its second placement on the Financial Action Task Force Grey List. Unsolved problems with widespread money laundering in its casino, real estate, gold trade, and non-Governmental Organisations (NGO) sectors, where industries require comprehensive AML training to convince the FATF that effective compliance is in place, have not yet been conducted, primarily due to severe budgetary constraints.

Nepal needs to focus on AML/CFT programs that will demonstrate to the regulator it has upgraded both compliance in the private sector, to the level of Banking Best Practices, and adequate oversight from governmental agencies which have heretofore been underfunded and ineffective, in order to persuade the FATF that there has been significant reform, across the board. We hope and trust this will occur, now that there is a sufficient degree of political stability. 2027 will be here sooner than you think, and whether Nepal can show sufficient progress at this time, so as to justify FATF action, depends upon the government's resolve and action.

LOOK AT THE FACTS: NEARLY EVERY MAJOR CHINESE WHITE COLLAR CRIMINAL ARRESTED IN THE UNITED STATES DURING THE PAST TWO YEARS ENTERED WITH A SAINT KITTS & NEVIS CBI PASSPORT

Sentenced to 20 years' imprisonment; fled to China.

If you have been reading my articles diligently, you know that, by and large, most of the Chinese nationals arrested for major white collar crime in the United States since 2023 were found to own a Citizenship by Investment (CBI) economic passport issued by SAINT KITTS AND NEVIS. This is an established fact, and if you are a compliance officer, you correctly act accordingly, by classifying SKN passports as high-risk, requiring that an enhanced due diligence investigation be conducted, before you accept individuals holding those identity documents as bank clients, full stop, because you may have a career criminal before you, not a legitimate customer.

I know very well that I am going to receive a lot of pushback for this statement from all the passport sales consultancies in Dubai, who will point out what they claim is Saint Kitts' effective due diligence program, which in truth and in fact is a joke being played upon the financial community. One only needs to read the articles about about how CARIBBEAN GALAXY REAL ESTATE LIMITED, which is Chinese-owned and controlled, sold tens of thousands of passports to Chinese nationals, with ZERO due diligence, because they has their own captive compliance company, owned by one of their senior officers. You will still be hearing the so-called professional opinions from the investment migration sector, especially those at Holborn. (which our UK readers know very well has had it's own share of complaints from consumers; read the articles) Compliance officers should regard those lengthy diatribes, supposedly attesting to the legitimacy of CBI programs, as little less than pure propaganda and spin from individuals who have a conflict of interest by passing judgment on the products that they sell to consumers. My intended audience, as always, are American and European compliance officers, who I trust will take my advice seriously, given their demonstrated interest in reading all those horror stories about Chinese fraudsters, money launderers and those engaged in industrial espionage for the Peoples' Republic of China.

In essence, I advise you to redline ALL Saint Kitts & Nevis passports presented to you, unless you can confirm that the holder is a native-born Kittitian, engaged in legitimate commerce. Reject all the SKN CBI out of hand, in my humble opinion, based upon decades of watching those passports being abused by financial criminals.

WHAT IS THE BEST TIME TO LAUNDER THE PROCEEDS OF CRIME? RIGHT IN THE MIDDLE OF A SHOOTING WAR; PAY ATTENTION, PLEASE

Remember the World War Two film, KELLY'S HEROES, starring Clint Eastwood and Donald Sutherland? It was about a group of American soldiers who steal a cache of gold from a bank, conveniently located behind the enemy lines in France in 1944. That movie reminds us of the law enforcement maxim, regarding the increased chances of success if a crime takes place amidst a background of chaos and confusion. Professional money launderers, a group of which at one point in my life I numbered myself among, instinctively know that when bankers and regulators are distracted by war or rumours of war, oncoming hurricanes or cyclones, or other national or regional catastrophes or events, their attention to detail fades, in the fact of the emerging threat.

Therefore, compliance officers at international banks must now increase their vigilance, and maintain a high degree of alertness, looking constantly for transactions which might mask the movement of criminal proceeds. While during period of danger or chaos, those transfers might be excused or ignored, due to current events, attention rightly focused elsewhere, or thought to be merely anomalies, they must be ferreted out, in real time, lest angry regulators later exact their justice, in a painful, and public manner.

In other words, expect money launderers to take full advantage of the situation; do not let them fool you; stay sharp, and catch them if you can.

HOSSEIN HATEFI ARDAKANI, IRGC WEAPONS TECHNOLOGY FACILITATOR

 

MIAMI'S MOST WANTED MONEY LAUNDERER, RAUL GORRIN BELISARIO, IS BEING HELD BY SEBIN IN A NOTORIOUS VENEZUELAN PRISON

tes ago • Edited • Visible to anyone on or off LinkedIn

RAUL GORRIN, the OFAC-sanctioned Venezuelan lawyer and television station owner, who is on the ICE MOST WANTED list, and who tops the fugitive list for money laundering here in Miami, is being detained by SEBIN, Venezuela's principal domestic intelligence agency, in a notorious underground prison in Caracas. Will he end up being sent to the United States in a secret deal, by the country's present leaders, who are trying to save themselves?

The circumstances of his detention by the Venezuelan National Intelligence Service are unclear, and we are attempting to obtain further details. The latest Miami case pending against him is U.S. vs. GORRIN, Case No.: 24-20468-CR-ALTMAN (SDFL). The former Swiss banker MATTHIAS KRULL is one of the individuals named in that indictment.

SAINT LUCIA'S GOVERNMENT, EXCEPTIONALLY LATE WITH ITS 2024 CITIZENSHIP BY INVESTMENT (CIP) REPORT, AUTHORIZES TWO NEW PROGRAMS, BUT OFFERS ZERO DETAILS

While SAINT LUCIA'S Prime Minister, PHILIP J. PIERRE, has ostentatiously flaunted in Parliament what he claims is the 2024 Citizenship by Investment (CIP) Annual Report, which was due more than six months ago by law, he has continued to withhold it from release. Insiders claim that he fears a backlash from Saint Lucians, when they learn of the extent to which it shows mainly sales to Chinese passport purchasers, by Chinese-controlled CARIBBEAN GALAXY REAL ESTATE LIMITED, which has been stained by major scandals involved underselling fraud, money laundering and corruption, in both Saint Lucia as well as in Saint Kitts & Nevis.

To add insult to the injury suffered by Saint Lucians, the government quietly released a notice, at a place not generally seen by the public, the Gazette, of its intent to open two new programs. Curiously, no details were offered, save the names of the projects, and there has been no further information released to the public.They therefore have no idea of the scope of these projects, and how many passports will be offered.

This tactic, which smacks of government intent to conceal the project from the public, is but additional evidence of a concerted effort to deprive Saint Lucians of information they need to exercise proper oversight over a CIP program that operates in secret, and has allowed Caribbean Galaxy to illegally divert an alleged USD$1.3bn in sales proceeds to China. Unless further details are forthcoming, Saint Lucians, who are supposed to be the beneficiaries of CIP projects, will remain in the dark, and probably again be the victims of the corrupt actions of the CIU, the agency which operates the CIP program.

 

The man who is illegally withholding the 2024 Report from St. Lucia

TODAY IS NATIONAL VIETNAM WAR VETERANS DAY 2026

Early mornings are precious to Vietnam veterans, even 55 years after they came home from a war they did not choose to serve in, for every dawn in Vietnam, during the conflict, if you were out in the field, you counted yourself as lucky to have survived another night, for night was when the enemy generally attacked.

Here's to all those Vietnam veterans who are still among us, haven't died from all the Agent Orange cancers, nor taken their own lives due to PTSD, and live to testify to the folly of endless foreign wars conducted by politicians who insure that their own sons never serve in them. Nobody lives forever, but we are definitely still here, America.

CHINESE FUGITIVE USES SAINT KITTS CBI PASSPORT TO PURCHASE £81m IN HIGH-END LONDON REAL ESTATE WITH IMPUNITY

SU JIANGBO, wanted in China for allegedly running an illegal casino gambling operation, used his SAINT KITTS & NEVIS CITIZENSHIP BY INVESTMENT passport to purchase 85 newly-built luxury properties worth £81m of London real estate. Su used his SKN CBI passport to incorporate a dozen UK companies to take title to the expensive realty, which included a penthouse worth the equivalent of $13m, and $24m of properties at Trytpych Bankside. Law firms listed as being involved in representing the UK corporate purchasers have been identified by the Organized Crime and Corruption Reporting Project (OCCRP) as Zhon Lun Law Firm, Riseam Sharples, and Ackroyd Legal LLP .

The Crown Prosecution Service has frozen the properties, pursuant to Unexplained Wealth Orders and Interim Freezing Orders.The arrest warrant from China includes 38 other individuals; Su is not in British custody, and is believed to be somewhere in Southeast Asia, possibly Cambodia, at this time. Efforts by media to contact him for comment after the UK properties were frozen were unsuccessful. Given the sordid history of the use of Citizenship By Investment passports issued by the five Caribbean CBI and CIP states, especially Saint Kitts and Saint Lucia, the failure of compliance officers at UK banks to immediately block transactions, until an enhanced due diligence investigation are conducted, to confirm Source of Funds and Source of Wealth, should be considered professional negligence, if not willful blindness. Frankly, I would redline all transactions, where Saint Kitts passports are used for identity purposes, until the client is cleared by an opinion of outside legal counsel. Was nobody in the UK paying attention to the fraud, money laundering and fraud revealed in the MSR Media cases?

Sample SKN passport

DISTRICT JUDGE: YOU HAVE A "FUNDAMENTAL DUTY" TO CONFIRM YOUR AI RESEARCH, OR THERE WILL BE CONSEQUENCES.

Buried towards the end of the latest court ruling in the $2m judgment for Defamation, entered against MY PILLOW owner, MIKE LINDELL, is a scathing attack on Lindell's attorneys, who used AI for research, and failed to check what the program gave them as legal authority, when they cited it to the Court. The trial Judge pointed out the serious factual errors, regarding the court decision they cited. See the portion attached hereto.

The judge ruled that they had a FUNDAMENTAL DUTY to check all the material that artificial intelligence they proffered to the Court, and it appears that their negligence will possibly result in sanctions where they hold their law licenses.

Compliance officers, when you use AI to conduct due diligence, ALWAYS check the results independently through a known, trusted resource. Failing that,, you could approve or disapprove a new client, based upon fictitious "information," which might come back and bite you, and your bank, later. Check your AI results, please, every time.

A FORMER CAREER MONEY LAUNDERER EXPLAINS IT ALL REGARDING SUCCESS IN TRADE-BASED MONEY LAUNDERING

Inasmuch as most compliance professionals don't have a lifetime of experience in the identification of trade-based money laundering, like AVRAAM DEMETRIOU, I believe it is important for frontline compliance officers to understand how competent their TBML adversaries are, so that they govern themselves accordingly. Otherwise, the deck is, frankly, stacked against them.

First of all, many laundrymen who engage in trade-based money laundering have prior relevant industry experience, which affords them distinct advantages over bank compliance officers tasked with the identification of TBML. I remember attending an emergency Saturday hearing in Federal Court as a young bank lawyer, where it quickly became apparent that my opposing counsel had an extensive shipping background. Lawyers and accountants who have worked for freight forwarders, shipping lines, or law firms that handle maritime matters exclusively possess a familiarity with the industry that young compliance officers are sorely lacking, as they are dealing with a wide variety of client businesses.

Second, these TBML laundrymen generally have the ability to create legitimate-appearing documentation that, unless compliance takes valuable time to confirm, will pass muster every time, especially in the hurried environment of an international bank's compliance department, with deadlines on pushing out files, and ambitious junior compliance staff on the way up, conscious of their need to complete assignments not just on time, but actually ahead of schedule. That nasty end-of-day deadline on file reviews will result in TBML sneaking through every time, unless the compliance officer knows the tricks of the TBML "profession."

Finally, artful laundrymen in the TBML sphere apply money laundering tradecraft, used to penetrate other business sectors, which is usually missed by compliance officers intent on looking for industry-specific techniques. You are looking for apples, when your opponent is throwing oranges at you, and beating you.

Space doesn't permit further detailing of the winning TBML tradecraft; I have explained some of the tricks in prior articles, and if you require a tutorial on what to watch for, I can present a virtual seminar on those TBML methods for your compliance staff. Find me here: miamicompliance@gmail.com

SPONSOR BANKS: INCREASE AML EFFICIENCY OF YOUR FINTECH PARTNERS THROUGH TRAINING ON TECHNIQUES LAUNDRYMEN ARE KNOWN TO EMPLOY WITH IMPUNITY

Given the current position of America's regulators, that sponsor banks are ultimately responsible for the anti-money laundering shortcomings of their fintech partners, it is humbly suggested that they focus on imparting relevant knowledge to fintech compliance officers, regarding the money laundering techniques and methods that are known to be successfully employed to that specific sector of the financial services industry. Laundrymen often use shell and shelf companies, after artfully concealing beneficial ownership, to deceive busy fintech startups which are focused on expanding their customer base to reach profitable status. They bank on the eagerness of fintechs to attract new business, hoping that management will trump normal compliance concerns, when expanding that important client base. Money launderers also look for fintechs desperate to enlist strategic partners, for mutually beneficial business arrangements; under those circumstances, they are betting that fintech ownership may not look too closely at the background of partner ownership. Our concern is that proceeds of crime will be moved though the unsuspecting fintech, piggybacked with legitimate transactions. Who really owns that affiliated company? Often, fintech compliance officers are simply unaware of how advanced money laundering techniques, funneled through sponsor bank partners, appear at the their inbound end. It has become their responsibility to impart that tradecraft to them, even if it means regular training sessions at the fintech location, and not conducted virtually, so that message gets through of its importance. it may seem like an uphill battle, but unless a sponsor bank wants that unwelcome visit from regulators, exposing the fact that one fintech dropped the ball in a major matter, you must teach those generally inexperienced compliance officers how to spot specific money laundering methods in real-time.

THE CASE OF THE CONVICTED CHINESE MONEY LAUNDERER WITH THE ST. KITTS CBI PASSPORT AND THE FUGITIVE DISENTITLEMENT DOCTRINE

Remember DAREN LI a/k/a LI DAREN, the Chinese crypto scam fugitive, who pled guilty to Money Laundering Conspiracy, and then cut off his ankle bracelet, before fleeing the United States? An angry United States District Judge in Los Angeles, sentenced Li to the maximum - 20 years' imprisonment, for his crimes. We note however that Li, when interviewed at an undisclosed location abroad
(Cambodia, perhaps?) stated that his conviction, which he pled guilty to, was "unjust," that he had been "deceived and induced" to enter a guilty plea, and that his attorney was appealing his conviction. 

Perhaps someone should enlighten Li, regarding the FUGITIVE DISENTITLEMENT DOCTRINE, well established in American Federal jurisprudence, which states that:

"In Ortega-Rodriguez v. U.S., 507 U.S. 234 (1993), the Supreme Court observed that '[i]t has been settled for well over a century that an appellate court may dismiss the appeal of a defendant who is a fugitive from justice during the pendency of his appeal,' id. at 239, citing Smith v. United States, 94 U.S. 97 (1876), as its earliest invocation of the doctrine."

Li will have to surrender himself, and return to custody, if he want to prosecute an appeal, and even then, there's case law affirming that an appellate court may not commit error if it dismisses his appeal anyway. Perhaps he should have taken the time to consult with his attorney, before cutting off that ankle bracelet, if he was truly serious about his claim of being railroaded into a guilty plea.

PAUL BILZERIAN: TIME MAY BE RUNNING OUT IN THE CARIBBEAN

Paul Bilzarian

Let me be very clear to my friends in the compliance community: Paul Bilzerian is a wanted man in the United States. There is a current federal indictment; There are active criminal charges; And there is an arrest warrant. Yet, for years, he has continued to reside in Saint Kitts and Nevis, operating in a jurisdiction that many of you already know well — not from tourism brochures, but from SAR filings and enhanced due diligence reports.

THIS CASE NEVER CLOSED — IT EVOLVED

Some of you may remember Bilzerian from his original conviction back in the 1980s. Securities fraud. Aggressive takeover schemes. A textbook case.But the real story — the one compliance officers should care about — is what came after.
- Massive disgorgement orders from the U.S. Securities and Exchange Commission 
- A refusal to pay 
- Decades of litigation and a judgment
- And the systematic movement of assets offshore 

Fast forward to 2024, and the U.S. government has had enough. New charges include wire fraud, securities fraud, and conspiracy.This is no longer a historical case. It is active.

THE ST. KITTS FACTOR — AND THE CBI QUESTION

Bilzerian relocated to a jurisdiction that offers financial opacity, flexible corporate structures, and a long-standing Citizenship-by-Investment (CBI) program. CBI is not illegal. But from a compliance standpoint, it introduces identity layering, jurisdictional complexity, and obstacles to enforcement.

THE STRUCTURE: CONTROL WITHOUT OWNERSHIP

According to U.S. prosecutors, Bilzerian’s financial strategy follows a familiar offshore pattern:
- Assets placed in offshore entities 
- Nominee ownership 
- Indirect control mechanisms 
He doesn’t “own” the assets — but he controls them.

DETENTION REPORTS — A POSSIBLE SHIFT

Local outlet St. Kitts Times reported that Bilzerian was detained on the island. At the time of writing, this has not been confirmed by U.S. authorities or the government of St. Kitts and Nevis. If confirmed, it could signal a shift.

THE PRESSURE ON SMALL JURISDICTIONS

The United States has intensified enforcement across the Western Hemisphere. Jurisdictions like St. Kitts and Nevis face a choice: protect offshore clients or maintain access to the U.S. financial system.

EXTRADITION: FROM THEORY TO POSSIBILITY

If U.S. pressure increases, extradition becomes a credible scenario.

LOCAL RELATIONSHIPS — AND PERCEPTION RISK

There are persistent perceptions that offshore actors develop proximity to local elites. There is no publicly confirmed evidence of specific relationships between Bilzerian and senior officials. But perception risk alone can drive action.

FINAL ANALYSIS

Paul Bilzerian is wanted by the United States government; He has operated from a CBI jurisdiction for years. The question is no longer whether he can remain offshore — but whether the jurisdiction can afford to keep him.

THE RIJOCK RULE

Offshore protection works — until the cost of providing it exceeds the benefit.

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FOR FURTHER READING:

ST KITTS ECONOMIC CITIZENSHIP REP IS CAREER FRAUDSTER

https://rijock.blogspot.com/2016/07/st-kitts-economic-citizenship-rep-is_5.html