SPONSOR BANKS: SHOULD THEY CONSIDER REQUIRING AN EXTERNAL INDEPENDENT COMPLIANCE AUDIT IN ADVANCE OF POTENTIAL FINTECH RELATIONSHIPS?

Given the current position of American regulators, concerning the ultimate responsibility of sponsor banks, regarding the compliance programs of their fintech clients, and repeated reports that most fintechs do not operate AML programs at the banking best practices level, should they not have an outside, independent organization audit fintech compliance, in advance of any contractual agreement?

The period in which a sponsor bank has the most leverage upon a new fintech client is during onboarding negotiations; after the relationship has been established, its ability to achieve a 100% response from a new fintech declines sharply, as there is a lesser incentive to comply, and during the initial set-up period, both parties are occupied with the tasks necessary to connect.

Therefore, given the fact that the ultimate responsibility for effective fintech compliance lies with the sponsor bank, it is humbly suggested that it make an external audit of compliance one of the preconditions for entering into a relationship; the results, and what the fintech is willing to do to upgrade if and as necessary, will insure that established AML standards are in place. This places fintech leadership, rather than its subordinate compliance staff, in the role of seeing that its CIP and transaction monitoring programs pass muster.

Records of the audit conclusions could also serve to mitigate any regulatory issues in the future, as they would serve to document sponsor bank efforts to insure effective compliance standards.

ANATOMY OF CBI APPLICATION THEFT:READ THE TIMELINE OF EVENTS INVOLVING RIF TRUST AND LUGOLD

Readers who have inquired, regarding precisely how a sales executive at RIF TRUST boldly stole a CBI application fee from LU GOLD, a sub-agent acting on behalf of an applicant for a SAINT LUCIA CIP passport, can see for themselves from the Timeline that Lu Gold presented, seeking to clear up the matter. 

Neither RIF TRUST nor CARIBBEAN GALAXY GROUP ever repaid the funds, forcing Lu Gold, as sub-agent, to submit new funds to move its customer's application forward.

Whether the new anti-money laundering legislation now effective in the UAE will result in criminal charged against an RIF TRUST officials in this and other cases remains an open question.

SPONSOR BANKS: ADD A COMPLIANCE OFFICER WITH FRONTLINE FINTECH EXPERIENCE TO YOUR STAFF

As sponsor banks strive to improve the effectiveness of the compliance departments of their fintech partners, it may be beneficial to take a page from my unique background as a former money launderer-turned compliance officer. My skillset, acquired during a decade on the other side of the law, gives me a valuable perspective that is useful to compliance officers seeking to close loopholes in their programs.

Let's apply the same principle to the issues sponsor banks face, regarding their fintech partnerships. If they actually had someone on their compliance staff who had spent years inside a fintech compliance department, would it not serve to better improve their understanding of the special challenges that those people face when trying to adapt traditional AML and CIP policies to the unique fintech corporate culture? Fintechs at times are known to discourage effective compliance procedures, due to concerns over cost and delay of customer service issues, which sponsor banks need to fully understand, to provide workarounds and practical solutions.

Therefore, it is suggested that sponsor banks onboard an experienced compliance officer who has prior hands-on experience at a fintech; that individual would have more sensitivity to fintech concerns, which could improve the relationships, while at the same time have the ability to suggest solutions to the knotty compliance effectiveness problems that sponsor banks face daily with their fintech partners. Bring in someone who has that frontline experience, to add value to your compliance capability.

BOB LEVINSON, AL-QAEDA's SECOND MOST-DANGEROUS MAN, URANIUM, HEAVY METALS, AND AMERICA'S 2025 CAMPAIGN AGAINST VENEZUELA

Osama & Mustafa in Afghanistan

For those readers who wondered why I am now bringing up retired FBI Special Agent ROBERT LEVINSON, the American longest detained in the Middle East,
IS RETIRED FBI AGENT BOB LEVINSON STILL ALIVE IN IRAN?
https://lnkd.in/etx_fZ4f. he is part of a story carefully hidden from public view, but which is now relevant, as we watch the present American administration take military action against the Maduro regime in Venezuela, and question what its endgame really is.

Turn the clock back 20 years, to the Madrid and London terrorist bombings, and meet MUSTAFA SETMARIAN NASAR, a/k/a ABU MUSAB AL-SURI Al-Qaeda's Syrian-born leading theoretician, and the author of the organization's 1600-page definitive treatise, THE GLOBAL ISLAMIC RESISTANCE CALL. Setmarian was the known intellectual author of those attacks, according to Bob Levinson, when he enlisted yours truly as part of team that surveilled the fugitive terrorist, while under the protection of the Venezuelan government, as preparation for his eventual capture, done quietly by American agents, who then shipped him to Pakistan, so that Americans would not know that AQ had a senior leader in their backyard.

Now on to the connection with today's news; my team observed Setmarian at Venezuela's principal commercial seaport, supervising the illegal export, to Iran, of cargo believed to be Uranium, under international sanctions and control. At the same time, Iranian-controlled companies engaging inside Venezuela in what was publicly stated to be gold, but in truth and in fact was the extraction of Heavy Metals, were conducting a covert mission on behalf of the Iranian Government. Credit Bob Levinson for being one of the earliest to have eyes and ears on these operations. Whether his information-gathering operations resulted in his subsequent capture in Iran remain an open question, because Cuban Intelligence, working out of the Caracas headquarters of CANTV, the local telephone utility, were reading his emails, and most surely sharing that with Iran. I personally saw the list of compromised emails, and he was one of the very few Americans being spied upon in that manner.

Let's put this in 2025 context; should the Maduro regime fall, due to American saber-rattling, a government friendly to the US might be installed, one that would not only cease the deliveries of Uranium of a sworn enemy of the United States, but enter into a business relationship for the sale, to American tech companies of the Heavy Metals that they require. Foiling Iran, and at the same time creating new and lucrative commercial relationships, while achieving American foreign policy objectives; interesting to say the least.

IS FORMER FBI AGENT BOB LEVINSON STILL ALIVE?

It's the question that keeps me up night; is Robert Levinson, the retired FBI agent working an authorized intelligence gathering program for a group of obscenely ambitious CIA analysts, still alive in custody in Iran, after nearly twenty years? The US says it believes him to be dead, but our government's track record on honesty, when it comes to Bob, as he was known to his friends in the law enforcement world, is abysmal. Initially, the CIA reported that he had been tortured to death; later an opportunity to recover Bob was scotched when an American Secretary of State declined to make a favorable statement to the press. The case is a cover-up on steroids.

The backstory, regarding Bob's true mission in Iran, involving WMD, still hides in the classified shadows, as does the abortive Special Operations mission to extract him from his captors. In truth and in fact, there's so much more to the story than has ever been declassified, and perhaps a no-holds barred documentary is necessary to reveal it all, and to find a way to, for once and for all, determine whether he is still living in Iran, under House Arrest, and genuinely afraid to return to the United States, for reasons of his personal safety, or deceased.

Those of us who worked with Bob, and his family, deserve no less.

A YEAR ON, CONVICTED FORMER BVI PREMIER ANDREW FAHIE'S APPEAL IS SLOWLY MAKING ITS WAY THROUGH THE SYSTEM; IS HE WASTING THE ELEVENTH CIRCUIT'S TIME?

Fourteen months after ANDREW FAHIE, the appeal of British Virgin Islands' poster boy for corruption's ( Money Laundering and drug trafficking) conviction is just now seeing the trial transcripts being filed with the Eleventh Circuit, he is serving eleven years at Jessup FCI, with a 2033 release date.

With all that evidence at trial introduced against him, his chances of a reversal of the conviction appears to be small indeed.The question, therefore is, will be finally give in an cooperate with US law enforcement, to make an attempt to qualify for a Rule 35 Sentence Reduction. Rumours were flying at the time of his arrest that he has firsthand knowledge of criminal activity of other senior Caribbean leaders, in the BVI and also in ANTIGUA & BARBUDA. Perhaps he will decide the risks to his personal safety in the world of narcotics trafficking are acceptable, in exchange for a get-out-of-jail-free card. There are a number of sealed documents in the court file, post-trial, so it may be in progress. We will be watching the court docket to see whether his sentence is quietly reduced, without any press coverage.

CONSUMERS ACQUIRING CBI PASSPORTS FROM SIERRA LEONE AND SAO TOME & PRINCIPE MAY BE IN FOR A ROUGH RIDE: THOSE JURISDICTIONS HAVE MAJOR CORRUPTION ISSUES; IS IT SAINT KITTS ALL OVER AGAIN?

Applicants seeking these new African Citizenship by Investment passports should be painfully aware that public sector corruption in both SIERRA LEONE as well as SAO TOME & PRINCIPE are described as rampant, pervasive and endemic, even more serious than those we have succinctly described as occurring in the five Eastern Caribbean CPI/CIP passport states. Any of the individuals hawking the African CBI who does not disclose this is guilty of misrepresentation of material facts.

When corruption reign in a CBI-selling state, due diligence goes into the toilet, the moment bribes of government officials come out. Narcotics traffickers, money launderers, fraudsters, and all the Usual Suspects get their passports, irrespective of their criminal records; that's just how it works when underpaid and amoral government officials accept bribes to sell passports to unqualified applicants.

Every applicant for an African CBI passport is taking a risk that his travel document, which can be terminated at any time by a local court system or government administrator, without due process, will expose him to serious inquiry, and even interrogation, the moment he presents it at an airport of entry, seeking to evade the visa requirements of his home country's passport. Will these African passports become stigmatized, such as has now happened with Eastern Caribbean travel documents under scrutiny in Europe, we cannot say, but anyone foolish to think these new tools for evading visa requirements will be judged to be low-risk, is fooling themselves. The risks do not justify the investm

WILL NEW UAE MONEY LAUNDERING LAWS ON WILLFUL BLINDNESS HIT THE LEADERS OF DUBAI-ROGUE CITIZENSHIP BY INVESTMENT FIRMS?

If you follow new developments in anti-money laundering legislation, you know that the united Arab emirates (UAE) has updated its AML laws to include what amounts to what we Americans call Willful Blindness, where liability can arise where a person either actually knew, or it would have been reasonable for them to have known, about the illicit nature of funds.

Now pair that with an additional provision that provides for personal liability: Managers of legal entities can now also be subject to personal criminal liability in certain circumstances. How this will be interpreted will be of interest to those leaders of companies that have sold Eastern Caribbean passports for up to 60% discounts, which are illegal under the jurisdictions that issue them, and could constitute a Predicate Offense under the UAE AML/ CFT laws.

Will the UAE finally crack down on what has been a totally unregulated industry? Only time will tell, but we will be watching.

SHEER CBI MADNESS; NEW SIERRA LEONE PROGRAM WILL ALLOW REMOTE "RELATIVES" AND UNVERIFIED "BUSINESS PARTNERS" TO PIGGYBACK WITH THE PRIMARY APPLICANT !

Forty-two years after Saint Kitts' diplomat (and money launderer) WILLIAM HERBERT, JR. created the first functional Citizenship by Investment passport sales program, to offer to the Medellin Cartel, someone has just found a way to exceed his dark vision: the new, expanded SIERRA LEONE CBI scheme, as detailed in investment migration mouthpiece IMI DAILY, offers consumers the broadest definition possible of relatives, and even has a catchall category of Business Partners, without any qualifying factor of an established relationship. 

The country is a hornets' nest of rampant corruption; read the international media to verify.

Pure insanity; money launderers today must be booking the next available flight to Freetown ( being careful to cover their tracks), for it is the perfect storm in which to place career criminal clients ( with aliases, of course) and even themselves, as part of the crazy Friends & Family Sierra Leone scheme. I cannot wait until transnational white collar criminals, each holding this new career risk reduction device, start to get arrested around the globe. Is there no limit to the amount of pure greed behind these new African-based programs? has anyone considered the Unintended Consequences? I rest my case.

Nigerian wanted for murder who paid $25,000 for Sierra Leone passport showing him born in Freetown.

SPONSOR BANKS WOULD DO WELL TO SEE THAT REGULAR ADVERSE MEDIA SCREENING OF THEIR FINTECH PARTNERS IS CONDUCTED, AS PART OF A PRUDENT RISK REDUCTION PROGRAM

While we have been focused of late in concentrating upon the need for sponsor banks to insure, through a variety of ways, that their fintech partners create and maintain an effective program of AML compliance, there is another area that requires attention: regular adverse media screening of all fintech clients. It is in the sponsor bank's vested interest to periodically troll for adverse media, including social media, to watch for retail customer complaints, civil litigation, regulatory issues, employee or leadership disputes, and other negative news that might indicate legal, regulatory, personnel, or public perception problems.

Sponsor banks must be able to anticipate operational, financial, consumer and legal problems that may befall their fintechs, as they could directly affect account traffic, and even sponsor bank reputation, due to the fact that they are linked in a number of ways to their fintechs. Consumer complaints, and issues with fintech product reliability, could be directed at the sponsor bank where payments were processed, irrespective of fault or blame.

There are a number of outstanding adverse media screening programs and tools commercially available; some go beyond what had been described as straightforeward screening to providing context behind potential risks. Whatever program you choose, do so after careful consideration, so that you can analyze risk to your bank early on, before rapidly moving events overtake your ability to take corrective steps.

Of course, as a retired and reformed career money launderer, I am concerned with the possibility that fintech misconduct could constitute a predicate act supporting a money laundering charge against not only the fintech, but involving the sponsor bank as well.

If you, as a sponsor bank, aren't using an adverse media screening platform, prudent risk management dictates that you acquire one, and monitor any emerging fintech controversies that appear.

SHOULD SPONSOR BANKS CREATE INTERNAL CLINICS FOR THE COMPLIANCE STAFF AT THEIR FINTECH PARTNERS, TO INSURE THAT EFFECTIVE AML PROGRAMS ARE OPERATIONAL?

Given the fact that the compliance programs in place at many fintechs have come under attack, for being sub-standard or ineffective, especially when it comes to anti-money laundering, should not sponsor banks take the bull by the horn and conduct compliance clinics to remedy the deficiencies? Full day programs, offered specifically by each sponsor bank to its fintech partners, would focus on customer identification procedures, transaction monitoring, money laundering tradecraft, and other relevant subjects that have been identified as fintech compliance shortcomings, to elevate the proficiency of each individual fintech compliance officer, and thereby reduce risk levels at sponsor banks.

A one-day in person program, and definitely not virtual, would foster the frank exchange of information, identify specific problem areas, and serve as a forum for fintech compliance officer feedback. Sponsor banks should use not just their own compliance staff, but industry experts to round out the program and keep it interesting, which would attract attendees. A document confirming attendance, and certifying it, could be an Important part of the continuing professional education of those fintech compliance officers, as well as further develop the relationship between fintech staff and compliance officers at their sponsor bank.

Finally, since so much of what sponsor banks do in the compliance sector has mitigation relevance, such a program, when presented to regulators in responding to any future compliance issues, could even serve to reduce or eliminate ultimate civil fines and penalties contemplated by regulators; think seriously about establishing such a program.

SOME OF THE TRICKS UNETHICAL CARIBBEAN ECONOMIC CITIZENSHIP SALESMEN USE TO DIVERT APPLICATION FEES

If you followed the MSR Media cases, you know that many of the Chinese-controlled companies selling passports from the five Eastern Caribbean states had their customers send the application fees to banks in Singapore and Hong Kong, rather than into financial institutions located ion the Caribbean. As the result, it is conservatively estimated that at least four billion US dollars was diverted from Saint Kitts & Nevis and Saint Lucia CBI & CIP programs.

For those following the outright theft of client application fees in the current RIF TRUST INVESTMENTS/LU GOLD LTD. story, the Nigerian company was manipulated into delivering the money, in cash, directly into the hands of RIF executive DENNIS GUTTIG, JR., who also forged the client's signature on funds reimbursement instructions. Remember none of these salesmen, or the passport vendor companies, has any sort of professional license subject to regulation, nor is the investment migration field regulated by any country other than those which sell the passports, and those can only cancel the permit to sell. This business operates outside any legal control, with the consequences I have detailed above. It gives Caveat Emptor a whole new meaning.