GANG OF FOUR RINGLEADER FLEES GRAND CAYMAN

Cayman Gang of Four ringleader, Sharon Lexa Lamb has fled Grand Cayman; efforts to locate her anywhere in the Cayman Islands have proven fruitless. While she may have quietly made passage to the Republic of Cuba, where she obtained residency last year, through a marriage of convenience, her exact whereabouts are unknown.

Miss Lamb may have fled ahead of the release of damaging disclosures, in the liquidation proceedings involving the defunct shell company, B & C Capital, Ltd., to the effect that B & C was insolvent. at the time that Lamb, and Dundee Bank President, Derek Hedley Longworth Buntain, illegally transferred millions of dollars of client money to the company.

 As the Senior Vice President of Dundee Bank, at that time, Lamb breached her fiduciary duties, when she processed the transfers, and she is a defendant in a civil suit presently pending before the Grand Court. She is also a person of interest in other civil suits, pending elsewhere, and the subject of a criminal investigation.

Sources in the Isle of Man, Lamb's country of origin, have not seen her recently on the island. One source in Grand Cayman says she has now returned to the islands, but is in hiding.

WILL 2017 OPENING OF BANK OF PALESTINE IN CHILE BE AN OPPORTUNITY FOR TERRORIST FINANCING ?

           

The announcement, by the Bank of Palestine, that it intends to open a branch in Santiago de Chile in 2017, may raise Country Risk issues for the Republic of Chile. Chile, which has a large population of descendants of Palestinian immigrants, has heretofore not been the subject of concern for terrorist financing, by Hamas & Hezbollah.

The opening of a facility of a financial institution, which was formed in Gaza, but now has its headquarters in Ramallah, with offices and branches in both territories, could provide a new funds pipeline for terrorist financiers who are funding Hamas and Hezbollah, to move criminal proceeds, earned in Latin America, into the Middle East. Such acts could result in the Bank being excluded from the US banking structure, which could be fatal to its business.

Though the bank has had a good reputation for avoiding Hamas-controlled charitable organizations, and Islamic associations, and refrains from accepting them as clients, the use of third party corporate entities, in Chile, not known to either internal  compliance, or Israeli regulators, or American regulators, could result in quietly but efficiently funneling drug profits of Hamas into Gaza, or Hezbollah money into the West Bank (Judea & Samaria). Country Risk for Chile may be affected; the prudent move is to watch the Bank's activities closely, and initiate enhanced due diligence on any and all international funds transfers, for the first six months of operation.

Bank of Palestine headquarters, Ramallah.

PANAMA'S APOLOGISTS MISS THE POINT COMPLETELY

Since the "Panama Papers" scandal dominated the news in Panama City, the country's professionals, as well as politicians, have sought to distract attention from their money laundering banks. Many go so far as to challenge American journalists to actually attempt to open a bank account, and many have difficulty doing so, as they must produce a large number of documents, to achieve success.

This tactic, while appearing to be convincing, is misleading for two important reasons:

(1) US citizens, and legal residents, pose a bookkeeping nightmare for foreign banks, due to FATCA reporting requirements. Panama banks, frankly, do not want the problems, and will make it difficult for any US national to open an account with them. Besides, Americans are generally not promising to deposit substantial sums; it's small business for the banks.

(2) Panamanians, especially lawyers, have no trouble opening accounts, for they employ bearer-share corporations, as the account holders, and in most cases promise top make lucrative, large deposits, which the banks desire. Of course, bribes are often offered to facilitate the transaction. In many cases, the bank owners are even related to the lawyers seeking new accounts, or both the bank and the attorneys are members of the same organized crime group, usually the one I refer to as the Syrian Organized Crime Syndicate, the largest group in the country.

As you can see, it's only outsiders who have problems opening accounts; the money launderers, their lawyers, and criminal elements are welcomed with open arms, because of the large deposits, which will soon be entered the bank. The fact that Source of Funds, and Beneficial Owner, never come up, illustrates the ongoing nature of Panama's serious banking deficiencies.   

A SOUTH AMERICAN PASSPORT WITH SCHENGEN-LIKE PRIVILEGES ; ARE THEY BLOODY CRAZY ?

UNASUR, the Union of South American Nations, has once again brought up with the concept of a uniform South American passport, allowing free transit throughout the region, Schengen Zone style, basically abolishing the visa requirements that exist among Latin American nations. The idea is to emulate the European Union model of borderless travel and opportunity.

The issue is, given the universal problem the region has with corruption, acquiring a passport, which would allow free access, from Mexico to Chile, would only facilitate, and empower, existing narcotics trafficking, money laundering, human trafficking, arms trafficking, and consumer goods smuggling networks, already in operation. One cannot trust underpaid government servants in the region to follow strict compliance procedures, when issuing such passports, where bribes and kickbacks are commonplace. It would expand criminal opportunities tenfold.

In the absence of any effective compliance gatekeepers in Latin America, we respectfully state that the region is NOT ready, anytime in the near future, to adopt regional passports.  

DUNDEE BANK KNEW THAT B & C WAS INSOLVENT WHEN IT TRANSFERRED MILLIONS IN CLIENT MONEY

Grand Cayman's Dundee Merchant Bank, which held tens, or maybe even hundreds, of millions of dollars*, in accounts of Canadian pensioners, breached its fiduciary responsibility to its clients, when its senior officers transferred large sums to B & C Capital, Ltd., although the shell company, ostensibly a trader in securities, was insolvent at the time millions was shipped out to B & C Capital. Evidence confirming these facts appeared recently, in the Liquidation of B & C.

The transfers were approved by, and physically transferred on the orders of, President & Director, Derek Buntain, and Senior Vice President & Director, Sharon Lexa Lamb. They were the most senior officers at the bank during the relevant time the transfers were effectuated. Both Buntain and Lamb are members of the notorious Cayman financial crime crew, the Cayman Gang of Four. They deceived the clients, by falsely stating, in writing, that B & C  Capital was "a bank."

Derek Buntain

Accepting the funds at the literally penniless B & C Capital were the fugitive trader and fraudster, Director Ryan Bateman, and his partner in crime, Fernando Motto Mendes, who claimed to be the Managing Director, notwithstanding he was ineligible to hold such a position, due to his checkered past.

Sharon Lamb

Dundee Merchant Bank is therefore strictly liable to the customers, not just for actionable negligence, and breach of fiduciary duty, but the conduct of its officers, Buntain & Lamb, was willful, wanton & reckless, and in total disregard of their customers' rights. Whether punitive damages lie for its wrongful acts is a question for the courts, but the level of misconduct appears to reach such heights where it is appropriate and proper. Dundee Bank is a wholly-owned subsidiary of Canada's Dundee Corporation, which will be held strictly liable, as the parent.

Also, both Derek Buntain and Sharon Lexa Lamb are personally liable for their actions, and they both should receive a lifetime ban on working in any financial or fiduciary capacity.

Ryan Bateman

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* Investigators do not know precisely how much was stolen by Lamb, Buntain & Bateman, because the thieves, and their attorneys, have been hiding behind the Cayman Islands' secrecy laws, since the losses were discovered.

Note to Readers: All Anonymous comments, posted by the Cayman Gang of Four, especially Sharon Lamb, are being automatically deleted. These so-called comments are being posted solely to confuse the issues, and ignore the evidence, much of which has been turned over to law enforcement agencies in a number of countries.

AVOID CHINESE COPIES OF iPHONE OR OTHER APPLE PRODUCTS AT ALL COSTS

Bogus Apple store in Mainland China.

Remember those photos of the completely bogus Apple store in Mainland China,. that were making the rounds last year ? Chinese consumers thought that they were getting the real thing, but they were being fed counterfeit iPhones, iPads, and even laptops, some who which actually used the Windows operating system.

A word to the wise about these counterfeits:

(1) NEVER purchase any Apple products, anywhere, unless you obtain them at an authorized Apple reseller or retailer. With all the knockoffs of iPhones, you simply cannot take any shortcuts with these items; reduced prices are probably your first clue, but avoid all other sales outlets.

(2) DO NOT buy any Apple products in China for one cannot verify that you are in a real store that sells Macs.

Counterfeits.

(3) Remember that the Chinese Government wants total surveillance upon its nationals, and any counterfeit Apple iPhone, iWatch, or computer or tablet, may have spyware embedded in it, from the factory, which is probably cooperating with the authorities. What if you had proprietary information stolen from your laptop, by the Chinese Government, and then given to a government-controlled Chinese company, who engineered, built and marketed your products, or sold your trade secrets ?

Do not attempt to save a dollar by shopping online, or in a dodgy clearance store, for a computer or telephone ; you may get more than you bargained for.

Bogus screen on left.

ATTORNEYS FOR IRAN SANCTIONS EVADER ZARRAB FILE MOTION TO DISMISS INDICTMENT

The defendant's booking photograph

Reza Zarrab, whose arrest on Iran sanctions evasion charges, when he arrived in Florida with his family, for a vacation at Walt Disney World, is seeking to have his indictment dismissed. His case, which generated a large amount of public attention, when his attorneys offered a lavish house arrest package to the Court, so that he would no remain in pretrial confinement, had had a substantial amount of media attention.

The issue presented by the indictment: Whether a foreign national, using solely transfers between foreign banks, and foreign entities, is liable, under US Iran sanctions, solely because the US Dollars involved were ultimately cleared through American banks ?

Zarrab has assembled a "dream team" of attorneys, from some of America's best law firms, as well as the US office of the UK firm Clifford Chance, and Viet Dinh, the former Associate Attorney General under the Bush Administration. They have, jointly, filed a profusely cited 55-page memorandum of law, in support of the motion, asking that the Indictment be dismissed, due to it being fatally flawed.

The defendant's arguments, simplified, are:
(1) The IEPPA does not apply.
(2) There is no extraterritoriality.
(3) The processing of dollars, for foreign banks, is irrelevant.
(4) The Indictment fails, with respect to each count, as the allegations are insufficient.
(5)  The Indictment fails on both statutory and constitutional grounds.

Readers who need to review the complete text of the Memorandum of Law in Support of Defendant Reza Zarrab's Motion to Dismiss the Superseding Indictment  can access it on PACER, or through a hyperlink on the New York Times website. If you are unable to do so, kindly email me and I will send you a pdf file containing the Memorandum.. Email me at:  miamicompliance@gmail.com

Unless it is continued, the trial will commence in January, 2017.

  

AMERICAN BULK CASH COURIER ARRESTED UPON ARRIVAL IN JAMAICA

It appears that Jamaican marijuana traffickers, blocked from repatriating dug profits through the USA banking structure, continue to employ bulk cash smuggling, when they need to ship their cash home. Coline Brown, reportedly an American citizen, residing in New Jersey, was detained and arrested, upon arrival at Norman Manley International Airport in Kingston.

Miss Brown had concealed  USD$76,180 inside her luggage, and failed to account for it, when questioned by the Financial Investigation Division of the Jamaica Constabulary Force. She was subsequently charged with:

(1) Possession of Criminal Property
(2) Concealment of Criminal Property
(3) Failure to Declare
(4) Bringing Criminal Property into Jamaica. 

TURKEY INSTITUTES A TRAVEL BAN FOR ACADEMICS

The Government of Turkey has issued a blanket travel ban, prohibiting all members of the country's academic sector from travel outside the country. Though stated to be only a temporary measure, it is not known how long such restrictions will remain in place. This act has potentially serious ramifications for Country Risk.

Many of Turkey's academics are secular, and maintain pro-democracy sentiments. The government has charged that many were supporters of the failed coup, and they cannot be allowed to depart, for they may have to face justice for their role in the abortive military attempt to unseat the increasingly Islamic government. Academics are perhaps the last source of truth about Turkey's internal society, including corruption, and local participation in sanctions evasion activities regarding Iran.

Additionally, academics presently outside the country have been ordered home, upon pain of
nonspecific retribution, should they fail to promptly return. The effect of these restrictions upon freedom of speech has already been seen, and without objective and accurate information about Turkey, it will be impossible to accurately assess Country Risk. The result will most likely be a major increase in Country Risk levels, due to what amount to an effective information blackout on negative news, as reported by the academic community.

OPPOSITION THREATENS A "TURKEY PAPERS" DATA LEAK

In the bloody aftermath of the failed coup in Turkey, the Opposition, or what is left of it, after thousands of arrests and detentions, has reportedly stated that it intends to go public with a form of "Turkeyleaks" massive dump of sensitive and classified government documents. Do not minimize the consequences of such an act, should it take place.

Two major pending issues could be further exposed by such disclosures:

(1) Damaging details regarding Turkey as the continuing safe harbor for Hamas, which is using the country as a foreign operating base against Israel. Hamas Money Laundering, and terrorist financing evidence, regarding Turkish banks, if made public, could hurt Turkey in the West.

(2) The Pending Iran sanctions case, against Reza Zarrab, in Federal Court in New York, whereby gold was used to circumvent Iran sanctions, through Turkey. Should evidence that suggests Turkey allowed such a massive evasion program to operate surface, it could prove extremely damaging for Turkey.

The Government of Turkey is apparently taking the threat seriously; it has blocked access, within Turkey, to the Wikileaks website. The company, in response, has advised that it may still be accessed, through proxy servers, or through other means. Whether this is merely an empty threat, or that documents will appear, and severely incriminate the government, is not known, but it should be taken into account, for Country Risk purposes. Opposition elements remain a force to be reckoned with, which includes not just the military, but moderate, secular elements of the population, that fear Turkey is sliding down the hole, into an Islamic state.

CAYMAN ISLANDS GANGSTER HAS SIGNIFICANT UNDERWORLD PARTNERS

Wanted

The fugitive securities trader, the Canadian Ryan Bateman, who has a long and sordid history of stock price manipulation and securities fraud, does business with a number of "businessmen" whom you would not like to meet in a dark alley, in addition to his membership in the Grand Cayman crew, the Cayman Gang of Four.* These connections have a long reach, and have left a trail of victims in their wake.

These are but a few of the known activities that Ryan Bateman has engaged in:

(1) Trading securities, to manipulate markets, with a known Montreal organized crime syndicate. The trades were conducted through a company controlled by the Canadian mobsters.

(2) Purchasing 78% of the stock of a small software company (EYGY), that trades on the Over-the-Counter market, rebranding it as an energy company, and then manipulating the market to such an extent that the Securities & Exchange Commission abruptly, and swiftly, suspended trading in the company's stock. The original names was Somo, Inc., which was immediately renamed Enterprise Energy, Inc.

Here is what the SEC Release [ No.34-78059] stated:

" The commission temporarily suspended trading in the securities of EYGY, because of
   recent unusual and unexplained market activity, and potentially manipulative transactions,
   in the company's stock...
 
   The SEC appreciates the assistance of the Financial Industry Regulatory Authority
   (FINRA)." [ June 14, 2016]

The company's CEO is Shane Manning, and attorneys connected to the company are reportedly Scott Doney and William Scott Lawler.

(3) Bateman's prominent role in a number of oil & gas investment ventures, some of which involved obtaining offshore drilling rights, none of which appear to have ever become operational, and profitable, including a Cayman Islands-domiciled venture, a Bahamian venture, an Atlentic Ocean venture, and a reported venture involving the Republic of Cuba. Most observers have concluded that all involved acts of fraud, committed by Ryan Bateman, and others.

There are a number of domestic ( US and Canada) investment schemes, which we will cover in a subsequent article, but the above list most certainly qualifies Mr. Bateman as a prolific career criminal.

It makes you wonder why Cayman Islands authorities never charged him with any securities crimes, or even common law fraud, especially the most recent scandal, involving the theft of tens of millions of dollars in investment funds, by the Cayman Gang of Four. Is he a Confidential Informant for a law enforcement agency, and does he have the proverbial  "Get-out-of-Jail-Free card," like the American  mobster, James 'Whitey' Bulger, Jr. ? We cannot say, but there must be some reason why Bateman has evaded justice thus far.
______________________________________________________________________
* The Cayman Gang of Four are Ryan Bateman, Sharon Lexa Lamb, Derek Buntain, and Bateman's straw man,  Fernando Moto Mendes. Some commentators add William Tynkaluk as a member of the Gang.

ALERT ON BEIRUT-TO-CARACAS-TO-PANAMA CITY MOVEMENT OF LEBANESE NATIONALS

Coat of Arms of Panama City

Businessmen in the Republic of Panama are reporting a large and suspicious movement of Lebanese nationals, arriving into their county via a circuitous route. The precise intent of these individuals is unknown, but given the relationship between Venezuela's radical leftist Maduro government, and the internationally-sanctioned terrorist organization known as Hezbollah, which has long enjoyed safe harbor in Venezuela, it must be assumed that these new arrivals are in Panama City to use its financial center for illicit purposes.

The sources have noted that the Lebanese arrive in Caracas, where they illegally acquire legitimate Venezuelan and Panamanian passports (see our recent article on the subject), and then board commercial flights into Panama. Given the recent American anti-Hezbollah legislation, which severely penalizes any Beirut bank found to be conducting transactions with the terrorist organization, it is quite possible that Hezbollah money managers (read: money launderers) are switching to Panama's notoriously "willfully blind" banks, to move their funds on a global scale, especially criminally-derived income.

Therefore, any prudent compliance officer, at a financial institution located in North America, or Europe, would do well to pay particular attention to increased traffic from Panamanian banks, especially wire transfers whose ultimate destination is elsewhere, or which are forthwith transferred out, upon receipt at your bank. The last thing that any Western compliance officer wants is for his or her bank to run afoul of the Hezbollah International Financing Prevention Act.   

BVI BARS FOREIGN JOURNALISTS SEEKING THE TRUTH ABOUT THE TAX HAVEN'S DODGY CORPORATIONS

The fallout from the Panama Paper scandal, in which Mossack Fonseca records indicate that it formed the majority of its offshore corporations, mainly used by clients for illicit purposes, in the British Virgin Islands, has included prohibiting foreign journalists from not only conducting interviews there, but even entering the Island nation. Several journalists, including one with a confirmed appointment with the governor, have been detained upon arrival, and declared persona non grata, and promptly put on thew next plane out, without any legal proceedings.

 Eyewitness reports indicate that BVI nationals, and their government, has regarded any news about the BVI dodgy corporate formation industry, as a direct threat to their economy. Those corporations, formed to evade taxes, launder criminal proceeds, and hide bribe and kickback money, bring in an estimated $200m a year, for the local government in Tortola. What's wrong with this picture ?

Considering that the UK Foreign and Commonwealth Office has taken only token action to bring transparency to the BVI, it is humbly suggested that compliance officers, when they see that a bank client intends to use a BVI company, for any purpose, decline to assist. This means that the bank should refuse to open an account for any BVI company, for any purpose, as there are very, very few legitimate users of these tax evading corporate entities. Refuse the business, please, lest you later receive a visit from law enforcement, asking tough questions about Willful Blindness.   

AUTHENTIC PANAMANIAN PASSPORTS FOR SALE FOR CASH

Reports from Panama have confirmed that legitimate, blank Panamanian passports are being sold online. This is the first confirmed news, regarding the availability of authentic Panamanian passports.

Bogus Panamanian travel documents have long been available; just recently the authorities shut down a network that we vending fake passports for $705. Cuban nationals have been the targeted consumers, although the quality of the bogus passports has been poor, and generally insufficient to pass US and EU arrival scrutiny at Immigration. This new availability of the real thing is disturbing, for it is a game-changer regarding how much due diligence compliance officers will now have to perform on new Panamanian clients.

It is suggested that bankers detail a Panamanian employee, where available, to speak to the new client, in order to validate that the individual is truly a Panamanian, and using slang words, as well as cultural terms specific to Panama. Otherwise, a bank may unwittingly accept an OFAC-sanctioned individual, narcotics trafficker, or money launderer. 

WHICH MEMBER OF THE CAYMAN GANG OF FOUR IS UNDER INVESTIGATION FOR STOCK MANIPULATION ?

The question of the week for our readers: which member of the notorious Cayman Gang of Four* is being investigated, in the United States, for the crime of stock manipulation in 2015 and 2016 ? Remember, previous crimes committed by these gangsters do not count.

Whom do you have to choose from ? here are the players:

(1) the Canadian securities trader, Ryan Bateman, presently living in Fort Lauderdale, Florida.

(2) the Isle of Man native, ex-banker, Sharon Lexa Lamb,  keeping a low profile in the Cayman Islands.

(3) The Portuguese fraudster, Fernando Moto Mendes, also hanging out in Grand Cayman.

(4) The disgraced Canadian ex-banker, Derek Buntain, hiding out somewhere in Canada.

We will disclose all the details, on this blog, later this week. Stay tuned.
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* Hint: it is NOT the Canadian securities trader, William Tynkaluk, though his insider trading and securities fraud is legendary in the Canadian province of Ontario. Bill Tynkaluk, who has been called in for interviews, several times, by the Ontario Securities Commission, will never be indicted, as the influential Canadian securities industry maintains an iron grip upon the local regulator, the Ontario Securities Commission, so as to avoid any negative publicity about securities crime.

Tynkaluk is, however, a close personal friend of the mystery man we are discussing today. Some people are saying that Bill T is the Fifth Gangster, and the term is so richly deserved, for his crimes and transgressions, committed in support and facilitation of the Gang of Four, surely qualify him as the fifth member of this cabal. Ask all the Canadian pensioners that have been swindled.