SPANISH CLAIMS OF MONEY LAUNDERING BY KOKOREV FOR OBIANG REFUTED BY US STATE DEPARTMENT WHITE PAPER

We continue to analyze the story behind the illegal actions of Spanish prosecutors, in the Canary Islands, to frame Russian businessman Vladimir Kokorev, employing money laundering charges that have no factual basis. The evidence is simply not there, but Spain believes that a conviction of Kokorev will eventually lead to the removal from office of Equatorial Guinea President Teodoro Obiang.

Thanks to Wikileaks, an unclassified white paper on Equatorial Guinea,* written at the US Embassy in Malabo, which presents facts that refute the allegations of corruption in the country, is publicly available, on the Internet. This document details the history of Equatorial Guinea, which dispel and controvert Spain's allegations of massive corruption and money laundering. We recommend that you study it; for those whose time is limited, here are the major points:

(1) In the early days of independence, EG had insufficient funds to pay its government employees their full salaries. They received much of their compensation in kind, lands, the exclusive right to operate certain industries or businesses, and other material benefits, in lieu of cash. That is why government officials, staff members, and employees, have commercial enterprises, in addition to their official positions.

Before oil brought wealth to EG, many government employees worked only three days in their official capacity, and were busy earning a living during the remaining days. Post-oil development, many of these part-time businesses, land holdings, and other assets conferred upon them made them very wealthy. There was no theft of government property or assets.

(2) Therefore, EG has no conflict of interest laws on the books, Claims that ministers or relatives of the president, who themselves work in government, had illegal private industry holdings, is completely untrue. Those "moonlighting" government workers were, and are, not breaking the law.

(3) Lastly, the claims that the president illegally transferred oil profits, through EG accounts at Riggs Bank, to Kokorev, as part of a money laundering conspiracy have no basis in fact. President Obiang ran his country's finances directly, when EG had a tiny economy, requiring his countersignature on checks, to control the limited treasury. and he continued to control funds payments. He did not divert funds for his own family's use, but was paying Vladimir Kokorev for maritime and fishing services that he provided for EG.

As you can, there are major financial and cultural differences between the West, and Equatorial Guinea. In truth and in fact, EG is the largest funds contributor and depositor to the region's central bank, meaning that oil profits are being saved, not diverted to corrupt and greedy PEPs. Spain's carefully contrived money laundering scenario, involving Kokorev and Obiang, has no basis in fact; it  is a fiction presented solely for the ultimate financial gain of powerful Spanish corporations, whio want a large piece of the EG petro-profits for themselves.

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*http://wikileaks.org/plusd/cables/09MALABO27_a.html

CIMA DUCKS MEDIA QUESTIONS IN CAYMAN GANG OF FOUR SCANDAL

The Cayman Islands Monetary Authority, commonly known as CIMA, has responded to Cayman media questions, regarding its actions, or lack of them, regarding the $450m financial scandal perpetrated by local financial professionals known to the public as the Gang of Four. CIMA stands accused of ignoring its responsibilities, in properly regulating, subsequently investigating, and failing to enforce Cayman law, and assist the victims, who are Canadian and American retirees and pensioners.

Here are the details of CIMA's specific responses to media queries. Kindly note that no officer or director or CIMA made themselves available to the press. Instead, CIMA sent a public relations officer, whose answers were totally non-responsive to the reporter's questions.

(1) Articles critical of CIMA'S total lack of response to the financial scandal, deemed by many to be one of the largest ever seen in Grand Cayman, were said to be "inaccurate" and "misleading," in a number of material aspects, though no specific details were offered in rebuttal. The CIMA spin-master stated that "legal constraints" precluded it from providing details sufficient to "dispel those inaccuracies." Again, confidentiality is used as a shield, to allow it to evade answering tough questions.

(2) The CIMA statement, that has fully cooperated with all North American regulatory and law enforcement agencies, is totally false. CIMA staff members stonewalled Canadian regulators on all their questions, stating that all the information was "confidential," ducking behind local regulations not ever intended to deny information to regulators or law enforcement.

(3) CIMA did state that it was acting "in the best interests of the jurisdiction." This is a clear indication that CIMA has little or no regard for foreign investors, who end up as victims of Cayman-based white-collar criminals. Nowhere in the CIMA response to questions was any reference to the victims made; only that it would protect the Cayman Islands.

(4) Finally, the press aide stated that CIMA was "acting within its legal mandate." It does have a mandate to protect the investing public, and enforce the laws of the Cayman islands. Six months after it received conclusive evidence of massive fraud, theft, failure to discharge a fiduciary responsibility, acting as an unlicensed bank, and other crimes and regulatory violations, CIMA has failed to take any steps to close down B & C Capital Ltd., bring criminal charges against Sharon Lexa Lamb, Ryan Bateman, Derek Buntain, or Fernando Moto Mendes, the Cayman Gang of Four.

When a group, which included one of the victims, brought this to CIMA's attention last Summer, the most revealing comment made at the time, by a CIMA staff member, indicates the agency's disdain for victims: " They're only tax evaders." The truth is, the ones I know aren't.

If a regulatory body fails in its duties, it should be dissolved, and its leadership sufficiently publicly reprimanded, so that they cannot simply lateral over to a local bank or financial service firm. Either CIMA should be dismantled, or taken over by a UK supervisory body. If that cannot be accomplished, then perhaps the Financial Action Action Task Force should place the Cayman Islands back on its Non-Cooperative Countries and Territories (NCCT) List, until this happens. That's the FATF Blacklist, which is where jurisdictions that cannot police themselves belong.

BOGUS MONEY LAUNDERING CHARGE IS SPAIN'S THIRD ATTEMPT TO CONTROL ITS FORMER AFRICAN COLONY

Readers who may have wondered why Spanish prosecutors are seeking to bring charges of money laundering against Vladimir Kokorev, that are for legitimate transactions from a dusty decade ago, and which were previously found to be bogus, by a court of competent jurisdiction, need to know that this represents the third time that Spanish interests have sought to reimpose Spain's influence and interest in Equatorial Guinea (EG), its former colony.

(1) Most are familiar with the unsuccessful 2004 coup d'etat against EG, which fell apart when a band of South African mercenaries, intent upon invading and conquering the country, for then unknown parties, were detained in Zimbabwe, while literally en route to EG, to seek the overthrow of the present government. Most public accounts state that certain private British interests allegedly funded the operation, with the expectation that they would share in lucrative oil contracts.

What is not generally known is that two Spanish navy vessels were cruising offshore, actually in EG territorial waters, with 5000 Spanish troops on board. After the mercenaries had attacked, deliberately causing extensive civilian casualties, the Spanish soldiers were to be landed, and act as "peacekeepers." Spain would them bring EG back into its sphere of influence, with certain companies owned by prominent Spanish families taking a large share of the oil profits.

The confidential details of this coup may finally be made public in 2016, as according to UK media, a well-known British attorney, specializing in human rights cases, has been retained to bring a civil suit, on behalf of Equatorial Guinea, against the coup plotters and supporters.

(2) The 2004 Riggs Bank scandal, which involved a $25m fine, for Bank Secrecy Act violations, none of which were for any acts of the bank regarding its Equatorial Guinea accounts. The fine was levied solely for the bank's involvement with Chilean President Pinochet, and his attorney. In that investigation, Spain unsuccessfully sought to have payments made through Riggs, to accounts at Spanish banks as improper or illegal. The US Senate investigation made no such finding, nor did FinCEN or the Office of the Comptroller of the Currency, or there would have been a fine imposed.

(3) This brings us to the Kokorev case; though no criminal charges have been filed, Spanish authorities in the Canary Islands continue to hold Vladimir Kokorev, as well as members of his family. They are, according to official reports, only needed as Material Witnesses, but have not been allowed to bond out, notwithstanding that they previously resided in Spain for several years. They do not represent a danger to the community, nor are they flight risks, as Vladimir Kokorev is aged, ill & infirm. Also, their arrest and extradition from Panama was an extreme measure, to say the least, and it may later found to have been contrary to Spanish law.

Clearly, this money laundering investigation, which was brought far from Madrid, to shield the details from the public, and not because some of Kokorev's properties are located there, and which has no factual basis, is part of a continued plan by powerful interests in Spain, to take a share of Equatorial Guinea's lucrative oil industry profits. It is only the latest effort by Spain to exploit its former colony's natural resources, post-Independence, by creating an international scandal that could result in international sanctions against the current EG government, and its president, and hasten its collapse, by affording Spain an opportunity to regain its influence there. The bogus money laundering case is only a means to that end.

CONCEALED NATIONAL ORIGIN IS A FACTOR IN ASSESSING CLIENT RISK AT ACCOUNT OPENING

Where a prospective client comes from is one of the tools we use in accessing suitability at account opening; that is a given. What is often overlooked is the fact that sometimes, due to world events, the client comes from a specific country, and even has a passport to prove, it but his origin is really elsewhere. Is he (or she) really from a high-risk jurisdiction, to the point where enhanced due diligence is called for ?

 Compliance officers sometimes need to dig below the surface:
(1) Does the client's language ability ( accent/ use of slang phrases/grammar) match those that you generally attribute to someone from that country.
(2) Was the client born in another country ?
(3) Is his family name inconsistent with those you expect to find from that jurisdiction ?

Here is an illustration; This week, the United States indicted two Iraqi Middle Eastern immigrants, one of whom came from Iraq, and the other from Syria, on terrorist charges. Political correctness aside, neither of their individuals were ethnic Iraqis. Both were actually from Palestinian families that had settled there. Some major media failed to add this important detail in their coverage.

For client risk purposes, this make a huge difference. Both the Palestinian Authority (PA), which has  limited government in the West Bank (Judea & Samaria), and Hamas, a designated terrorist organization in power in the Gaza Strip, are utterly corrupt organizations, whose officials become millionaires by diverting aid funds to their personal use.

Furthermore, both regimes are notorious for spewing anti-West, anti-American and especially anti-Semitic propaganda, on a global basis, meaning that both of these two arrested individuals were probably exposed to anti-American hatred from an early age. Some Palestinians become so brainwashed that they become terrorists, as we painfully know from reading the news each day.

 We classify Palestinians opening bank accounts in Western banks as high risk for the above reasons. some are expelled from Israel, for criminal or terrorist activities, and could end up at your bank. In the Middle East, other countries remember that Palestinians were expelled from Kuwait, after the First Gulf War, after the PA allied itself with the Hussein regime, which invaded that country.

Therefore, always look underneath a passport when seeking to determine exactly who the new client is; Things are seldom what they seem, "skin milk masquerades as cream."

DHS SAYS SUB-STANDARD DRIVERS LICENSES ARE GOOD FOR TWO MORE YEARS

The Department of Homeland Security, which is supposed to enforce the 2005 Real ID Act, which mandates tamper-proof & counterfeit-proof state drivers' licenses, have given the non-compliant states two more years to deliver them to their residents. This is after some states have already obtained two prior extensions of time to comply. Costs, partisan politics and data breach fears have contributed to the already unhealthy delays, which means raised risk levels for bank compliance officers.

Some of the states object to the increased costs, others, who have issued licenses to illegal aliens, have political reasons, for only legal residents & citizens are eligible for Enhanced Drivers' Licenses; still others assert that prior data breaches represent a well-founded fear.

If you have not already read my earlier article, published on January 3, 2106, you may want to scroll down the page and read it. Money launderers and terrorists, who can easily obtain bogus drivers' licenses in the non-compliant states, can open accounts at your bank. As I have previously stated, compliance officers should not longer accept the non-compliant DLs as primary identification, and you may want to require that ALL new accounts applicants give you a supplementary document, even those with compliant licenses.

In my humble opinion, driver's licenses run a poor second to passports for identification purposes. Many Americans have one. Concealed firearms permits, military IDs, and other official types are available; use them if you can.

INVESTORS: STAY OUT OF PANAMA IF YOU ARE NOT BILINGUAL

Many expats from Canada & the United States have been relocating to the Republic of Panama in the past several years, and the country has attracted its share of investors. If you are not fluent in Spanish, the risk that you will sustain a financial loss there rises exponentially; here's why.

If you are cheated by a financial criminal, or have a dispute in a legitimate business transaction, the court system, rotten with systemic corruption, will probably shock you. Since all court business is conducted in Spanish, you will need an official interpreter to participate in any court case you bring in the Republic of Panama, whether you are testifying or not.

Defense attorneys know this, and they throw down roadblocks, so that plaintiffs will never go to trial in their cases. Allow me to explain:

(1) The official reporter never shows up for court hearings, and your case is delayed for years, as it cannot progress. They are often bribed not to attend.

(2) Defense lawyers bribe judges' staff, and the judges themselves, to see that the designated interpreter never appears at scheduled hearings. Judicial assistants, suitably bribed, call up the interpreter at the last minute, and advise that the hearing has been cancelled.

(3) Attempts by plaintiffs' attorneys to substitute other interpreters are denied by the Court,probably because  the judge has been repeatedly bribed to delay the case indefinitely.

Therefore, unless you speak Spanish fluently enough to participate in a judicial proceeding, do not take the extraordinary risk of investing in Panama, because any case you file will never go to trial. 

IS VIKTOR BOUT SEEKING TWO BITES FROM THE SAME APPLE ?

As we have previously reported, Viktor Bout's motion for a new trial, and for an evidentiary hearing, was denied by the trial court. As expected, his counsel, Alexey Tarasov, has taken appeal. The question arises: will he limit his argument on appeal to the newly-discovered evidence grounds upon which he brought the motion for a new trial, or will he attempt to revisit his original appellate issues ?

Bout's appeal to the US Court of Appeals for the Second Circuit resulted in his conviction being affirmed, and he failed to seek Certiorari to the US Supreme Court. Since there is some overlap between his original appellate issues, and the points he made in his motion for a new trial, it will be interesting to see how his counsel frames the issues, and what the response of the US Attorney's Office in New York is. A Federal criminal defendant technically does not get two bites from the appellate apple, as a matter of right but in this instance, it appears to be precisely the case.

CIMA HAS JURISDICTION OVER FRAUDSTER B & C CAPITAL, BUT IGNORES ITS LEGAL RESPONSIBILITIES

CIMA's primary occupation ?

The Cayman Islands Monetary Authority has denied that it has jurisdiction over B & C Capital, Ltd., Ryan Bateman's Cayman corporation, that stole over $450m from investors, on the grounds that it is an Exempted Company. Unfortunately, CIMA has chosen to ignore specific Cayman laws that govern its regulatory authority, and the result is that it has washed its hands of any involvement in the Cayman Gang of Four trading scandal, leaving a large number of North American investors and pensioners high and dry, and broke. It is simply hiding its head in the sand, and failing in its duties.

An Exempted Company is defined, under the Companies Law of the Cayman Islands, as one whose business is to be carried out mainly outside the Cayman Islands. B & C Capital, Ltd., is currently managed full-time by an individual with a dodgy background, Fernando Moto Mendes, maintains its sole office in Grand Cayman, with staff, has a Grand Cayman telephone number, and holds itself out as a trader in securities and other investments from that office. For CIMA to claim that it was based offshore, and therefore an Exempted Company outside its jurisdiction for regulatory purposes, is inaccurate, and has no basis in fact.

CIMA appears to have conveniently interpreted the law so as to allow it to ignore the vast majority of frauds, Ponzi schemes, and money laundering operations that occur in Grand Cayman on a regular basis. It has chosen to improperly claim it has no jurisdiction, and therefore, cannot aid the many victims of Cayman islands white-collar crime, all of whom trusted that their investments, or retirement assets, were safe and secure in the Cayman Islands, which uses the fact that it is British territory to attract capital.

CIMA staff meeting ?

 An offshore financial center with a negligent and ineffective regulator is neither safe nor secure, as the victims of the Cayman Gang of Four have learned, to their detriment.  

BOTH SIDES REQUEST ORAL ARGUMENT IN RICHARD CHICHAKLI APPEAL

Both Appellant and Appellee have requested Oral Argument in the appeal of Richard Chichakli's  Federal conviction for sanctions violations. The US Attorney's Office filed its motion in November, right after the Brief of Appellee was filed, and Chichakli's counsel followed suit in December. The case is pending before the United States Court of Appeals for the Second Circuit , which hears all arguments in New York.
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CAYMAN ISLANDS MONETARY AUTHORITY REFUSES TO ASSIST NORTH AMERICAN AGENCIES INVESTIGATING $450m CAYMAN GANG OF FOUR SCANDAL

Investigators at a North American regulatory & law enforcement agency are reportedly incensed that the Cayman Islands Monetary Authority, CIMA, has refused to supply any assistance to them, in connection with an investigation of the theft of close to a half a billion US Dollars, in the Cayman Gang of Four case. CIMA officials have declined to make any information available, regarding banking transactions, claiming that such data is confidential, though some legal observers advise that the Cayman agency has the authority to render the cooperation requested.

CIMA, which has known about the loss of funds for at least six months, has not interviewed any of the alleged perpetrators, all of whom are Cayman residents, though most have subsequently fled, and gone into hiding. It has not closed down B & C Capital, Ltd., a shell company that held itself out as a "bank," and received the assets of as many as 60 Canadian and American retirees and pensioners. B & C's surviving Managing Director, Fernando Moto Mendes, remains on Grand Cayman, but CIMA has taken no action against him, notwithstanding his prior spotty record as a financial services agent.

Some whistleblowers have called for CIMA, which reportedly has at least a dozen unresolved fraud cases pending, to be taken over by the UK Foreign & Commonwealth Office (FCO), for malfeasance in office; others assert that CIMA should be dissolved, and replaced by a more effective agency; the fact that its large staff has failed to complete multiple investigations, which are incomplete after several years, is prima facie evidence that it is ineffective. Reports that official US & Canadian investigations of the Gang of Four case are in progress continue to surface, which could further embarrass CIMA, should they take action, where the Cayman regulator does not.  

POWERFUL FORCES IN SPAIN COMBINE TO FRAME RUSSIAN BUSINESSMAN FOR MONEY LAUNDERING

Readers of this blog who who have seen the article, Who framed Vladimir Kokorev for Money Laundering?* , need to understand the historical context behind the case, the amount of effort that has been expended to falsely implicate Mr. Kokorev, and his entire immediate family, in a case specifically designed to ultimately bring down the current government of Equatorial Guinea, and the underlying reasons for this well-orchestrated effort. The answer is complex, due to the fact that the players have chosen to remain in the background, and exert their power, opaquely, behind the scenes.

Who would benefit most from a conviction for money laundering against Valdimir Kokorev, and how does such a case affect Equatorial Guinea ? To answer that, we need to examine the history of that nation. When it was a colony of Spain, Equatorial Guinea was exploited for timber, cocoa and gold production, by the powerful families that dominate the economy of Spain, though it was not known to be one of the country's most lucrative overseas possessions.

Long after it was granted independence, Equatorial Guinea was found to have major deposits of oil and gas, which were developed with assistance from, and in coordination with, some of America's largest petroleum companies. Equatorial Guinea became one of sub-Saharan Africa's leading producers of oil, which has resulted in an extraordinary increase in national income.

This newfound wealth has reportedly drawn the economic elite class in Spain, who covet the massive income, as well as petroleum being extracted.and exported to world markets. Unfortunately for Spain, its overtures have been rebuffed, and Equatorial Guinea has allied itself withe the United States, whose oil companies are largely responsible for the country's vastly improved economy.

These Spanish interests believe that, should they be able to effectuate a change in the government in Equatorial Guinea, that they could gain entrance into a share of the country's oil production, and revenue. Powerful enough to influence Spanish prosecutors, these interests have revived an old, discredited allegation, concerning payments made to Vladimir Kokorev, a Russian businessman who was engaged in substantial business transactions with Equatorial Guinea.

Through a Kokorev conviction, Spanish interests hope to ultimately obtain global sanctions against EG President Obiang, and thereby to drive him from office. Spain would then install an EX expat more cooperative with its elite, resulting in a renewal of the flow of lucrative profits from Equatorial Guinea one again.

We will be closely following the Kokorev case on this blog; stay tuned.
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*http://rijock.blogspot.com/2015/11/who-framed-vladimir-kokorev-for-money.html

"WHEN THE BEST LAID SCHEMES" IN A MONEY LAUNDERING PROSECUTION "GANG AFT AGLAY"

The Department of Justice wins the vast majority of money laundering prosecutions brought in US District Court for the simple reasons that the preceding investigations, which often takes several years, generally result in the acquisition of a large body of incriminating evidence, which is more than sufficient to convict the defendant. That's why you rarely read an article about a judgment of acquittal in a money laundering case.

It is important, but not a requirement, that prosecutors have the documentary evidence in hand, prior to seeking an indictment, though it is possible to obtain an indictment without a smoking gun. The testimony of Federal law enforcement agents, or Cooperating Individuals may be sufficient, when made before a Grand Jury, to obtain an indictment.

You do finally need that evidence, through, at trial, and we shall now discuss a recent case, where the failure to timely obtain the same timely had fatal consequences for prosecution of money laundering charges. I will omit any details, which would allow you to ascertain the court or parties involved, lest it embarrass the prosecutors, or agents. involved, or defame the defendant, who does enjoy the presumption of innocence, notwithstanding the allegations, especially since he was not convicted.

The defendant, a national of a Latin American country, was charged with laundering the proceeds of narcotics transactions, through bank accounts located in some of the world's most prominent offshore financial centers, disguised as legitimate international business transactions. Though he had a US apartment, he was not a permanent resident, nor were there sufficient contacts for the Court, which ordered him held without bond, in pretrial detention. Apparently the fact that he had lived & worked in the US previously, including a period with a forensic accounting firm, was insufficient. His history of conducting international financial transactions probably also made him a flight risk, as did his dual citizenship in a country located in the European Union.

The US Attorney's office sought to secure the evidence, foreign banks records, mainly in tax haven jurisdictions, through multiple Mutual Legal Assistance Treaty (MLAT) requests, but they were not forthcoming after several months, and as the case came closer to the trial date, the Government asked for a trial setting in the following year, though it could not assure the Court that even then would the evidence be in its hands. Obtaining evidence from a foreign source can be difficult, and can be impossible, when facing s Speedy Trial demand.

The case was then transferred, due to improper venue, and rather than go to trial and lose, the Government came to a curious settlement with the defendant. He was charged with an immigration offense, which occurred years earlier, and all the original counts in the indictment were dismissed. we call this a plea of convenience, but the Government was certainly unhappy with the result.

The sentence was time served, which amounted to more than seven months in pretrial confinement, and Supervised Release was waived, meaning that was free to leave the United States. Of course, the Federal felony insured that he would not be coming back into the US, unless some government agency gave him permission. Thus, barring his subsequent cooperation with law enforcement, which was doubtful, given his experience in this case, he would not be visiting anytime soon. Of course, inasmuch as he was not facing a 20-year money laundering sentence, he was most likely relieved.

Was justice denied, for the lack of evidence in hand, or was there insufficient evidence to convict, had it been produced ? We cannot say, but we trust that a lesson was learned here; don't bring money laundering charges in Federal Court, expecting to acquire the evidence at a late date; you may not get it.

Without the evidence, the court file alone makes it impossible for us to determine his guilt or innocence.

  

RICHARD CHICHAKLI FILES REPLY BRIEF IN HIS APPEAL

Richard Chichakli has filed a Pro Se Reply Brief in the appeal of his criminal conviction; It is handwritten, and inscribed upon a legal pad. You may recall that the Bureau of Prisons, which had to deal with the many complaints he aired, about his inability to adequately prepare for trial while incarcerated, initially assigned him to the downtown Federal Detention Center Miami, far from his New York City attorney, as well as the Second Circuit Court of Appeals, which will rule upon his appeal of his conviction and sentence. BOP records now show him back in New York, at Brooklyn MDC.

His counsel had previously filed a Reply Brief, but Chichakli obtained court permission to file his own supplemental reply. He has responded to the US Attorneys' brief with these issues:

(A) The Government knowingly and intentionally offered perjured testimony, and suborned perjury.
(B)  The Indictment was varied and altered; the adding of a codefendant is an alteration, if not done by a Grand Jury.
(C) Appellant did not waive extradition.
(D) The Appellant has a cognizable claim for violation of his Constitutional rights, styled as " Ineffective Assistance."
(E) The jury were not informed of the law.
(F)  Viktor Bout was referenced as a co-defendant in the trial. Bout is not a defendant, thus the use of his name as a co-defendant seriously prejudiced Appellant.
(G) The use of irrelevant evidence, secret or not, prejudiced Appellant, and is in violation of the Rules of Evidence, by giving the Government unfair advantages, to which the defendant cannot respond.

Chichakli's attorney has requested Oral Argument in this cause. His presumptive release date is June 11, 2017.

IF YOUR STATE HAS NOT COMPLIED WITH DHS REQUIREMENTS ON DRIVERS' LICENSES, SHOULD YOU STILL ACCEPT THEM AT ACCOUNT OPENING ?

According to the Real ID Act of 2006, all the states in the US should have issued issued enhanced drivers' licenses; at least half of them have not yet complied, and at least two states' licenses are not valid for entry onto a commercial aircraft, or for entry in Federal buildings, as of 1 January 2016. What's wrong with this picture ? Many states are on their second extension, which expires in late 2016. This represents a clear and present danger for compliance programs. Perhaps the governor of one of the non-compliant states would like to explain himself, when his state's licenses are used to facilitate a terrorist act in the United States. We call this legislative malpractice.

Drivers' licenses, according to the Act, must be tamper-proof, and counterfeit-resistant, and must state the legal (immigration) status of the holder. In an age of global terrorism, not to mention rampant financial crime, most notably money laundering, compliance officers should ask themselves whether their risk-based compliance program can continue to rely upon the non-conforming licenses ?

It is humbly suggested that you hereafter require a supplemental, photo ID, to complete the customer identification process. An ID from a Fortune 500 company, a VA ID card, a concealed weapons permit, or any number of officially-issued identification cards will suffice, for when you accept, as sole proof, a drivers' license, which may be now sub-standard under Federal law, at account opening, you may later be judged to have failed in your compliance duties, if the new customer turns out to be a terrorist financier, or major money launderer.

Update your new account requirements, in writing, so that there will be no waivers granted to clients by "helpful" new accounts staff. If the TSA will no longer accept some of the state drivers licenses, to allow one to board an aircraft, you should not either; get a trustworthy second from of identification.

RAISE COUNTRY RISK FOR SWEDEN

The extraordinary migration into Europe in 2015, from the war zones in the Middle East, as well as economic refugees from Africa and Asia, have resulted in a massive increase in Sweden of its refugee population. In some urban areas, the net result has been disturbing; crime has been out of control, the fabric of the social assistance network has been stretched to its limits, and the failure of the majority of its Middle Eastern migrants to adopt Western culture, laws, human rights values, and mores, have all pushed Sweden towards an unstable future.

The fact that these new Swedish residents represent potential voters has resulted in the utter failure of the political parties to support any drastic and effective action on all fronts where it is needed. Multi-culturalism appears to have failed as an instrument of national policy in Sweden.

Unless and until the authorities can reduce the flow of refugees to a trickle, Sweden faces a probable breakdown in social services, a growing crime wave, conflict between Swedish citizens and the new, unassimilated and unmanageable mass of refugees. All this will destabilize the political and eventually economic health of the nation, and therefore its is prudent to raise Country Risk at this time, reducing both future investment and financial exposure, which could end up in default, if the trend seen over the past 48 months continues.