TURKEY NAMES HALKBANK CEO, CONVICTED IN US, AS DIRECTOR OF STOCK EXCHANGE

Mehmet Atilla, the executive from Turkey's state-owned Halkbank, was named this week General  Manager of the Istanbul Stock Exchange, according to the country's Minister of Finance and Treasury Berat Albayrak. Atilla was released from US custody in July, after serving a term in Federal Prison for assisting in Iran's billion dollar oil sanctions evasion scheme. The Iranian oil-for-gold sanctions evasion trader, Reza Zarrab, testified against Atilla at trial.

The appeal of his conviction is pending before the Second Circuit in New York. Turkey, which alleged that the Atilla case case was politically motivated, obviously was a willing participant in the lucrative global oil-for-gold sanction evasions program operated by Reza Zarrab, Babak Zanjani and Alireza Monfared.  

While it is not specifically known why Atilla, who was the number two executive at Halkbank, did not return to a position at the bank, most countries have laws that prohibit convicted felons from serving as officers at financial institutions.

NEW OFAC REGULATION REQUIRES ALL US COMPANIES DEALING WITH FOREIGN CLIENTS TO MAINTAIN A SANCTIONS COMPLIANCE PROGRAM

The Office of Foreign Assets Control,  OFAC, has cleverly implemented an Interim Final Rule which will, in effect, require ALL companies that buy or sell goods and services to foreign entities or individuals to create, and maintain, an effective AML/CFT compliance program. While the Rule does not specifically require such a program, the only prudent response to its impact is to create one forthwith, to protect your company, not just those engaged in the delivery of financial services.

The previous law required any US company or person, to file a report with OFAC, when any transaction was blocked, due to OFAC sanctions. This usually means wire transfers, payment orders, or other types of payment. Now, if a US company decides to cancel, withdraw, or decline any business because the foreign party is OFAC-sanctioned, a mandatory report must be filed as well.

This means that OFAC will be alerted, and may review prior transactions with that foreign party, and could impose a Civil Penalty for violations. In that case, the absence of en effective AML/CFT compliance program is a major factor in possible mitigation or even elimination of a large fine; a company's failure to have, in place, a compliance program is always specified in the "Name & Shame" public notices that OFAC published on the Treasury website, under Civil Fines and Penalties.

You can review the complete text of the Interim Rule here.

Therefore, prudence demands that, if your company provides ANY services to foreign nationals or entities, you had best have a working compliance program in place at this time. Programs that meet Banking Best Practices are the ones to emulate. They feature:
(1) A designated compliance officer.
(2) A written compliance program.
(3) Regular training of staff and officers on the program.
(4) An outside audit, performed regularly, to insure that the program is operating properly.

Treasury is to be commended for its ingenious method of insuring that all relevant industries create a compliance program, with one simple regulation.

GRENADA SUSTAINABLE AQUACULTURE DECEIVED INVESTORS ABOUT ITS TRUE LOCATION

If you look at the contracts between Grenada Sustainable Aquaculture Company Limited and the investors, whom we now must regard as victims, its specifies that GSA is a Grenada company, and itS principal address is that of attorney MARGARET V.L.A. WILKINSON, who is also the Local Agent and Escrow Agent. The Agreement also specifies that any Notice filed pursuant to its terms is to be delivered to said agent. This creates a presumption that the company is local to Grenada.

Now look at the address which appears on the Internet, on websites of GSA. It shows it to be in Dubai, in the United Arab Emirates. Specifically, 108 Sheikh Zayed Road, in the Shangri-La Hotel, Office 703. Would someone like to explain that inconsistency ? If I was a prospective investor in GSA, I would assume that its officers and staff would be in Grenada, on site or nearby, in order to efficiently and effectively create the aquaculture project. Any attorney or investigator examining the facts would question the ability of GSA to build and complete the project from afar. As it turned out, the project was not only not completed, it appears to have never been started, causing Government to cancel it in its entirety.

Victims of the scam have advised that they were ordered and directed to send payment to the UAE, and to Singapore, both jurisdictions far from the stated Grenada construction sites. If this investment capital is truly intended to be used to constructed state-of-the-art aquaculture facilities, why was it being sent to the Middle East or Far East ? These and other questions remain to be answered before a determination can be made regarding whether criminal fraud was committed, and whether the project manager, and other company officers, as well as local agents, can be charged with a crime.

Individuals who have an interest in a GSA investment, and who require further information, may contact this blog at :  miamicompliance@gmail.com

ZEUS MALICIOUS SOFTWARE HACKERS WANTED BY FBI

WHAT HAPPENED TO THE MISSING $18m FROM GRENADA'S CANCELLED GSA PROJECT ?

Investors who made USD $275,000 payments into the failed Grenada Sustainable Aquaculture (GSA) Project, which had a buy-back guarantee from project owner and developer Soren Dawody, report that they have still not received their funds back, notwithstanding repeated promises from the developer, who has allegedly defaulted on meeting reimbursement schedules. Only a portion of their original investment were to be returned, and even those smaller sums were not to be fully repaid for three years. Where are these project development funds ?

While no accurate figures have been made public, it is estimated that GSA developers took in over $18m. The project was never initiated, and was eventually cancelled by the Government of Grenada in 2018, even though the developer reached its investment targets. The investors were promised six per cent annual returns after three years. Mr. Dawody has gone on involvement in a number of other projects in Europe and the Middle East, including a similar aquaculture program in Antigua & Barbuda, but the estimated sixty-five victims have never been repaid.

It is noteworthy that the GSA payments to the developer were not made into accounts in Grenada, but into accounts in the United Arab Emirates (UAE) and Singapore. Whether there is criminal liability for fraud, misappropriation or illegal diversion of funds, and money laundering, under the laws of Grenada, has been the subject of debate among legal observers; Dawody has been absent from Grenada for several months. and creditors of GSA have not received payment, which are other indicia of fraud. He is reportedly a resident of Canada, but presently lives in Dubai, UAE. Was the missing $18m invested in other Dawody projects ?

READ THE CIVIL SUIT MOSSACK AND FONSECA FILED AGAINST NETFLIX OVER "THE LAUNDROMAT"

  
A Federal District Court has judge denied a request for Injunctive Relief, in a Connecticut case filed against NETFLIX, to prevent it from giving its members access to the motion picture "The Laundromat," which they allege defames them in the movie's depiction of their reputed money laundering activities. We note that both MF partners have been charged, in the Republic of Panama, with a number of offenses. The Court transferred the case to California, according to media reports.

Readers who wish to review the complete text of the 42-page Verified Complaint may access it here.

IRANIAN HACKERS WANTED IN $30m SAMSAM RANSOMWARE SCHEME

COUPLE ARRESTED FOR ฿1bn DRUG MONEY LAUNDERING IN THAILAND FACE DEATH PENALTY

A husband and wife financial crime team in Thailand are looking at the death penalty, after they were arrested in a seizure of ฿100m in a drug money laundering case, linked to the country's largest drug trafficking syndicates. Naruepol Phapphathee and Patthama Buathong, named as the leaders of the ring, had  ฿25m in cash seized, including ฿5.5m hidden in a washing machine.


 A Thai criminal court sentenced a major money launderer to death earlier this year, and a similar sentence is expected in this case. Over 500 bank accounts have been identified with this laundering syndicate.
_____________________________________________________________________________
Note: 1 Thai Baht (฿) is is worth 3 1/3¢ (USD).

HEZBOLLAH TELLS ITS SUPPORTERS TO TARGET LEBANESE BANKS THAT FOLLOW US SANCTIONS AGAINST IT BY PROTESTING, ATTACKING AND STORMING THEM

Beirut's Bank Street

Arab media reports that Hezbollah has instructed its Shi'ite supporters to "attack and storm banks" in Beirut that adhere to US sanctions against it, its leadership and economic institutions. While the public statements call for public street protests. the fear is that such actions will lead to violence, disrupting bank operations, and thereby damaging the Lebanese economy.

Beirut banks are anxious to avoid the fate of Jammal Trust Bank (JTR Bank), which was forced into liquidation, after OFAC sanctioned it for providing financial support to Hezbollah, and a number of Hezbollah officials in Lebanese government were also targeted by US Treasury.

Other unspecified affirmative steps to confront the banks have apparently been approved by the terrorist organization, which wields serious political as well as military power within Lebanon, are reportedly being organized at the behest of Iran, which hopes to use the resulting chaos to force the United States back to the bargaining table; American sanctions upon Iran have had a major effect upon its economy, especially in international trade. Even though the US supports Lebanon, whether or not it will render concessions to Iran, to protect the Beirut financial structure, is doubtful.

Nevertheless, the threat of abrupt bank closures, due to damage as the result of organized violence by Hezbollah, remains a concern. Country Risk for Lebanon must now be substantially increased, as well as reducing any temporary financial exposure that is currently outstanding. 

IS THERE INSIDER TRADING AHEAD OF WHITE HOUSE PUBLIC ANNOUNCEMENTS ?

Insider Trading*, where an individual illegally profits by engaging in securities trades using non-public information he possesses, generally refers to intelligence about companies' future sale, merger, expansion, unveiling of new products, or other secrets, recent allegations surrounding what may be illegal use of upcoming announcements from the White House have emerged, with supporters, allies or associates of President Donald Trump as the guilty parties. Given the disrespect for the law by certain present or former government officials, Insider Trading on their part is not an unexpected event.

Controversial accusations that securities traders have earned $3.5bn, by trading in advance knowledge of public statements later issued by President Trump, have been appearing in major media, along with rumors that such conduct is under Investigation by the Securities & Exchange Commission, which enforces Insider Trading laws and regulations.

It is true that stock prices often rise or fall, based upon public policy statements made from the White House, especially regarding international trade issues with China, but they also can be affected by announcements regarding changes in American policies regarding foreign affairs, military deployments, and other critical international issues. The claim is that certain traders, who are the recipients, known in the securities industry as 'Tippees," are receiving this information, in advance of its public disclosure, and making obscene profits by executing stock trades based solely upon that intelligence. They would have received the advance information from someone in the White House, or from individuals who themselves received it from such a person.

Given that the maximum Federal prison sentence for Insider Trading is twenty years, or a five million dollar fine ($25m fir corporate entities), we hope and trust that transactions that appear to have been made after illegal and unauthorized receipt of inside information are thoroughly and properly investigated, and that criminal charges be brought where the evidence supports indictment.

It may also be necessary to inquire into whether the information, at one point, is classified, and that disclosure violates the Classified Information Procedures Act, which has a maximum 10 year sentence or a significant fine.
________________________________________________________________________
*A good definition: the illegal practice of trading on the stock exchange to one's own advantage through having access to confidential information.



 

RUSSIAN HACKERS WHO STOLE FROM US BANK ACCOUNTS

LETTER TO CONGRESSIONAL COMMITTEE INVESTIGATING TRUMP FROM RUDY GIULIANI'S COUNSEL

The President's private lawyer has refused to cooperate with the permanent Select Committee on Intelligence of the US Congress conducting the Impeachment investigation. Below is his letter.

US CHARGES TURKEY'S HALKBANK WITH FACILITATING $20bn IRAN OIL-FOR-GOLD SANCTIONS EVASION SCHEME

The Turkish state-owned TURKIYE HALK BANKASI A.S., trading as HALKBANK, has been charged, in a 6-count Indictment, alleging  the bank's involvement in a $20bn Iran oil sanctions evasion scheme. The operation, known as Oil-for-Gold, involved the bank's illegal facilitation of the transfer of billions of dollars in illicit profits, benefiting Iran.

Halkbank Deputy GM Mehmet Atilla and the Iranian oil trader, Reza Zarrab, have both been convicted for their roles in the scheme to evade US and UN sanctions on Iran. The allegations also accuse other Halkbank senior staff of participating in the lucrative sanctions evasion scheme.

The Counts:
(1) Money Laundering.
(2) Conspiracy to Commit Money Laundering.
(3) Bank Fraud .
(4) Conspiracy to Commit Bank Fraud.
(5) Conspiracy to Defraud the United States.
(6) Conspiracy to violate the IEEPA.

Readers who wish to review the complete text of the 45-page Superseding Indictment may access it here.

FRONT COMPANY USED BY RUSSIAN-AMERICANS IN ILLEGAL CAMPAIGN CONTRIBUTION CASE

Readers who wanted to see the Florida corporate documents of FRAUD GUARANTEE LLC, the front company that allegedly was used by two Florida businessmen, now under arrest, to move illegal foreign campaign contributions into the hands of American politicians may view it below. The Incorporator, Florida attorney Donald Allison, was a former Assistant United States Attorney during the same period that Rudy Giuliani was an Assistant Attorney General, and the US Attorney in New York.

FINCEN, SEC AND CFTC JOINT STATEMENT ON DIGITAL ASSETS