AMERICAN BULK CASH SMUGGLER CHARGED WITH MONEY LAUNDERING IN JAMAICA

Dalton Forrester, a 35-year old American citizen who attempted to smuggle in over $100,000, in cash, into Jamaica, has been detained, and charged with multiple counts of money laundering-related offenses. He had concealed USD$101,378.00, upon his person, and in his luggage, upon his arrival at Sangster Airport, on April 9, 2016.

Forrester, who Jamaica authorities state is from New York, may be from Boston, as public records show only one African-American individual in the US with that exact name. That Dalton Forrester has an upcoming wedding set for September 2017, and if they are the one and the same individual, his fiancé, who has posted details about their relationship online, is in for a surprise.

The charges listed against him are:

(1) Bringing criminal property into Jamaica.
(2) Possession of criminal property.
(3) Concealment of criminal property.
(4) Cross-border movement of funds
(5) Conspiracy to possess criminal property.

There is a hearing set for today, April 20, 2016, at Montego Bay Magistrate's Court.

IN A FUTILE ATTEMPT AT DAMAGE CONTROL, PANAMA'S PRESIDENT VOWS TO ABOLISH BEARER SHARES

President Juan Carlos Varela, seeking to contain the massive reputation damage that his country is sustaining, by reason of the Panama Papers disclosures, about tax evasion and illicit money hidden by corrupt politicians, through the Mossack and Fonseca law firm, has stated that bearer shares will be shortly abolished. Why should we believe him ?

Much of Panama's attraction, as an offshore financial center and tax haven, is centered around the absolute anonymity that bearer shares deliver, and should such a vehicle no longer be available in Panama, you would see capital flight out of the country, and a serious drop in new business, which would insure a major depression in the local economy. Given only lawyers and law firms can form corporations in Panama, you can count on the legal sector to see that National Assembly never passes sufficient legislation, that would end the laws authorizing the issuance of bearer shares.

Panama's banks, many of whom practice willful blindness, regarding both Source of Funds, and Beneficial Ownership of corporations, would also block any reform of the corporate code, so don't hold your breath, waiting for the imminent enactment of legislation, in Panama, that would, in essence, kill the country's illicit offshore industry. bearer shares, and dirty money, are both here to stay in the Republic of Panama.  

WATCH FOR OPPORTUNISTIC MOVEMENT OF DRUG PROFITS INTO ECUADOR IN WAKE OF EARTHQUAKE

Money launderers charged with repatriating narcotics profits earned in North America are always looking for targets of opportunity, especially events where they can hide their wire transfers within the huge flow of relief funds that follow natural disasters, and the recent earthquake experienced in Equador has most certainly got their attention.

The facts are all favorable:
(1) Equador has had a Dollarized economy since 2000.
(2) It is adjacent to Colombia.
(3) It already serves as destination for southbound narco-profits en route to Colombia.
(4) the country is in dire need of financial aid to assist in earthquake recovery.

Money launderers have a history of using natural disasters, where all efforts are focused on getting aid to the affected area, and the willingness of bankers to facilitate rapid movement of what appear to be aid funds, to transfer drug profits, free of the usual scrutiny. Look for the names of charitable organizations that are deceptively similar to those that are well known, or those that are no longer active. It is also possible that small or obscure legitimate charities may be co-opted to move dirty money, though bogus entities are more likely.

 Bankers who are urgently requested to help with disaster relief may not take the time to vet NGOs, or entities who claim to be charities, in light of the emergency. Therefore, if you do not know the charity, including the individuals who are seeking your assistance, Mr. Banker, please ensure that a thorough due diligence investigation is conducted by Compliance, even if the charity is referred to you by a longtime client, for legitimate individuals, who believe they are doing good works, may unwittingly be facilitating the movement of drug profits.     

WHY GARY LUNDGREN REFUSED TO SHOW FINRA HIS BANK ACCOUNTS

When FINRA ordered Gary James Lundgren to produce his accounts and records, he brazenly disobeyed five FINRA directives to open his books and records; the result was the ultimate loss of all his securities licenses, and a lifetime bar on any participation in the securities industry*. No legitimate trader of securities would ever allow that to occur.

His lawyer, Alcides Peña**, attempted to employ every single procedural roadblock, to delay the proceedings, asserting one bogus defense after another, until FINRA removed him, due to the simple fact that he was not admitted to practice law in any state. The final stunt: after asking for a hearing, Lundgren decided not to attend, probably because he fears a sealed Federal indictment exists, charging him with securities violations, and tax evasion.

Why would any licensed trader, with a lifetime of experience in the field, allow such a result, when he could have easily avoided such a disastrous outcome, by disclosing his finances. ? Read on.

If Gary Lundgren had turned over his bank account information, FINRA investigators would have seen these glaring violations:

(1) Lundgren took investment funds from US citizens, paid through his brokerage firm in the State of Washington, to his accounts in Panama, where he did not hold any securities licenses, and purchased local real estate, as well as unregistered securities, and took some of the investors' money into his personal accounts, so that he could make investments in his own name.

Gary James Lundgren

(2) Lundgren has a long and sordid history of accepting bulk cash from criminal clients located in Colombia, who sell narcotics, and engage in other illegal cash-producing businesses. He laundered the money, by using it to purchase real estate in Panama, from Panamanian builders who accepted the money, no questions asked. His connections with traffickers in Medellín are well known.

(3) Lundgren had a long history of accepting money for convicted Pyramind/Ponzi schemer, David Murcia Guzmán, and when Murcia was extradited, never to return, Lundgren reportedly retained millions of dollars, which he converted to his own use. Any close examination of his bank accounts would surely find deposits for which Source of Funds could never be established.

(4) Lundgren knew securities salesmen all over the United States, who steered investor funds to him, as he was paying high commissions to those who did. Lundgren promised double-digit returns, monthly, and his well-known high yield investment program, which was bogus, also constituted a security under US laws, meaning that SEC registration was required; it was never performed.

Therefore, had he followed the law, and timely delivered to FINRA the necessary records, he might have gone to prison in 2015, when the documents produced incriminated him. True, his dilatory tactics may have bought him some extra time, perhaps before any criminal charges were filed in the US, but his situation has now deteriorated further.

Two Panamanian law enforcement and regulatory agencies have now opened an investigation into Gary Lundgren's acts; one of them is a task force on organized crime. One US law enforcement agency is known to be conducting a new investigation, after Lundgren made repeated death threats to journalists reporting on his FINRA disbarment. He continues to illegally participate in the trading of US securities, using third parties, in a direct challenge to American regulators.

 Due to his advanced age, Lundgren, should he be convicted in Panama, would be sentenced to home confinement, but in the United States, where the Bureau of Prisons maintains state-of-the-art medical care, and he will have to serve some serious prison time; Let justice be served.
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*FINRA permanently bars fraudster Gary Lundgren
**Alert: Fraudster Gary Lundgren has a new in-house Lawyer

MOSSACK AND FONSECA WORKED FOR FRANKLIN DURAN WHILE HE WAS SERVING TIME IN AN AMERICAN PRISON

Franklin Duran's Venezuelan Naval Intelligence badge and ID 

The lengthy press releases, published by Mossack and Fonseca, claiming that the law firm's Customer Identification Procedure, and compliance staff, were conducting due diligence upon all their clients, appear now to be a joke. Miami is buzzing about the disclosure that Franklin Duran was conducting business with MF, while he was actually serving a four-year sentence in Federal Prison. This confirms that there were no checks performed on clients by the law firm.

Duran is notorious in Miami, due to the "Suitcasegate"corruption scandal, which was the seizure of $790,550 in cash, by Argentinian Customs, when local Key Biscayne resident, Guido Antonini Wilson, attempted to smuggle in an illegal campaign contribution, destined for Cristina Fernandez de Kirchner. The money, which came directly from PDVSA coffers, traveled with Antonini to Buenos Aires on a private jet charter, where the passengers on board, which included a number of Argentinian (PDVSA) and Venezuelan state officials, imbibed an obscene number of bottles of Johnnie Walker Blue Label $200.00 Scotch. It was later alleged that $4.2m was successfully smuggled into Argentina that day, for Kirchner's campaign, by another individual on the flight.

Only the best for bulk cash smugglers.

Duran later traveled to Miami, and threatened Antonini, and his family, if he told the authorities the truth about the origin and purpose of the money. Duran was convicted of the Federal crime of acting an an unregistered agent of a foreign power, namely the Government of Venezuela, and conspiracy.

The fact that a fifteen-second Internet search would have turned up Duran's case confirmed that there is, in essence, no real compliance practiced at Mossack and Fonseca. The firm admits that it did not discover Duran's unsuitability, as a client, for five years after the fact, and that may have occurred only because investigative reporters were overtly inquiring about MFs clients in 2015, and the firm may also have known about an American law enforcement investigation that began in 2014.

Franklin Durán, in the Gumball Rally.

Duran, after serving his sentence, was deported from the United States. He is reportedly living in the Republic of Panama. Compliance officers, be advised that his complete name is Franklin Durán Guerrero, born 12 September, 1967, in Caracas, and his Venezuelan Cédula Number is 7.927.630  .

Next month, a complete list of MF clients is due to be released, and further evidence is expected, confirming that Mossack and Fonseca deliberately ignored performing even the most rudimentary check on new clients, so long as they paid the exorbitant fees the law firm charged for corporate services.

BAHRAIN DESIGNATES HEZBOLLAH A TERRORIST ORGANIZATION

The Kingdom of Bahrain, lining up with the actions of the other Gulf states, the GCC and the Arab League, has formally designated the Lebanese Shi'ite group Hezbollah, as a terrorist organization. Bahrain also designated  68 other regional Islamist groups as terrorists, including Al-Qaeda and ISIS/ISIL.

Inasmuch as some of our readers may not be familiar with the minor terrorist organizations, and because I have not seen this published in the Western press, the complete list of the entities sanctioned by Bahrain follows, excluding those already named:

ANSAR AL-ISLAM/AL-QAEDA KURDISH BRIGADES
AL-QAEDA IN THE ARABIAN PENINSULA
THE NUSRA FRONT
THE ABU SAYYAF ORGANIZATION
THE ISLAMIC MOVEMENT OF UZBEKISTAN
MOHAMMAD'S ARMY
LASHKAR-E-TAIBA MOVEMENT
THE ANSAR LEAGUE
AL-QAEDA IN THE ISLAMIC MAGHREB
THE PAKISTANI TALIBAN
THE ABDULLAH AZZAM BRIGADES
ANSAR AL-DIN
BOKO HARAM
ANSAR AL-SHARIA IN BENGHAZI
ANSAR AL-SHARIA IN DAMAH
AL-JAMAA AL-ISLAMIYA
LASHKAR-E-JHANGVI
THE ISLAMIC JIHAD MOVEMENT
THE ORGANIZATION OF JAMAAH ANSHARUT TAUHID
ANSAR AL-MUSLIMEEN IN SUDAN
AL-MOLATHAMOON BRIGADE
ANSAR AL-SHARIA IN TUNISIA
AL-MURABITOUN GROUP
ARMED ISLAMIC GROUP
THE PROTECTORS OF SALAFIST DAWA ORGANIZATION
THE EAST TURKESTAN ISLAMIC MOVEMENT
EGYPTIAN ISLAMIC JIHAD MOVEMENT
EMIRATE OF THE CAUCASUS
GLOBAL RELIEF FOUNDATION
MOVEMENT OF SHAM AL-ISLAM
INDONESIAN RED CRESCENT SOCIETY
ADEN-ABYAN ISLAMIC ARMY
ISLAMIC INTERNATIONAL BRIGADE
ISLAMIC INTERNATIONAL BRIGADE
ISLAMIC JIHAD ORGANIZATION UNITED WITH THE ISLAMIC MOVEMENT
AHLU SUNNA FOR DAWA AND JUHAD GROUP
THE SOLDIERS OF THE CALIPHATE
ISLAMIC FIGHTING GROUP IN LIBYA
THE SERVICES' OFFICE
ISLAMIC FIGHTING GROUP IN MOROCCO
NETWORK OF MOHAMMED JAMAL
MUJAHIDIN INDONESIAN TIMUR
AL-TAWHID AND JAHAD GROUP IN WEST AFRICA
RAJAH SOLAIMAN MOVEMENT
REVIVAL OF ISLAMIC HERITAGE SOCIETY
BRIGADE OF RIYAD AL-SALIHEEN MARTYRS
THE FORCES OF THE ISLAMIC JIHAD
ARMY OF AL-MUHAJIREEN AND AL-ANSAR
ISLAMIC FIGHTING GROUP IN TUNISIA
ORGANIZATION OF RECONSTRUCTION OF THE UMMAH
ORGANIZATION OF FULFILLMENT OF HUMAN WORKS
THE ISLAMIC UNION
INTERNATIONAL AL-AKHTAR TRUST ORGANIZATION
AL-HARAMAIN CHARITABLE ORGANIZATION
AFGHAN SUPPORTING COMMITTEE
GROUP OF AL-MOWAQIOON BEDDAM
AL-FURQAN ORGANIZATION
AL-RASHID TRUST ORGANIZATION
CHARITABLE FOUNDATION OF AL-IHSAN
ISLAMIC COOPERATION ASSOCIATION
RABITA TRUST ORGANIZATION
INTERNATIONAL OFFICE OF THE TAIBA AGENCY
THE COALITION OF FEBRUARY 14 YOUTH
THE GROUP OF ASHTAR BRIGADES
POPULAR RESISTANCE BRIGADES

Some of the groups are obviously local branches of the same organization, and it is not known how many of these are regional "unofficial" names adopted from segments of major trans-national groups, to distinguish themselves from the mainstream ones. Also, remember, that these are transliterations into the Latin alphabet, from the original Arabic, and a number of variations of these names will certainly exist. Some of these groups may be very small, and others known only from their press releases, or Internet presence, but other represent a current clear and present danger, both in the Middle East, and increasingly, in the West.

ALERT: FRAUDSTER GARY LUNDGREN HAS A NEW IN-HOUSE LAWYER

Gaspar Lee Pedreschi

Gary James Lundgren, his securities license revoked for life by FINRA, and his clients clamoring for their promised 15% per month interest payments, due from a fraudulent high value investment program he operates, has apparently replaced his in-house attorney (read that as court fixer), Alcides Peña, with Gaspar Antonio Lee Pedreschi, whose photograph appears at the top of this article. If you encounter this guy in Panama City, stay far away, if you want to keep your assets.

Pedreschi, who now makes the rounds with Lundgren, in Panama City, is listed, in the public records, a a director and/or subscriber, of many of Lundgren's fraudulent securities and real estate corporations, and you can assume that he is working with the Alaskan expat's two grown children, in fronting for him, regarding unlicensed trading in US and Canadian securities as well as assisting with Lundgren's true specialty, using bearer share Panamanian companies to fleece retired North Americans.

One more thing: Pedreschi has been heard openly bragging about his regular trips to Medellín, Colombia, so you can add bulk cash smuggler, and money launderer, to his list of duties for Lundgren, who is know to launder narcotics profits, through the purchase of Panama City condominium apartments and offices. Perhaps someone ought to inform this young lawyer about the extraterritorial reach of the Money Laundering Control Act of 1986, and the 20-year prison sentence that can be imposed for violations.     

CIA ENGAGED MOSSACK FONSECA FOR IRAN-CONTRA AND BCCI

Details released this week, reportedly from the examination of documents known as the Panama Papers, indicate that the law firm of Mossack and Fonseca served a number of intelligence services, including, most notably, the Central Intelligence Agency (CIA). That information is indeed correct: Mossack Fonseca assisted the CIA, with both the formation and operation of anonymous shell companies, and the covert movement of cash. MF name partner, Jurgen Mossack's father, Erhard, was a CIA asset in Panama, during the Cold War period, which may have served to facilitate MF involvement.

The Panama aspect of the Iran-Contra operation, wherein arms and ammunition delivered to Central American airstrips, ostensibly for the Contras, who opposed the radical Sandinista regime in Nicaragua, and money was earned through the sale of narcotics, smuggled into the continental United States, was commanded by CIA supervisor Reeve Whitson, and assisted by a Canadian covert operative known by a code name; Maximilian. Whitson's unit, known as the Quarry, supervised the arrival of cash, at a  private CIA-controlled airfield at Punta Pacifica, in the area where the Trump building now stands.

It is doubtful that any significant information will be extracted from the Mossack documents, due to the fact that all the relevant MF files were not kept at Mossack; they were stored at the US Embassy. The other covert operation that MF assisted the Company with was the Bank of Credit and Commerce International, more commonly known as BCCI, which later imploded in a scandal that exposed the hidden hand of the world's darker forces in the opaque world of international banking and finance. Again, Mossack and Fonseca provided corporate and financial services to the Agency, in its dealings with BCCI.

 Mossack and Fonseca also assisted the CIA with projects, but information about those matters is still believed to be classified, and therefore not an appropriate subject to be included here, but the law firm's covert involvement occurred over a period of many years.

ALERT FOR IDENTITY MANIPULATION BY MOSSACK FONSECA FOREIGN OFFICE STAFF

Mossack's Brazil chain of command

When I wrote the recent article Mossack's Covert Global Sales Apparatus Operated under the Radar, on April 6, I noticed that the Miami office manager of the Mossack subsidiary, which appears to be a sales office, though it operates out of a residential condominium, curiously showed up with two different last names. One of our readers of that article commented that he found she has been using four different names. This is a technique specifically designed to foil any investigation that seeks to find a pattern, or course of dealings, in financial transactions. It is a method of deception often used by financial criminals.

We must assume that they are in widespread use by overseas Mossack staff members, as they attempt to confuse any possible inquiries, or due diligence investigations, and conceal their business from local licensing authorities, as well as tax men, and regulators.

Here's what you might expect, based upon what I have extracted from the Miami manager's name permutations:

1. Using the staff member's full four-part Latin American Spanish name ( first name, middle name, father's last name, mother's last name).
2. Splitting her last name into two parts, and making the first part of it into a bogus middle name.
3.Using her full middle name, and a fragment of the last name.
4. Using a compound or hyphenated last name.
5. Using the middle name as her last name.

 Searches, in local public records, and state or provincial corporate services websites, can uncover the use of alternative names by the same individuals. One must only look for documents with the same common denominator, such as recorded filings, to see the signatures of deceptively similar, yet unique, names, which could be the same individual, seeking to confuse investigators or law enforcement.

The takeaway here is that Mossack Fonseca should be expected to have used all the tradecraft of money launderers in its representation of criminal clients, including the normal precautions taken by  financial criminals.

MOSSACK AND FONSECA PARTICIPATED IN FINANCIAL PACIFIC INSIDER TRADING SCANDAL

The law firm of Mossack and Fonseca, whose global money laundering and tax evasion facilitation program has been exposed in the Panama Papers, was also apparently involved in the Financial Pacific/Petaquilla Gold Mine insider trading scandal, reportedly, according to individuals who have access to the information gleaned from MF emails, and documents, given to certain media by whistleblowers.

For those not familiar with the Financial Pacific case, the participants, relying upon inside information, purchased huge amounts of shares of Petaquilla Mining stock, which soon thereafter, based upon the public release of favorable information, soared. The fraudsters then took obscenely high profits; the trades were effectuated using the Financial Pacific brokerage house.

Certain of the Mossack firm's clients were reportedly privy to the inside information and the movement of their funds through accounts which it opened for those clients, to purchase Petaquilla stock, was allegedly accomplished by MF staff, at cooperating banks, through Financial Pacific.

We have previously covered the dominant role in Financial Pacific's purchases of shares of Petaquilla stock, for clients, by Gary James Lundgren, the American expat trader whose securities licenses have recently been revoked by FINRA, and who is now barred, for life, from trading in securities, in the United States. Lundgren's connections with Mossack and Fonseca, and those of its clients who traded on inside information, has not yet been publicly released by the teams of journalists who have been reviewing the MF material, but several Panama insiders believe that he handled many of the illegal trades for MF clients, and that he may have provided some of the cash needed for the large purchases of stock.

Gary James Lundgren

Only when the complete treasure trove of data is released will we know the true extent of the Mossack and Fonseca firm's involvement in the massive securities fraud, which was perpetrated upon innocent investors who purchased Petaquilla shares, at vastly inflated prices, from MF clients, who had inside information, ahead of the investing public.

PANAMA PAPERS: PRESIDENT VARELA AND PANAMA CITY MAYOR BLANDON BRING RUSSIAN ORGANIZED CRIME TO MOSSACK AND FONSECA

President Juan Carlos Varela

The plot thickens: the latest news from individuals who are reviewing the treasure trove of documents known as the Panama Papers, reportedly contains extremely incriminating information about Panamanian President Juan Carlos Varela Rodríguez, and Panama City Mayor, José Isabel Blandón. Also implicated is Blandón's law partner, Herbert Young-Rodríguez

According to the source, Attorneys Blandón and Young delivered a large number of clients, who were all affiliated with Russian Organized Crime syndicates, to Mossack and Fonseca, who handled all their corporate and financial business. Then, President Varela, in a prearranged deal, saw to it that lucrative government contracts were awarded to those new shell companies formed by the Mossack firm, and controlled by the same Russian criminal elements.

It is premature to estimate whether these disclosures will force Varela or Blandón to resign, and in Panama, corrupt senior officials tend to stay in office until the end of their terms, after which they relocate to the United States, so as to enjoy the illicit fruits of their corrupt labors, so do not look for him to bow out. Whether Mossack, and his partners, are ultimately indicted, however, is another story.

Watch this blog for further news regarding this developing story.

  

WORLD CUP OF FRAUD

If you haven't had a fix recently, of the FIFA scandal, try this excellent resource:

FIFA,  A WORLD CUP OF FRAUD

http://www.sportsmanagementdegreehub.com/fifa

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Our thanks to Zelda Robbins, for providing it.

GOVERNMENT OF PANAMA CENSORS NEWS ABOUT PANAMA PAPERS SCANDAL

Panama's Varela administration has severely cautioned the country's newspapers about reporting any further negative details of the so-called Panama Papers documents. Editors of the major print media have passed that warning along to their rank-and-file journalists; all stories to be published, must first be approved by the senior editor, and the newspaper's attorneys, before they will be allowed.

The net effect of this virtual censorship is that only stories favorable to the law firm of Mossack and Fonseca, the focus of the Panama Papers scandal, will be printed. We have seen a very articles, but they all focus on the Government's reputed investigation of the outside "hack" Mossack servers. In truth and fact, the documents were taken, in an inside job, by multiple individuals.

The Mossack & Fonseca law firm , though it grossed $42m in a recent year, according to reliable reports, paid many of its staff minimum wage, periodically had major staff layoffs. Some observers believe that these policies were to encourage a periodic turnover in support staff, so that no individual learned too much about the firm's many clients. The same reason is given for the firm's penchant for engaging inexperienced compliance officers, and changing them every two years or so.

Press censorship, in such a vital topic as the Panama Papers case, harms not only the global business community, but also could result in critical, inside information being withheld from the public at large. Freedom of the Press has been under attack in the Caribbean of late, generally by governments eager to avoid the release of damaging information, often about corruption.

Whether this is the beginning of widespread news management in Panama, by the government, is not known, but due to the controversy spawned by the release of the Panama Papers, it is critical that locally-obtained information and news be freely distributed in the Panama City media, for the protection of the financial institutions in the Western Hemisphere, investors, and compliance officers charged with risk management.  

HOW MOSSACK FONSECA CLIENTS GOT THEIR DIRTY CASH INTO PANAMA

Readers who were wondering exactly how all those corrupt politicians managed to get their bribe & kickback money into Mossack Fonseca's wealth management division, allow me to explain. They used the notorious VIP Arrivals Lounge at Panama's principal airport, Tocumen International, and walked their cash right in, free of any inspection or examination.

Most Latin American countries have a Very Important Persons facility at their international airports; while they were designed for the wealthy upper class, to allow them to avoid long customs lines, they unfortunately allow anyone lucky enough to have the connections to gain entry to totally evade any customs inspections, which is a boon for money launderers and bulk cash smugglers.

In Panama, the parties are met upon arrival, and prior to formal entry into the customs and immigration lines. They are taken into VIP lounge, and can then immediately pass through, with all their possessions free from any inspectors, or questioning. Arrival/departure cards are processed, and they soon depart for Panama City. This is how foreign officials, or their bulk cash smugglers, gain unfettered entry into Panama, and the preferred route for many a Mossack Fonseca client over the last forty years.

DID FINTRAC FAIL TO SERVE THE PUBLIC GOOD BY WITHHOLDING NAME OF OFFENDING BANK ?

         

A firestorm of protest continues to emanate from the financial community in Canada, because the country's anti-money laundering regulator, FINTRAC, has declined to release the name of the bank against which it imposed a CAN$1.1m fine, deserves an answer. Notwithstanding that FINTRAC routinely releases the identifies of other non-bank financial institutions (NBFI) that it names & shames, the agency continues to shield the name of the offending bank from disclosure.

All of Canada's major banks have reportedly denied that they are the guilty parties, leaving the small regional banks, which are unlikely, and the Canadian branches of foreign banks, where the guilty party is most probable. The ostensible reason given by FINTRAC, regarding the failure to name the bank, would involve a lengthy appellate process; if this was truly the case, then why does the agency generally release the names of the non-banks that it sanctions and fines ? I frankly cannot buy this argument.

The other FINTRAC argument is that, if the bank is named, then all its correspondent accounts may be terminated. I do not buy that argument either; if the unnamed bank loses its correspondents, the such action is necessary for any risk-based compliance program of the banks it is doing business with. The bad bank brought the hardship on itself.

Canada's big banks have a valid point: if the offender is not named, then all the banks, which are most likely not involved, are now under the cloud of suspicion ? Also, the business public has a right to know who it should avoid. Canada's regulators are clearly not sensitive to the greater good here, and they should be called on the carpet for it, in the court of public opinion, to discourage similar actions in the future.