SENATORS CITE CONTINUING AND UNSOLVED PROBLEMS WITH MONEY LAUNDERING THROUGH REAL ESTATE

US Senators Sheldon Whitehouse and Chris Van Hollen, in a letter to the Comptroller General, detailed their concerns about the use of real estate to launder the proceeds of crime. The Senators, well aware of the power of the real estate industry, which has successfully managed to exempt real estate from both the Bank Secrecy Act and the Money Laundering Control Act. They have asked the Comptroller to examine the effect of the Geographic Targeting Orders (GTO) upon the anti-money laundering efforts of law enforcement and regulatory agencies.

Readers are urged to read the entire letter, which appears below.

305 RUSSIAN INTELLIGENCE AGENTS IDENTIFIED THROUGH AUTOMOBILE RECORDS

These are the seven Russian GRU (Main Intelligence Directorate) agents who have ben charged with cyber-crimes in the United States. Three hundred and five other GRU agents have also been identified through their automobile registrations, all of which show their home addresses as the GRU barracks where the cyber-crime unit is based. Below are two of their passports.

Readers who wish to examine the Indictment can review the complete text here:
 https://www.justice.gov /opa/page/file/1098481/download
The style is United States vs. Aleksei Sergeyevich Mirenets, et al  Case No.: 18-263 Crim (WD PA).

HAMAS CONTINUES TO STAGE TERRORIST FINANCING OPERATIONS FROM TURKEY

It appears that the Government of Turkey was being lest than honest when it assured the West that Hamas was no longer conducting terrorist operations from its territory. The Jerusalem District Court in Israel has recently sentenced one of its own Arab citizens to a term of imprisonment of three and one-half years for transporting 300,000 Euros from Turkey, into Israel, and delivering the money to Hamas contacts there.

Dara'am Jabarim pled guilty to:
(1) Assisting a terrorist orgaization.
(2) Contact with a foreign agent.
(3) Using personal property for terrorist purposes.
(4) Prohibited personal property transactions.

Jabarim, a businessman, met with Hamas officials in Turkey, who handed the funds to him. which were salaries for Hamas terrorists. 91,000 Euros were confiscated from his home in Umm al-Fahm in northern Israel.

AMERICAN REGULATORS RULE THAT COMMUNITY BANKS AND CREDIT UNIONS MAY SHARE AML RESOURCES

The major US regulatory agencies for financial institutions, OCC, FRS, FDIC,  FinCEN and NCUA, have issued an Interagency Statement permiting the sharing of BSA/AML resources, through a collaborative agreement, providing for the pooling of assets. There are certain restrictions and limitations. Readers who wish to review the Statement can access the complete text here

ELECTION FRAUD AND BRIBERY ISSUES NEED REFORM IN DOMINICA

This letter, from the organization leading the peaceful protests in the Commonwealth of Dominica, details the critical issues surrounding election fraud in that country. Widespread election time bribery, the inportation of expatriate Dominicans to Roseau by free airline travel, and the award of temporary and short-term election time employment, haveall contributed to the problem. Here are some suggested solutions.

APPEALS COURT DISMISSES PONZI SCHEMER SCOTT ROTHSTEIN'S APPEAL OF GOVERNMENT WITHDRAWAL OF HIS RULE 35 MOTION

The Clerk of the Eleventh Circuit Court of Appeals has dismissed attorney/Ponzi schemer Scott Rothstein's appeal of the District Court's order granting the Government's motion to withdraw it's motion for reduction of sentence, and denial of the Defendant's request for an Evidentiary Hearing. The dismissal, which was on purely procedural grounds, for for failure to file and Appendix within the time required by the Court.

Counsel for Rothstein, the Fort Lauderdale attorney who sold bogus court settlements of sexual harrasment and discrimination claims to investors, in a sophisticated Ponzi scheme, where Rothstein and his staff actually forged court documents and judicial signatures, has sought to reinstate the appeal, which has already seen a number of prior procedural errors and mistakes. The Court has not yet ruled on this issue.

The Government's motion to withdraw its pending Rule 35 Motion for Reduction of Sentence occurred after Rothstein attempted to improperly assist his then wife, and others, to secrete and sell valuable jewelry, to avoid its sale to repay victims. Kim Rothstein and two other individuals were convicted for their role in that illicit activity.

Rule 35 motions provide that the Government, in its sole discretion, may seek a reduction of an existing sentence from the Court, and that discretion is well-settled law, but Rothstein's counsel nevertheless sought to enforce the reduction, on the grounds that the motion failed to expressly provide for a method for its withdrawal. Rothstein, who has been in custody since 2009, and is being held in a secure location, drew a fifty-year sentence. While his official Release Date has not been published, a rough calculation shows him leaving Federal Prison sometime in the year 2051, at which time he will be 91 years of age.

CBI PASSPORTS ISSUED IN EUROPE AND THE CARIBBEAN MANDATE FACIAL RECOGNITION SYSTEMS FOR CUSTOMER IDENTIFICATION VERIFICATION

The nations of Europe and the Caribbean that offer Citizenship by Investment (CBI) programs have issued large numbers of passports to their applicants. Some of these CBI passport holders, when arrested, are found to be in possession of several passports, under multipe aliases and bogus identities. This poses a clear and present danger to international banks that accept affluent foreign clients, for their Customer Identification Procedures, as presently constituted, are ineffective to verify the identities of these individuals.

Why is this happening ? Some of the issues:

(1) Citizenship by Investment Units (CIU), under pressure to accept the vast majority of applicants, to meet budgetary goals of their government, intentionally scale back their due diligence inquiries, often at the express direction of their superiors.

(2) Corruption is a major factor, especially in nations with poor economices, and underpaid government officials and clerks. The lure of easy money, paid by or on behalf of criminal elements, is often too powerful to resist. Others are simply accepting bribes because it has become part of the CBI culture, particularly due to to payments by foreign-based CBI consultants, who gain extremely high commissions from each approved application.

(3) Technological gains, which have now advanced far beyond Photoshop manipulation and counterfeitting of documents, allow applicants to present seemingly authentic instruments, under names other than their own, which end up as clean identities on CBI passports.

(4) The translation or transliteration of names, from languages not using the Latin Alphabet, generally from Asia and the Middle East, means anyone making a small alteration of an applicant's true identity easy, and impossible to catch during due diligence. The result is a new identity, which computer searches of sanctions lists, conviction records, and blacklists will not spot.

Therefore, since you cannot trust the names appearing on CBI passports, as well as the underlying identity documents that were used to obtain them, only an examination of the images of the individuals  will be effective, and dispositive, in verifying the true identities you are seeking.

Facial recognition software platforms, which access social media and social networking resources, Internet images, visa photographs, official sources, proprietary image databases, CCTV and other image resources, are the only proven method of positive identification of targets. Data can be manipulated. counterfeited, altered or erased, even from official sources, and in official records.

Photographs which confirm identity of individuals, taken from a wide variety of outside resources not under the control of your target, will tell if you he is a Politically Exposed Person (PEP) hiding his identity, a member of an organized crime syndicate, a corrupt government official, a known terrorist financier, or simnply a legitimate international businessman. In this chaotic world of  document manipulation, which is made much more dangerous by the issuance of CBI passports to financial criminals, sanctions evaders, foreign intelligence agents and other high-risk individuals, only facial recognition software can cull them out of your new client list; Anything else will fail to extract the truth, resulting in an unacceptable level of risk on your part.

 

FOREX COMPANIES ENGAGE IN TRANSNATIONAL CRIME WITH IMPUNITY

A recent case, involving foreign exchange (Forex) fraud illustrates the transnational, unregulated nature of an industry that, to date, has been able to evade meaningful law enforcement suppresion. A California investor, who had a small amount placed with a Forex company, was solicited by a high-power salesperson, who convinced him that he could reap a 50% return, and who therafter placed a large sum with the company. When he sought to access his "profits," he was then talked into sending even more money, so that he could "draw" on his money. As you might have guessed, he lost it all, over $180,000, according to a report.

These Forex firms, often run by career criminals and fraudsters, are generally:

(1)   Incorporated in one tax haven jurisduction, which is totally opaque regarding beneficial ownership of company stock, and in a different part of the world from the clients a/k/a victims.

(2) Qualfied to do business in a second dodgy jurisdiction, with frontmen on the documents there. You have no chance to obtain redress through that country's courts, due to rampant corruption

(3) Maintaining bank accounts in a third offshore financial center. This is also a placew where you waste your money attempting to get justice in court.

(4) the company's owners reside in a country that does not extradite its citizens, allowing them safe haven from criminal prosecution abroad. This makes them bulletproof from their victims' criminal claims.

If an investor intends to participate in Forex, he would be best served by engaging a firm in his own country, after making sure, through due diligence, that it is reputable and dependable. When investors are lured by puffing statements of overseas firms, boasting of huge profits, it is too good to be true.

ARE CHINESE INTELLIGENCE AGENTS EMPLOYING CARIBBEAN CBI PASSPORTS TO OPERATE IN THE UNITED STATES ?

His Holiness, the Karmapa

This is Urgyen Trinley Dorje, the seventeenth Gyalwang Karmapa, the prominent Tibetan Monk, second only to the Dalai Lama in ranking. He is also the proud owner of a Dominica CBI passport, although how he was able to secure one is a bit of a mystery, as Tibetans are only issued ID cards by China, not passports. Just how did he prove his identity to Dominica's Citizenship by Investment Unit ? Perhaps the Chinese Government was able to assist him.

The Karmapa is currently living in the United States; he's reportedly been here for more than a year, reportedly not wanting to return to India, which has indicated that it will impose severe travel restrictions upon him, due to concerns about his close relationship with the Government of the Peoples' Republic of China.

Their Holinesses, the Dalai Lama and the Karmapa

The Chinese Embassy in Dominica, which amagingly disgorged over 900 Chinese nationals when a hurricane last threatened the country, is an oddity. Its size is completely disproportional to its stated mission. There is little commercial traffic between the Commonwealth of Dominica and China. A handful of foreign students, less than one can count on the fingers of your hands, and, except for foreign aid, such as weapons and armored cars, not much contact between the two governments.

Embassy of the Peoples' Republic of China, Dominica

 
The majority of Dominica CBI passport holders are  Chinese nationals; the same statistics are true for Antigua & Barbuda; St Kitts & Nevis also has a large number of its CIP applicants from China. How many of these supposedly "private businessmen" from China are, in truth and in fact, intelligence agents engaged in espionage in the United States ? We cannot say, but it might be interesting for American law enforcement to determine how many ethnic Chinese are residing in the US with CBI passport, and what activities are they engaging in while based here.

A FEW MORE DETAILS EMERGE ABOUT TURKEY'S MONEY LAUNDERING ARRESTS

DHKP-C flag

A few additional details have been made public, regarding the massive money laundering arrests said to have occurred in Turkey, involving funds alleged to have been routed to Iranians resident in the United States. Given that no specific information is avasilable, we are unable to confirm its accuracy; the Government of Turkey has, in recent years, made arrests that appear to have been made for purely political, and not valid law enforcement, reasons, so take this news with a grain of salt.

(1) 280, out of the total of 417 suspects originally stated, are said to be in custody in Turkey.

(2) The amount of money claimed to have been laundered through Turkish banks and financial facilities is in excess of $400m, employing over 28,000 bank accounts.

(3) The transferor groups that were  involved include Hezbollah, the Kurdish sanctioned organization, PKK, the Gulenist group, FETO, and the Revolutionary Peoples' Liberation Party-Front, DHKP-C.

(4) Those arrersted received commissions for making the transfers, were part of an organized structure, and were linked together.

PKK

It is at this stage impossible to determine whether Turkey is seeking to take advantage of the exposure of a major money laundering network to cast blame on some of its traditional opposition organizations, or whether they are legitimately involved in moving funds for Iranians.

ANTIGUA'S RESTRAINING ORDER ON LEROY KING VIOLATES ENGLISH COMMON LAW AND ECSC RULES

Privy Council: no jurisdiction here, Mr. King

If you were disturbed by the recent ruling of a judge in Antigua's High Court, preventing the extradition of Leroy King, the co-defendant of mega-Ponzi schemer Allen Stanford, to the US, to face a life sentence, you are not alone. The Court ruling, that King's request for a ruling as to whether he has a right of appeal to the Privy Council, from his adverse ruling at the Eastern Caribbean Supreme Court, was sufficient to stay his extradition, was not only error, it violates both ECSC rules and English Common Law.

To be more precise: King has NO right of appeal to the Privy Council, because his case to the ECSC was an appeal. The ECSC was acting as a court of last resort, and appeals to the Privy Council do not lie from ECSC rulings, when it acts as a Court of Appeal. You do not get more than one right of appeal; only one bite of the apple, so to speak; That's English Common Law.

The actions of the Antiguan judiciary, allowing one bogus appeal after another to be filed, for years, to keep Leroy King from telling US authorities what he knows about who in Antigua received those millions of dollars in bribes and kickbacks from Stanford, speaks volumes about the rampant corruption that poisons the country. Foreign investors, steer clear, for if you later have a bona fide grievance, the courts of Antigua are infected.    

WAKED FILES SECOND MOTION TO DELAY APPEAL PROCESS

 Nidal Waked Hatum,  a principal in Panama's Waked Money Laundering Organization, has for a second time, sought further delays in the US Attorney's appeal of the decision of the trial judge not to enter an Order of Forfeiture in his criminal case. Although Waked was convicted, and has served a short (27 months) sentence for money laundering conspiracy, the Court declined to enter a judgment for the $520m provided by statute, or even the $20m actually laundered.

Waked's counsel has alleged that his workload precludes his timely completion of his Brief of Appellee, and has, in support thereof, cited to two pending matters. The US Attorney has indicated no opposition to this, his second motion for aditional time, but we feel that time is of the essence, as grantingthge motion will give Waked additional time to transfer or secrete his global criminal proceeds, making their seizure more difficult, if not impossible.

I frankly do not buy the excessive workload excuse, for counsel for Waked has a number of highly qualified partners, any one of whom could prepare and file the brief. The whole thing fails the smell test, in our humble opinion. If the Waked Organization has investments in North America, which the US could reach with a forfeiture judgment, they will now have sufficient time to sell them, and transfer the proceeds. Delay often results in justice denied.

The Waked Clan (Panama)

In addition, Sr. Waked does not appear to have learned any lessons from his criminal case, and as soon as he returned to his native Panama, a picture of him with his extended family appeared in the local press, and he is far from expressing remorse for his money laundering crimes. He reportedly is suing banks in Panama, and the Government there, for $165m, for liquidating his business holdings. Did he forget that he was convicted in Miami Federal Court ? Will that not be admissible evidence against him ?

MASS MONEY LAUNDERING ARRESTS IN TURKEY; SUSPECTS MOVED MONEY TO IRANIANS IN USA

The Government of Turkey today announced that it has detained 417 individuals, under investigation on money laundering charges, for the movement of large amounts of foreign currency to the United States. Although few details are available, reports from Cyprus indicate that Turkish authorities allege that funds were mostly going to Iranian citizens resident in the United States.

Those arrested violated Turkey's criminal laws, as well as its laws regarding the financing of terrorism, according to reports. The funds were allegedly transferred through financial institutions, and through Automated Teller Machines (ATMs), and appear to have been "Smurfed" into accounts, in lesser amounts, through multiple deposits.

There is no indication of the political leanings of the recipients, who were not publicly identified, nor of the total amount Turkey claims were laundered and transferred to the US. The national currencies of both Iran and Turkey crashed this year against the dollar, but precisely why there was a massive operation, during the past year and a half, according to the report, is unknown. Iranians, unable to transfer funds through their sanctioned financial system, must report to intermediary countries, in order to transfer dollars into America, but the case remains a mystery, especially since Turkey has a history of using criminal charges for purely political reasons. There has been no release of any information on this case by American law enforcement agencies or financial regulators, which adds to the mystery.

 

IRAN SANCTIONS EVADER REZA ZARRAB SPOTTED BY JOURNALISTS IN NEW YORK RESTAURANT, NOT IN CUSTODY

Reza Zarrab, the Iranian "oil-for-gold" sanctions evader, who, with his partners Alireza Monfared and Babak Zanjani, orchestrated a $9bn operation that covertly sold Iranian petroleum around the world, and who pled out before trial in US District Court in New York, was recently seen by journalists, at Nobu in Manhatten. Notably, he was neither in custody, nor being escorted by FBI agents, which is puzzling, being that he faces substantial prison time. Photographers captured him with a female companion; his trademark beard is gone. Zarrab has not yet been sentenced, nor has a sentencing date been scheduled. They left in a Cadillac Escalade. It is not known whether his driver was also a bodyguard. 

His complete freedom, with only a driver to acceompany him and his date, might indicate that his level of cooperation is extraordinary in scope. There are a number of other probable targets in the New York case, and one should assume that the billions of dollars diverted by Zarrab and his partners are also of interest to the United States, for seizure and forfeiture.

 Legal observers believe that the  targets of the investigation include:

(1)  Financial professionals in Malaysia's obscure tax haven, Labuan, who moved the proceeds of sales. Oil tankers often anchored nearby, storing unsold product in the harbor of the offshore financial center.
(2)  Government officials and lawyers in the Commonwealth of Dominica, who sold the partners CBI and diplomatic passports, laundered the proceeds of crime, and registered the oil tankers in Dominica.

Obviously, there will be additional indictments handed down in this case, ands we will be monitoring the docket, reporting back on all developments as they occur.

IS CHINA ASSISTING MALAYSIAN FRAUDSTER WITH ST KITTS CBI PASSPORT ?

Jho Low, the Malaysian financial who stole billions from the state-owned 1MDB Fund, and who has artfully eluded arrest by pursuing Malaysian authorities, may be getting some assistance in his quest to flee to St Kitts, where his CBI passport will virtually guarantee extradition-free sanctuary. Low, who is Malaysia's Most Wanted Fugitive, is believed to have secreted many millions in SKN, so that he can spend the rest of his life in total luxury. St Kitts is home to a number of financial criminals wanted in their own countries.

According to Asian sources, Low, an addition to the 1MDB scandal, engineered the diversion of funds from the joint-Chinese-Malaysian infrastructure project, which Malaysia later cancelled. A number of Chinese government officials, who were allegedly the beneficiaries of bribes and kickbacks that Low stole from the financing, are believed to be helping Low evade Malaysian police agents dedicated to capturing him. Just how much due diligence did St Kitts CIP unit perform upobn Low's background, prior to issuing his CBI passport ?