US SANCTIONS IRAN'S LARGEST PETROCHEMICAL HOLDING COMPANY

The US Treasury Office of Foreign Asset Control (OFAC) has sanctioned the Persian Gulf Petrochemcial Industries Company, also known as PGPIC. The stated reason was that PGPIC provides financial support to the engineering component of the Islamic Revolutionary Guard Corps. In addition to PGPIC, thrity-nine of its subsidiaries and agents have also been designated.

The names of the subsidiaries can be located here.

CANADA: ESTIMATE OF MONEY LAUNDERING BY PROVINCE

This graph is based upon estimates, by province. The actual amount, most of which consists of the proceeds of crime laundered through real estate purchases, may be higher. Please note that the sums are in Canadian Dollars ($CDN) in billions.

COMPLIANCE PROGRAMS ARE NOT AFFECTED BY MUNICIPAL RESTRICTIONS ON FACIAL RECOGNITION SOFTWARE USE BY LAW ENFORCEMENT

If you are a compliance officer at a bank that is employing facial recognition software systems in your Customer Identification Program to verify identity, non-PEP status and correct legal name of new or prospective clients, do not be overly concerned by news regarding municipalities, or even states, passing statutes banning its use. Those laws are specifically directed to law enforcement and other government agencies who are using CCTV footage in mass surveillance programs, where the targeted individualS neither know of, or consent to, its use.

The use, by private industry, of facial recognition software, where the individuals involved give informed consent to its intended use, is outside the scope of the new legislation. Therefore, if you are deploying a facial recognition software platform to search social media, social networking sites, the Internet and image databases, to identify a new or prospective bank client, consent should be obtained.

It is humbly suggested that your counsel prepare a consent form, to be signed by new clients at account opening, or upon application, in which the client acknowledges that, in order to properly identify them, additional measures will be employed, including but not limited to facial recognition software, social media & social networking, Internet searches, database searches,and other resources. Consider this only broad guidelines, as your counsel may be aware of additional or alternative language that is more appropriate or relevant.

Compliance officers, at financial institutions, who are not currently using facial software programs searching social media, Internet and image database resources, to properly identify their customers, should seriously consider obtaining such a program, as the failure to effectively verify customer identity is generally considered compliance malpractice by regulators.

LEST WE FORGET: BOB LEVINSON STILL HELD IN IRAN SINCE 2007

WHEN USING FOREIGN NEWS ARTICLES FOR ENHANCED DUE DILIGENCE, USE PRESS FREEDOM CHART TO ASCERTAIN RELIABILITY OF INFORMATION

If you are a compliance officer conducting an enhanced due diligence inquiry on a new prospective foreign bank client, and you are accessing media from his or her country, one of the ways you can judge whether the material you find is reliable (or truthful) is the degree of pres freedom in that nation.

Here is the latest Press Freedom Chart; with it, you may ascertain the extent of press freedom that exists in the client's country. Given that many non-democratic nations either censor news about corruption among government officials, or PEPs, or self-censorship is practiced by press in other with similar totalitarian governments, you may use the chart to validate the level of accuracy of negative  information you obtain from that country.

Alternatively, where there is absolutely nothing available about your client, from a non-democratic jurisdiction, you may not draw the conclusion he or she is clean. You then must seek out information from other sources, in countries known for press freedom, and lack of government interference in media coverage.

Sometimes, even this chart and your other public sources are not helpful; in that case, you must entertain whether non-public sources must be enlisted to get to the truth about your new, affluent and promising, client.

READ THE 107-PAGE PRIVATBANK COMPLAINT AGAINST FORMER OWNERS FOR MONEY LAUNDERING AND FRAUD

If you read our recent article, Ukraine's Government-owned Privatbank Sues its Former Owners for Money Laundering and Fraud, you may want to read the 107-page Verified Complaint. You may access the complete text here.

JAMAL SAEED ABDUL RAHIM, PALESTINIAN HIJACKER

CORRUPT PALESTINIAN AUTHORITY OFFICIALS FUNDING HAMAS IN MALAYSIA

Reports from Israel confirm that corrupt senior Palestinian Authority officials are moving PA funds to Malaysia, where they are used for Hamas terrorist training there. The money, obviously diverted from Authority accounts, is laundered through Dubai, and thereafter into Malaysia.

The senior PA leaders named as players in the terrorist financing operation are:

(1) Dr. Mahmoud Al-Habash, the Supreme Sharia Judge of the Palestinian Authority; he also holds the titles of PA leader Mahmoud Abbas Adviser on Religious and Islamic Affairs, and Chairman of the Supreme Council for Sharia Justice. He is said to have formed shell companies for the movement of the proceeds of corruption  out of the West Bank, through Dubai and to Malaysia. His bureau chief is listed as Khaled Barude. Hamash is known to be display a violently anti-American perspective.

Habash

(2) The Ambassador of the Palestinian Authority to Malaysia Anwar Al-Agha. His now ex-wife reportedly divorced him when she discovered he was using her as an officer in his shell companies without her knowledge and consent.

Al-Agha

(3) These two conspirators are linked to Hamas member Fatah Al-Nuri, a businessman now living in Algeria, and Yasser Abbas, the son of Mahmoud Abbas; these two individuals are also involved in terrorist financing. Another close associate is the PA Ambassador to the Sudan, Abed Al-FatahAl-Satri.

The Prime Minister of Malaysia, Mahathir Mohamad, who is known to have close links to Hamas,is presumed to be facilitating Hamas operations, and providing material support to Hamas, which is a global terrorist organization.

We have previously reported on Hamas military training camps in Malaysia; we now know how they are financed.

FRAUDSTER SENTENCED TO EIGHTEEN YEARS FOR IMPERSONATING SAUDI PRINCE IN $8m SCAM

 
Anthony Gignac, whose convincing impersonation of a Saudi Prince allowed him to fleece investors of over eight million dollars, was sentenced this week, in a Miami courtroom, to eighteen years in Federal Prison. Gignac, who scam came complete with fake diplomatic license plates, bogus DSS identification for his "bodyguards," all the the trappings of a billionaire, used these tools to trap willing investors into paying him for non-existent global projects.

The "investments" he offered included participation in Saudi Aramco, the government-owned oil company, casinos, a pharmaceutical company, and hotels. all of which were fictional. Gignac used the money to live an opulent, private jet, luxury car existence, including a pricey unit on Miami's exclusive Fisher Island. He is a resident of South Florida.

Readers who wish to learn more details can access the Department of Justice press release here.

READ NEW OFAC TERRORIST ASSETS REPORT

The 2018 OFAC Terrorist Assets Report was just released on the Treasury website. You may review the complete text here.

MUHAMMAD ABDULLAH KHALIL HUSSAIN AR-RAHAYYAL, PALESTINIAN HIJACKER

SERVING 660 YEARS FOR LAUNDERING MONEY FOR CALI CARTEL, HE SEEKS COMPASSIONATE RELEASE

Attorneys for Stephen Saccoccia, who is currently serving 660 years in Federal Prison for laundering narcotics profits for the Cali Cartel, have filed a motion in US District Court in Rhode Island, seeking compassionate release, pursuant to the new First Step Act,  a prison reform law which allows judges to release elderly nonviolent prisoners under extraordinary circumstances, especially if they have health problems.

Saccoccia, a former high school mathematics prodigy, reportedly laundered more than $135m for the cartel; he has already served twenty seven years. His sentence included a $16m fine, and forfeiture of $136m of assets. His wife was also convicted, but served only 14 years and was released fifteen years ago. Saccoccia received the maximum sentence permitted by law. His release date is October 17, 2567; he is presently at the Federal Penitentiary in Coleman, Florida.

The courts have previously denied Saccoccia the right to retain assets which were part of the forfeiture judgment. His assets included money held in safe deposit boxes abroad, and 83 gold bars, found buried behind the home of his mother.

The US Attorney in Rhode Island, who is disputing Saccoccia's claims of serious health problems, as well as his other grounds, is opposing release due to the seriousness of the crime, and has requested a delay to determine whether the warden at the prison where he is incarcerated actually received his request for release.

SHOULD COMPLIANCE OFFICERS CHECK SOCIAL MEDIA ON NEW FOREIGN CLIENTS ?

Now that the US State Department is requiring visa applicants to disclose their social media and email addresses, and given the current ability of foreign applicants for bank accounts to conceal their true identities, should bank compliance officers now also obtain social media and social networking information on new foreign clients, and employing a facial recognition software program, verify client identity, as well as check for potential PEP status or terrorist affiliation ?

If the US Government deems social media information to be so important that it now orders it to be divulged on visa applicants, that should convince compliance officers of its importance in the due diligence process. As a risk reduction tool, the verification of a new customer's true full legal name, using facial recognition on social media and other Internet resources, will greatly minimize the possibility that the client is using an alias, or is otherwise unsuitable for onboarding for a number of  important reasons.It will essentially rule out the client as high risk.

New accounts staff are advised to revise their account application forms to include social media user names, Internet websites and blogs, and any relevant social networking information, as an integral part of the customer identification procedure. Should you fail to do so, and money launderers, hidden PEPs, or terrorist financiers obtain accounts, and abuse them, compliance officers may be looking at a future finding of compliance malpractice, or regulatory action.

JUNE 4, 1989 TIENANMEN SQUARE BEIJING JUNE 4, 1987

READ FBI REPORT TO CONGRESS ON SHELL COMPANIES

Steven D'Antuono, the Acting Deputy Assistant Director of the FBI's Criminal Investigative Division, gave an exensive Statement to the US Congress on May 21, 2019, entitled Combating Illicit Financing by Anonymous Shell Companies. We consider it recommended reading; you may access the complete text here.