HOW TO STOP THE MONEY LAUNDERING AND TAX EVASION PROBLEMS POSED BY THE BVI AND CAYMAN

Tax evaders, money launderers and corrupt political leaders all favor the British Caribbean tax havens of the Cayman Islands, and the British Virgin Islands, and it has become clear that the UK Foreign and Commonwealth Office will not step in, and impose Direct Rule, as was done with the Turks & Caicos, due to the enormous costs, and manpower, that such actions would require. Perhaps there's a more cost-effective, and efficient, alternative, that would cause the world's criminals to cease exploiting these offshore centers: give these two British Overseas Territories independence.

In truth and in fact, people with cash to hide are attracted to the BVI, and Cayman, due to the fact that these are British possessions, which connotes some semblance of stability and safety for their dirty money. Though this is largely illusory, as we have seen repeatedly, when legitimate foreign investors have lost their assets there through fraud, without obtaining any relief whatsoever from local or UK agencies, it is the major selling point, aside from bank and corporation secrecy.

Set the Caribbean tax havens of Cayman & the British Virgin Islands free, and watch how fast Chinese tax evaders abandon the BVI corporation, and how swiftly people with dirty money decline the BVI/Cayman "sandwich," of a BVI company holding a Cayman bank account. Removing the British territory pedigree will peel back an important attribute that attracts dirty money, and hopefully shut down the BVI shell company factory, for that reason.

Then, if these new countries still refuse to revoke their laws on the issuance of bearer shares, and their abject failure to require Source of Funds and Beneficial ownership, the US & Canada will be free to impose crippling sanctions, until they do. Presently, the nations of North America are powerless to reign in these tax havens, but with independence, major sanctions could be implemented.

So what about it, Foreign & Commonwealth Office? Will Britain finally do what has been sorely needed since the 1980s, take steps that will end the problem, once and for all, by granting the BVI and Cayman full independence ?

MIAMI'S OBJECTIONS TO BEING SINGLED OUT FOR MONEY LAUNDERING ARE NOT WELL TAKEN

The Miami-Dade County Commission, in a symbolic resolution, has lodged a strong objection to what its feels is undeserved attention from US law enforcement and regulatory agencies, regarding money laundering in Miami. This comes on the heels of the Miami indictment, this week, of 22 individuals for laundering millions of dollars for the Sinaloa cartel, including the principal money launderer for Joaquín "El Chapo" (Shorty) Guzmán.

The Commissioners are objecting to specific US Treasury Department targeting orders, involving 700 import/export firms neat the Miami Airport, and all real estate transactions over one million dollars, that occur in Miami-Dade County. Please allow me to respond, as I believe I have unique qualifications to analyze the issue they have raised, due to my 45 years of experience, working in this city, literally on both side of the money laundering problem.

First, Miami's banks lead the nation in regulatory fines & penalties, for deficiencies in their anti-money laundering and countering the threat of terrorist financing (AML/CFT) programs. Many banks are censured multiple times, and consistently fail to improve their AML programs sufficiently to be removed from regulatory supervision. It appears that they regard those fines as the cost of doing business, for repeated violations indicate a corporate culture that regards profit ahead of instituting banking best practices. This is a national disgrace, and it needs to stop.

Second, we are home to the largest healthcare fraud operation in the United States, where unneeded and bogus health care, medicines and medical appliances are fraudulently prescribed, and sold, costing the American taxpayer billions of dollars in bogus billings. The healthcare scam even has a special Miami twist to it, where Cuban nationals are actually imported, as front men, then returned to Cuba, outside the reach of US law enforcement. Often, criminal proceeds is also wired to Cuba, and placed in Cuban state-owned banks.

Third, Miami's vacation mecca culture conspicuous consumption, often excessive and even garish, has spawned a high-end real estate market that attracts dirty money, and inasmuch as money laundering laws do not yet apply to realtors or brokers, the city has become a magnet for "flight capital," with little push back from a business community, eager to take obscene profits from anyone.

While the "Miami Vice" era of the 1980s, where carloads of dodgy cash were deposited in Brickell Avenue banks, is gone forever, more subtle methods of placing dirty money still are in widespread use in Miami-Dade County. The malevolent Cocaine Cowboys no long assassinate their competition in the city's streets, but they do find ways to move consistently drugs and money through Miami. County Commissioners, we are still a problem for US law enforcement. If you really want to no longer be the subject of unwanted attention, get the business community to actively assist in money laundering suppression, by refusing to accept money, where the Source of Funds cannot be established. Miami businessmen, leave the attractive dirty money alone.

PANAMA PAPERS INFORMANT FIRST SOUGHT TO SELL THE INFORMATION IN PANAMA

Jahaira (photo chosen for privacy reasons)

The story of the informant (or informants) responsible for releasing the "Panama Papers" document to the global press is far more complex than the media is making it out to be. Mossack and Fonseca's description of the theft of the information, as a cyber-hack, is simply not true, as you know. Let's clear the air on the individuals known to be involved, especially since readers are now writing in, and asking me to identify the players.

First of all, the original informant, as previously detailed in this blog, was a receptionist at the Mossack law firm; she served as Ramón Fonseca's longtime mistress, and, of course, had access to the firm's email accounts. After the affair ended badly, she left the firm, taking with her a large number of emails and documents.

Thereafter, she attempted to vend her documents around Panama City, and did sell off small segments; this was back in 2008 and 2009, a fact that seems to have escaped most of the published stories purporting to report on the facts, which made it appear that this all occurred only one year ago. Some of her documents did find their way into the hands of US law enforcement agencies, leading to speculation that the information may have been responsible for subsequent indictments of narcotics traffickers, the demise of HSBC, and the departure of Citibank from Panama.

 Her name is Jahaira M., for those who are still curious,  though I have omitted her last name to spare her hundreds of hungry journalists appearing at her door tonight. The most recent action, regarding the documents, that I am aware of is a contact she had in Germany, which may explain the appearance of the documents first at Sueddeutsche Zeitung. She is believed to still reside in the Republic of Panama; That is why I chose a photo of her that preserves her privacy.

Second, the sources may consist of more than one cooperating individual; we have previously covered the matter of the married Panamanian couple, he a wealth management officer at Mossack and Fonseca, she a former compliance officer there. It is not know whether he is still working there, so it is best that both of these individuals remain anonymous for now. I have deleted part of their last name; Mr. & Mrs. San***z.

They were active in what I can only describe as Panama's extreme nightlife scene, where my investigators first had contact with them; this was after Jahaira was hawking her emails and documents. The couple were also selling confidential MF documents, and again some found their way into the hands of US law enforcement, which probably contributed to subsequent arrests.

Therefore, we cannot say for certain that any one individual is the sole confidential informant that leaked the documents we now refer to as the "Panama Papers."

US SENATE BILL PROHIBITS INDIRECT IRANIAN ACCESS TO US DOLLARS

Legislation was filed this week in the US Senate, to prohibit Iranian access to the US financial system, and to ban offshore US Dollar clearing. The bill is intended to block any issuance of a license to conduct an offshore US Dollar clearing system for Iranian transactions, or to provide any such system with dollars.

The bill, entitled Preventing Iran's Access to United States Dollars Act of 2016, also provides for sanctions to be imposed upon any financial institution found to be participating in such transactions, and  is also reportedly intended to affirmatively restate that existing law prohibits the issuance of a license which will allow Iran indirect access to the US financial structure. Direct access has long been prohibited.

The bill's co-sponsors are US Senators Marco Rubio (Florida) and Mark Kirk(Illinois). readers who wish to access the complete text can do so by accessing the Senator's website:
http://www.rubio.senate.gov/ and choosing "Newsroom."

  

SECRET, NONPUBLIC BRANCHES OF MAJOR INTERNATIONAL BANKS EXIST IN PANAMA

       

This may be a good time to expose an underground aspect of Panama's banking structure. Above you is a photograph of the Global Bank Tower, located on Calle 50, in downtown Panama City. While the building's name obviously tells you who the key tenant is, there are other banks whose names, curiously, do not appear on the building list in the lobby. Do you wonder why that is so ?

I have identified the offices of two "closed door" banks at this address; one is a major international Swiss bank,  UBS, whose name you are familiar with. The other is one of Canada's biggest banks, Royal Bank of Canada.Neither office is open to the public; they turn in any walk-in visitors, who may venture in without an appointment. One must pas security scrutiny in the lobby to gain admittance. There are no names emblazoned on the office doors; only a low-key logo tells clients that they are in the right place, and not some anonymous Panamanian financial services firm.

They are not agencies, branches, or official rep offices of any kind, nor do they appear on any official SBP list of licensed financial institutions, of any type or designation. I know, because I have checked. Individuals who have been in these nonpublic offices have told me that banking business is indeed regularly conducted there for clients.

So why is everything hidden ? No licenses means that these "closed" facilities pay no taxes, nor licensing fees, to the Government of Panama. exactly how are they permitted to remain open ? While there is no ready answer, one should remember that Panama is one of the most corrupt countries in Latin America, along with Venezuela and Haiti. have illicit payments changed hands ? We cannot say.

Whether there are other international banks operating under the radar in Panama City is not known, but where there's smoke, there's frequently fire. I know that, if I am a compliance officer at a bank located in North America, or the countries of the European Union, I would be seriously concerned about the possibility that there are others, with a covert footprint in one of the world's most notorious centers for money laundering activity, and govern myself accordingly, when seeing transactions involving stops in Panama, for banks that otherwise have no branches there.

MEMO TO CAYMAN FINANCE: THE CAYMAN ISLANDS ARE INDEED A SECRECY JURISDICTION, DUE TO THE CONDUCT OF ITS FINANCIAL SERVICES COMPANIES

Today, in a detailed position paper, Cayman Finance, which generally speaks for the financial service industry of the Cayman Islands, went to great lengths to show that Cayman is not a secrecy jurisdiction, spelling out, in chapter & verse, how many ways Cayman maintains the standards consistent with the OECD, and the other major developed countries. Treaties and international agreements were listed in great detail, by Jude Scott, Cayman Finance CEO. This is all true; the Cayman Islands do follow international standards.

I beg to differ with Mr. Scott, not in the laws in effect, but in the reality on the ground; while the Cayman Islands may have signed all the appropriate agreements that demonstrate transparency, and comply with the financial standards of the developed world, its financial services professionals practice opacity, rather than transparency. They do this by routinely, and consistently, employing a method of operation which will guarantee that any inquiry into beneficial ownership will absolutely fail to succeed.

The technique has no established name; I will label it the BVI/Cayman Sandwich. Cayman financial professionals, regularly and constantly, form British Virgin Islands companies for their clients, the BVI company is then used to open Cayman bank accounts. What's wrong with this picture ?

Allow me to list the reason why such an arrangement is by no means transparent:

(1) BVI companies have bearer shares, which means that there are no written records of the names and residence addresses of shareholders, on the certificates of shares of stock. Whosoever holds the shares in his hands, owns the company, and all its assets, including bank accounts, wherever located. That's the reason tens of thousands of Mainland Chinese own BVI corporations; you cannot know who owns what with any degree of accuracy, as ownership transfer is unrecorded, and can occur multiple times.

(2) While technically BVI regulations require the financial services professionals to hold the names of the shareholders, and hold the stock as custodians, there is a loophole large enough to drive a truch through. A third party, known to be trusted and AML/ CFT qualified, can hold that information, relieving the BVI firm of that responsibility. Unfortunately, there are no specific qualifications required of this third party. What if it is a tiny firm, located on Pitcairn Island, or some other remote location, which conveniently cannot be reached by any form of subpoena or demand for information ?

(3) The method, which I have identified was common to the accounts of two of the victims in the Cayman Gang of Four scandal, one a retired lawyer, the other a retired accountant, worked like this: the clients were assigned a BVI corporation; directors were located in another country; bank account in a third country; this is the Modus Operandi of Cayman financial service professionals.

Therefore, nobody can be reached to identify the beneficial owner of the corporation that owns and controls the Cayman bank account. Yes, the Cayman Islands is not a secrecy jurisdiction, but the tactics of its financial service community imposes secrecy through trickery, subterfuge, sharp practice, and abuse, by domiciling the client's company in a secrecy territory.

Yes, the Cayman Islands have all the laws and regulations of a responsible international financial center, but the islands financial professionals pervert the system, using the time-tested BVI-Cayman Sandwich. Until that scheme is outlawed, opacity will continue to rule in Cayman.

MOSSACK'S COVERT GLOBAL SALES APPARATUS OPERATED UNDER THE RADAR

It appears that Mossack Fonseca's public relations campaign, aimed at disseminating disinformation, and denying the law firm's role in global tax evasion, money laundering, and global investment of criminal proceeds, is in high gear. We have MF partner Ramón Fonseca claiming that the source of the information was a massive hack of the firm's database, when in truth and in fact it was Fonseca's mistreated, spurned mistress, a former employee. who was the primary source of the information.

Most distressing is the fact that the law firm has been totally silent about its off-the-books, cleverly disguised international network of salesmen, hawking the virtues of the firm's services. What legitimate law firm does that ? None of the offshore services offered involved legal advice, merely tax dodges, wealth management of cash with no questions asked about source of funds, and investment of anyone's money, irrespective of their status as a government official, with ready access to public money.

While it is true that only attorneys, and law firms can form corporations, under Panamanian law, all this type of work is done by paralegal assistants, and the only advice proffered is a referral to the firm's wealth management, and other subsidiaries, who will hide the client's proceeds of crime.

look at these two examples of MFs opaque method of offering dodgy, non-legal services, to prospective clients overseas:

(1) Canadian investigators have uncovered a Vancouver corporation, ostensibly open for only one year, offering MF services, a decade ago. Here's the twist: even though the company is allegedly closed, it is still listed as an MF asset in some places, its telephone still works, and the Canadian attorney originally listed as the local manager has a long and dark history of involvement in suspect activities; he also maintains other vehicles for offshore work, not named as Mossack Fonseca subsidiaries. Just how much business is the British Columbia office conducting, and is it paying any taxes at all to Canada ? There was also a covert office in Toronto, located within a million-dollar condominium apartment in the city's financial district, operated by a "wealth manager."

(2) MFs Miami, Florida sales office is located in a Luxury condominium apartment on pricey Brickell Avenue. I cannot find any means of contacting it, nor the names of staff members. The Registered Agent is itself a corporation. It has no webpage, nor ascertainable email address. Exactly how are prospective clients to contact it ? The answer is: don't call us, we'll call you. One seriously doubts that this covert sales office files any US tax returns.

Multiply these stories 120 times, as related by a Mossack Fonseca wealth management staff members, and you have a good idea of how this law firm pulls in dodgy clients, with dirty money. Perhaps  Lic. Ramon Fonseca should cease and desist from his many pronouncements about his firm's total innocence, for we do not believe anything he says to the media at this point.  

FINTRAC FINES CANADIAN BANK A MILLION FOR AML DEFICIENCIES, BUT WILL NOT NAME IT

The Financial Transactions and Reports Analysis Centre of Canada, or FINTRAC, has imposed a CAD$1.1m civil penalty against an unidentified Canadian financial institution, for failing to report suspicious transactions, and for other compliance deficiencies. It is reportedly the first time that the Canadian anti-money laundering regulatory agency, has fined a bank.

The document has not been made available to the public, but according to sources with access, the fine was imposed for these defects:

(1) Failure to report an attempted or actual suspicious transaction.
(2) Failure to report receipt of CAD$10,000, in cash, or more, in a single transaction.
(3) Failure to report an electronic funds transfer of CAD$10,000, or more, to a destination outside Canada.
(4) Failure to report receipt, from outside Canada, of an electronic funds transfer of CAD$10,000 or more.
(5) Failure to apply written compliance policies and procedures, which must be kept up to date and approved by a senior bank officer

The exact amount of the fine was CAD$ 1,154,670 . To say that I am disappointed that FINTRAC has failed to disclose the name of the offending bank is an understatement. Many Canadian banks have US subsidiaries, branches, or agencies, as well as affiliates in the Caribbean, and both American & Caribbean bankers deserve to know that a bank they regularly deal with is not following banking best practices with regard to anti-money laundering policies and procedures.

 If this is a genuine effort to avoid reputation damage by the offending bank, I am not impressed, for the protection of the banking public certainly comes before the reputation of a guilty bank, and before the pockets of its shareholders. Someone needs to convey that message to the leadership of FINTRAC.

FRANCE IS PLACING PANAMA BACK ON ITS TAX HAVEN BLACKLIST

The Finance Minister of France, Michael Sapin, in a meeting of the National Assembly, has advised lawmakers that he intends to place the Republic of Panama back on the French list of uncooperative tax havens. The grounds appear to be the earth-shattering disclosures popularly known  as the Panama Papers, specifically the actions of the law firm of Mossack & Fonseca, in setting up offshore corporations for foreign nationals who were tax evaders.

 Sapin also noted for those at the meeting that Panama has failed to follow through on its commitment to the OECD to share tax information with the countries of the European Union. The automatic tax information exchange has been proceeding in schedule at other offshore financial centers, but Panama has resisted orderly cooperation.

515 Panama shell companies showed up in French criminal investigations in 2015, according to statements of the Finance Ministry, which has now opened a new investigation into aggravated tax evasion of it citizens, as the direct result of the Panama Papers scandal.

MOSSACK FONSECA'S BLANKET DENIALS HAVE NO FACTUAL BASIS

The partners, and the public relations people working for Mossack Fonseca, have gone to great lengths to claim that the law firm merely formed corporations and foundations for valued clients, and was not involved in their financial matters. In truth and in fact, MF was engaged in money laundering, as well as wealth management for their clientele, on a massive basis.

Forget about the whistleblower for a minute; let me introduce you to a Panamanian couple; We shall call them Sr. y Sra. S_____z. He is a wealth manager for MF, and his wife works as a compliance officer there, and they are Confidential Informants. This duo, who had a large amount of incriminating information from MF files, sought repeatedly to sell it to the highest bidder in Panama. Whether they found ready, will and able buyers is anyone's guess.

They also disclosed a some sordid details about MF, all of which the company is attempting to deny ever happened. Here's a sample:

(1) Mossack Fonseca employed over 120 sales staff, worldwide in its wealth management branch, whose sole goal was to sign up clients. Their illicit funds would first be laundered, through bearer share Panamanian companies, and then invested, so that the client would realize a regular return on his or her illegally-acquired assets. There was a division of labor; money laundering was handled by one division, and wealth management by another. Some these "investments" were arms trafficking into African countries caught up in civil wars;  many of the others were for illegal or immoral purposes as well.

(2) Compliance officers at MF were replaced and rotated every two months, which meant that nobody in compliance had the big picture about the clients who were engaged in criminal activities, or who were PEPs banking bribe & kickback money. This short-term replacement also meant that MF would not have to pay the ones who were let go severance, which is otherwise required under Panamanian employment law.

When the compliance officer ascertained that a new client was either a criminal, or subject to international or OFAC sanctions, or a corrupt PEP, management would tell her to disregard her information, because the Panamanian authorities would never discover that fact. Panama does have an abysmal record, regarding arrests for money laundering. Simply put, there are none. Remember also, that Ramon Fonseca himself, while trying to defend his law firm, admitted that it does not always know the identity of the beneficial owner of a corporation that it forms for "valued clients." We call that Willful Blindness, in the Money Laundering Control Act of 1986.

Therefore, when you hear from the spin doctors at Mossack Fonseca, remember that it does indeed engage in money laundering for dodgy clients, as well as investing their criminal proceeds. 

ALERT ON CAPITAL FLIGHT OUT OF PANAMA

Compliance officers at international banks, located in North America or in the European Union, should be on the alert for any attempts to transfers funds out of financial institutions located in the Republic of Panama today. The revelations, which are just now coming out, of the extent of the massive money laundering, orchestrated by the Mossack Fonseca law firm in Panama City, will force financial professionals to seek a safer haven for the dirty money of their clients.

Remember, the Mossack scandal includes not only organized crime money, but funds of corrupt government officials who took bribes & kickbacks, but also Politically Exposed Persons (PEPs) who profited illegally, on behalf of their patrons. Any sizable transfer of dollars is now suspect, unless and until you have clear and convincing evidence that taxes have been paid upon those funds, and know who the beneficial owner is.

Rumors have already been circulating to the effect that Canadian banks are not accepting any funds originating in Panama. You can expect similar red-lining in other jurisdictions shortly. The compliance issue is simple: knowing about the Mossack Fonseca scandal at this point, are you really safe in accepting any substantial wire transfer from a Panamanian bank, even if it is from a known client ? Given that PEPs previously thought to be legitimate and law-abiding are now listed by major news media, who have access to the raw data, you cannot take the chance; rejecting any funds at this time is the prudent move.

PANAMA LEAKS: DATA AT MOSSACK FONSECA LAW FIRM STOLEN AND TURNED OVER TO JOURNALISTS

This letter was reportedly sent out to a limited number of Mossack Fonseca clients recently; it recites that the recipients are not among those whose personal data was stolen by persons unknown to the firm.

Now its Panama Leaks; massive amounts of customer data, stored on the computers of the country's principal provider of corporations, Mossack Fonseca, has been stolen, and delivered to foreign journalists, who reportedly are planning on releasing  it as early as tomorrow (Monday). The data is believed to contain information on Panama companies, and bank accounts, held by foreign government officials, other Politically Exposed Persons (PEPs), and organized crime syndicates.

The public release of this information could result in widespread criminal charges against corrupt heads of state, and other officials who have banked the proceeds of illegal bribes and kickbacks they have received; there will be special attention paid to individuals who accepted money from American and British firms, to allow them to participate in lucrative business arrangements, as both the US & UK strictly enforce their foreign corruption laws.

Mossack Fonseca, already reeling being implicated in a major corruption case in Brazil, in which present or former government officials at the highest level are under criminal investigation, has also been in the news lately, due to allegations that senior officials in Malta hold secret banks accounts in Panama, facilitated by the Mossack firm. Investigative reporters are allegedly already to publish the names, and sordid details, of a large number of corrupt PEPs. Some television media are reportedly
planning on running stories early this coming week.

Panama insiders have said that the source of the information was not, as Mossack is reporting, an intrusion by hackers, but an inside job. A former female employee, with access to the data, was allegedly involved in an intimate relationship with a Mossack name partner. The relationship ended badly some time ago, and the employee exacted her revenge by going public with Mossack client lists and related data.

The impact of this leak cannot be underestimated; it will seriously undermine global confidence in the ability of Panamanian financial service providers to assist corrupt government officials, and career criminals, in hiding their ill-gotten gains, which is the major segment of the client base in such firms.  It is too early to know whether dirty money will now seek a different opaque harbor to be hidden.

US SUPREME COURT HOLDS ASSETS NOT CONNECTED TO CRIMES CANNOT BE FROZEN

The United States Supreme Court has ruled* that the assets of a criminal defendant, if not linked to his or her crime, cannot be frozen to pay fines & restitution if convicted, when those funds are needed to retain and pay defense counsel. The opinion, which was published on March 30, 2016, was a 5-to-3 decision, reversing the judgment of the District Court, which the Eleventh Circuit had affirmed.

The defendant, Sila Luis, of Florida, was charged with healthcare fraud, involving $45m in charges for services that were non-existent, or not needed. She had $2m in funds, which were not connected to her crime. The Court froze that money, but the defendant asserted that she needed it to pay her attorneys. The government wanted that money available, for fines and restitution, after her anticipated conviction.

The US Supreme Court held that the Sixth Amendment right to counsel was a fundamental Constitutional guarantee, while the government's interest in recovering those funds, while important, was trumped by the right to hire an attorney.  

Readers who wish to review the complete text of the Opinion can access it through the footnote below.
___________________________________________________________________
*Sila Luis vs. United States, Case No: 14-419 (S. Ct. 2016)

  

VENEZUELAN BULK CASH SMUGGLER RECEIVES 12 MONTHS FOR MONEY LAUNDERING IN ST. LUCIA

Some of the bulk cash seized

In what appears to the the first money laundering conviction in the East Caribbean island of St. Lucia, a Venezuelan national was sentenced to twelve months in prison, after the authorities found a treasure trove of cash in his hotel room, and within his stomach. Reglio Jesus Patino Reyes, a bulk cash smuggler, had dollars, Euros, Bolivars, and even some Chinese currency in his room, and more bulk cash was found when hospital action result in his expelling additional notes.

The significance of this case: money launderers continue to find ways to repatriate drug proceeds. The presence of Euros indicates that the money found was probably not earned in North America, but in Europe, which is seen as a developing, not declining, market for narcotics. Did he smuggle the bulk cash across the Atlantic, on a commercial flight, and is this now a major route for narco-profits returning to the cartels in Colombia and Venezuela ?

The other question this case poses; was the cash going directly into a Caribbean bank, or merely in transit south ? Some East Caribbean jurisdictions, which are not directly involved in the drug pipeline, are ideal for placement, and later transfer, of drug profits, due to poor AML programs, or local corruption. In any event, the authorities in St. Lucia are to be commended for their actions, and the courts for promltly convicting and sentencing the bulk cash smuggler.  

BARRED BY FINRA FROM SECURITIES TRADING, GARY LUNDGREN SETS UP HIS GROWN CHILDREN TO FRONT FOR HIM

                                           

Gary James Lundgren

Gary James Lundgren, who has been permanently banned from associating with any securities firm by FINRA, has chosen to defy the law, as handed down in the ruling of the National Adjudicatory Council. He has placed his two grown sons, James Lundgren, and ZacGary Lundgren, into unlicensed Panamanian shell companies, and through them, intends to trade securities in the United States. They are fronting for their father, who gives the orders.

According to sources with personal knowledge, Lundgren has given his sons rudimentary instruction in  securities trading, and is now engaged in passing all his own trades through the two of them, irrespective of the fact that neither son has a securities license, of any sort, either in the United States, or the Republic of Panama, which triggers another criminal offense. The Panamanian shell companies are not licensed to sell securities by the country's regulatory authorities. It is assumed that the sons, like their father before them, use the facilities of third parties, in the Continental United States, to effectuate trades.

ZacGary Lundgren

Inasmuch as trading in securities without a valid license, is a Federal felony, James Lundgren and ZacGary Lundgren, now join their father in the crime of acting as an unlicensed broker-dealer. The profits, which are criminal, when transferred through the global banking system, further implicates all three in money laundering, and conspiracy to commit money laundering, and securities fraud.

James Lundgren

The names of the new Panamanian shell companies engaged in illegal securities trading are not yet known, but we are searching  Panama's corporate records for that information. We shall endeavor to locate those names, and will publish them as soon as we have them in hand. We trust that JP Morgan, where Mr. Lundgren had most of his business and personal accounts, which he refused to show to FINRA, is reading this article, as well as those American regulatory and law enforcement agencies who have an interest in these three unlicensed individuals,