ARE YOUR BANK CLIENTS SELLING EQUIPMENT TO THE MIDDLE EAST GETTING END USER CERTIFICATES ?

If you don't have bank clients in the aviation industry, you probably missed the recent OFAC Advisory, Deceptive Practices by Iran with respect to the Civil Aviation Industry. That document showed the extent to which Iran has accessed prohibited US aviation technology and equipment, through third countries. No matter what your clients' field or industry, they must be on the alert for similar Iranian tactics, involving their products and services.

 For that reason, obtaining End User Certificates should never be an option,but a mandatory component of all sales to the Middle East, as well as Sub-Saharan Africa. OFAC will certainly come knocking, and your clients had better have an effective AML/CFT compliance program, as well as End User Certificates on file. It is suggested that they be signed by two senior officers of your clients' client, have the corporate seal, and be notarized, to verify that it is the act and deed of the recipient company.

Readers who wish to review the OFAC Advisory may access the complete text of the 8-page document here.   

TWO IRANIANS LIVING IN USA PLEAD GUILTY TO SPYING ON MEK MEMBERS

Two Iranian nationals residing in the United States have entered guilty plead in US District Court in Washington, DC, to a number of charges involving illegal surveillance upon Americans as illegal agents of the Government of Iran. The defendants are Ahmadreza Mohammadi-Doostdar, a dual citizen, and Majid Ghorbani, a legal resident.

The charges to which guilty pleas were entered:
(1) Acting as an Agent of the Government of Iran, without notifying the Attorney General.
(2) Conspiracy against the United States, a violation of 18 USC §371.
(3) Violating the IEEPA. (50 USC§1705).
(4) Violating ITAR. (31 CFR Part 560).

The defendants were collecting information on, and photographing, members of the Iranian opposition group, Mujahedin-e Khalq, better known as the MEK. One defendant reportedly monitored a Jewish Center in California. Trips to Iran, in connection with their illegal surveillance activities, were mentioned by the US Attorney (DDC) in an official press release. 

 They face sentences of up to twenty years in Federal Prison.

AFTER A DECADE OF DELAYS BY ANTIGUA, LEROY KING IS FINALLY EXTRADITED TO THE UNITED STATES TO FACE THE MUSIC IN $7bn STANFORD BANK SCANDAL

The last significant fugitive from justice in the seven billion dollar Stanford International Bank Ponzi scheme, Antigua's former banking regulator Leroy King has, at long last, been extradited to face multiple charges in the United States. King was observed, in the custody of the US Marshals Service, boarding an American Airlines jet, bound for the US.

King, whose misconduct prevented US regulators and law law enforcement from obtaining evidence for years, in their investigation of Allen Stanford's massive Ponzi scheme, was able to defer his 2009 extradition order for more than a decade. There's plenty of blame to go around; judges who sat on the case for years, then passed it along to another judge, courts that allowed King's attorneys to file a long string of "appeals" that he was not entitled to as a matter of law, and senior Antigua officials, who allowed the legal charade to continue. The King case caused a rift in what were previously good relations between Antigua and the United States.

Local Antiguan sources claim that King is terminally ill with cancer, but whether he is too ill to be tried at this time is not known. He does have first-hand knowledge of systemic corruption in Antigua during the Stanford era, which could result in additional indictments of former or present officials in the Government of Antigua, at the highest level, but it is questionable that he will ever testify.











 

   

RUSSIAN MILITARY INTELLIGENCE OFFICERS WHO INTERFERED WITH 2016 US ELECTIONS

IS IRAN EVADING US SANCTIONS THROUGH DOMINICA ?

Reports from the Commonwealth of Dominica have asserted that a large contingent of Iranian nationals attended the opening of a hotel there that offered investors a Dominica passport and citizenship, under the country's CBI program. Witnesses claimed that it appeared the Iranian guests were actually partners in the project, which was constructed by a company that operates out of the United Arab Emirates (UAE). (We are unable to confirm this information, and official sources insist that only one Iranian national was present at the opening.) What's true about the project ?

The hotel, which is classified as luxury, was built to attract wealthy investors, the magnet being that CBI passport, notwithstanding Dominica has a minimal tourist footprint, and whose economy, after a devastating tropical storm and subsequent hurricane, is in tatters. There is no international airport, and visitors must first travel to adjacent counties to gain access. Notwithstanding the situation, a typical lunch at the hotel came to EC$942. ( official sources say this was for a six-person lunch, but we believe that food bill is still very high). Government insists that the positive cash flow generated by the CBI program is beneficial to the country, irrespective of the questions about whether there will be increased tourism as the result of hotel construction.

As many as 800 CBI passports are alleged to have been issued to investors in the hotel, and prominent local residents in the Opposition claim that a number of those have been issued to Iranian nationals. Unfortunately, due to government policy, we cannot confirm many Iranians hold Dominica CBI passports.(Government says the largest group of CBI investors at that project are Chinese nationals). Given Dominica's history of association with Iranians engaged in the billion dollar oil-for-gold sanctions evasion scandal ( e.g. Alireza Monfared) the question on the minds of  Dominicans is whether any Iranians, holding Dominica CBI passports, which give them visa-free entry to many Western countries, are exploiting them to engage in a new phase of international sanctions evasion. There is no publicly-available information on this issue.

While CBI passport holders from high-risk countries may not be able to open bank accounts once inside Dominica, they are free to employ those passports elsewhere in the developing world, and there are concerns that, once they are established elsewhere, sanctions evaders from countries like Iran. with new identities, will have access to North America and the EU. In that manner, Dominica may be unwittingly facilitating sanctions evasion schemes abroad.

To add to the fears, unconfirmed reports abound of late in Dominica that appear to support previous rumors to the effect that Iranians have been trafficking hard drugs, coming from Southeast Asia, through Dominica. These stories have again surfaced during the ongoing trial, in Iran, of the suspected former Iranian intelligence agent, Alireza Monfared, who together with his conspirators, faces the death penalty for diverting billions of illicit Iranian oil profits to his personal accounts. Is Iran engaged in narcotics trafficking in the Caribbean, to raise money, much as Hezbollah does ? if so, are they using Dominica to achieve their goals ?

There are many questions surfacing, regarding Iran's influence in poor, and thoroughly corrupt, Dominica, run by a leftist leadr for the past two decades, who uses his wealth to remain in power at election time, and who openly associates with regimes in Latin America that are allied with Iran. We wonder when the answers will be forthcoming.        

MABNA GROUP WORKS FOR ISLAMIC REVOLUTIONARY GUARD CORPS

GRENADA GSA PROJECT FRAUDSTERS ALSO CHEATED ANTIGUA THROUGH THEIR ASA PROJECT

For those individuals who are disturbed by the failed Grenada Sustainable Aquaculture Project, which took in a reported eighteen million US Dollars, and was never built, but are not persuaded that the conduct constituted fraud, look at what the project managers did in nearby Antigua; they engaged in the same conduct in what is known as the Antigua Sustainable Aquaculture Project, also known as ASA.

ASA is a cookie-cutter copy of Grenada's GSA; both are utter failures. Not only are the investors defrauded, but the contractors, experts and aquaculture consultants were not paid for their work. Placing both websites side by side, readers can easily see the same marketing techniques, which extol the virtues of the projects, but cleverly fail to detail the operators' track record, because they had absolutely no prior experience in this field.

How the Governments of Grenada & Antigua ever approved it for its CBI program remains a mystery. Even the most basic due diligence investigation would have revealed that the promoters are completely unqualified to build and operate such complex environments. Will the victims choose to hold the two governments accountable for their financial losses ? That is the question.

ANTIGUA'S FUGITIVE REGULATOR, LEROY KING, LOSES LAST APPEAL, FACES EXTRADITION TO USA IN $7bn STANFORD BANK PONZI SCHEME

Leroy King, the former head of Antigua's Financial Services Authority (FSA), the country's banking regulator, reportedly faces imminent extradition to the United States, after the Privy Council, the country's court of last resort, declined to rule in his favor, and sent the case back down to enforce the Extradition Order.

King's case has been pending for ten long years, after an infinite number of unexplained cout delays, repeated judicial reassignments, appeals filed allowed by the judges which were not authorized by law, and obvious government influence upon the judiciary, all contributed to justice denied, and which demonstrated Antigua's corrupt judicial system, and lack of adherence to the Rule of Law. The case may have contributed to a decline in foreign investor confidence in the country, and decreased foreign investment in recent years., which has negatively impacted Antigua's anemic economy.

Some observers still believe that King will never be extradited to the US, where he faces what amounts to a Life Sentence, for his central role in in the Stanford International Bank multi-billion dollar Ponzi scheme. While FSC head, he held US regulators at bay for years, allowing Allen Stanford to perpetrate a Ponzi scheme exceeded only by Bernard Madoff's in scope and duration.

It is alleged that he could implicate very senior present and prior members of Antigua's government, and some experienced Antigua watchers doubt that King will actually be extradited; they worry that he faces physical danger, given what previously happened to the country's UN diplomat, who was believed to have evidence of official corruption at the highest level when, facing sentencing in an American court, he died under suspicious circumstances.

Will Leroy King actually be extradited to the United States, and tried in Federal Court in the State of Texas for his crimes  ? We cannot say, so please stay tuned.

HALKBANK ATTORNEYS SEEK DISMISSAL OF CRIMINAL CHARGES IN FEDERAL COURT THROUGH OBSOLETE TACTIC

If you remember your class in English Common law, an attorney could enter what is known as a Special Appearance, to contest personal jurisdiction. in essence, the lawyer was not submitting his client to the jurisdiction of the Court, but employing an archaic tactic whereby he appeared solely for a limited purpose. It was a legal fiction that allowed counsel to argue one issue, without subjecting his client to the court's jurisdiction. Technically, counsel is really not there for the purpose of what we call a General Appearance.

Needless to say, today's Federal Rules do not permit a criminal defense lawyer to file a Special Appearance, but that did not stop counsel for the Turkish government-owned Halkbank from attempting to invoke that obsolete remedy at common law. The bank, accused of facilitating Iran's billion dollar oil sanctions evasion program, asserts that the Court has no jurisdiction over it, as it has no offices or branches within the United States. They allege that the banks was not properly served with process. The bank's lawyers also was the sitting judge to recuse himself.

Judging by the Court's remarks, the bank argument, which reportedly has no legal authority in the Southern District of New York, and the Second Circuit, was not well received. Additionally, similar arguments were made, and settled, during the prior case against bank official Hakan Atilla, who was convicted for his role in the sanctions evasion scheme, and has already served his sentence.

The court gave bank counsel additional time to brief the bank, and to report back at a future date.

$25m RECOMPENSE POUR INFORMATION - ROBERT LEVINSON

The Rewards for Justice program has increased the reward for information leading to the recovery and return from Iran of former FBI Special Agent Robert "Bob" Levinson to a total of $25,000,000 .

1MDB BILLION DOLLAR JHO LOW BOUGHT CYPRUS CBI PASSPORT WHEN UNDER CRIMINAL INVESTIGATION

Jho Low, the high-flying Malaysian financial fraudster and money launderer who is presently a fugitive from justice in a number of countries, purchased a CBI passport from the Republic of Cyprus in 2015. At the time Jho secured the passport;

(1) He had fled his native country, after he came under suspicion for money laundering.
(2) He had been accused of fraud and violation of financial regulations.
(3) He had been classified High Risk in a 100-page investigative report furnished by a major global resource.

Did Cyprus actually ignore all of the above, when it reportedly conducted Due Diligence on Jho for his application ? Taking the above facts as true, it appears that either no Due Diligence was conducted, or problems uncovered when it was were ignored, in favor of the cash payments made by Jho.

Jho who also has a St Kitts & Nevis CBI passport, is a fugitive from justice, reportedly living in China.

  


 

GRENADA GSA PROJECT FRAUDSTERS USED SINGAPORE BANK ACCUSED OF LAUNDERING BILLIONS IN 1MDB SCANDAL

      

When the investors asked for wire transfer information in the Grenada Sustainable Aquaculture (GSA) project, they were directed to send payment, but not to the Grenada escrow agent, or a local financial institution, but to banks in the United Arab Emirates or Singapore. Given that the funds were earmarked for paying companies to construct and maintain sustainable shrimp and fish farms in Grenada, the wire instructions are disturbing, especially since, three years later, none of the facilities have been built out, none of the contractors and consultants have been paid, and none of the investors
have been repaid.

The Singapore bank that was designated to receive GSA funding is DBS Bank, formerly known as the Development Bank of Singapore Limited. DBS is presently embroiled in Malaysia's S$3.5bn One Malaysian Development Investment Berhad [Fund] (1MDB) scandal; it was hit with a S$1m fine by the Monetary Authority of Singapore (MAS) for money laundering violations and certain senior bank officers were hit with orders and sanctions. The bank's role in the scandal was known when the GSA project began accepting payments through it, and continued, notwithstanding that no prudent project manager would allow a bank accused of massive money laundering to continue to receive investor funds, unless he was himself involved in financial crime.

Even if we assume that it was proper and correct for GSA management to employ DBS to hold its funds, we cannot think of a more inappropriate bank for that purpose. DBS has only one  facility in the Western Hemisphere, and it is remotely located in California. All the project contractors, experts and consultants have their principal places of business  close to Grenada. How were they to be paid ? Obviously not. The investors who were defrauded, as well as the unpaid contractors, have been unable to contact Soren Dawody, the Iraqi with a Swedish passport,  who has not been seen in Grenada for years. 

FACIAL RECOGNITION TECHNOLOGY: ACLU SUES FBI, DEA AND DOJ FOR THEIR RECORDS OF USE

The American Civil Liberties Union (ACLU) brought a civil action this week, in Federal Court, against the Federal Bureau of Investigation, the Drug Enforcement Administration, and the Department of Justice, seeking extensive records of those agencies' use of facial recognition software (FRS). The plaintiff demanded documents that detail how they use and audit FRS, how they interact with the private sector firms that create and provide the software, and what agency internal procedures are in place to guide, regulate and safeguard use of FRS. Law enforcement agencies use FRS to identify suspects and witnesses in criminal investigations.

The suit was filed after the agencies failed to timely respond to repeated Freedom of Information Act requests. The FBI Next Generation Identification database reportedly contains more than 30,000,000 photographs. Another FBI resource, known as FACE, for Facial Analysis, Comparison and evaluation, holds over 640 million images.*

Readers who are interested in this subject may access the Complaint here. The style is American Civil Liberties Union of Massachusetts vs. United States Department of Justice, Federal Bureau of Investigation, and Drug Enforcement Administration,  Case No.: 19-cv-12242 (D Mass).

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* Compliance officers who use FRS for Customer Identification are reminded that they should only use photographic databases containing high-resolution headshot-quality images, and avoid low quality social media images, which can result in misidentification. 

GRENADA SUSTAINABLE AQUACULTURE PROJECT FAILED TO PAY ITS EXPERTS AND TECHNICAL SUPPORT CONSULTANTS

While there is a great deal of anger, from investors, rightly complaining that that they were cheated, directed at Soren Dawody's failed Grenada GSA project, the experts and technical support staff who were engaged to actually construct the sustainable aquaculture facilities are also quite vocal in their  oral and written statements about the massive eighteen million dollar fraud. The reason: they were not paid any of the fees and costs that they are owned by GSA, pursuant to contracts they signed with Dawody.

The stated plan was that Dawody would raise capital from foreign investors, who would receive a Grenada CBI passport, and also fund the aquaculture project. The technicians were never paid, the facilities were never built out, and project manager Soren Dawody, whose companies received the $18m, has chosen not to return to Grenada from abroad, where he has an immigration consultancy business. Whether there is criminal liability for fraud, and who should be charged, has not yet been ascertained.

Correspondence from the individuals and technical support companies that were to build the facilities indicates that they have blamed the Government of Grenada for inadequate supervision and monitoring of GSA, and asserted that government is liable to them for their fees and costs, and possibly also damages. Government was not a party to the Share Sales Agreement, but it could be found liable by a court of competent jurisdiction, should litigation ensue, which is likely. Meanwhile, there are a lot of very unhappy contractors wanting to be paid, and holding Dawody strictly liable for GSA's legal obligations. Government initiated an investigation into the project earlier this year.



 

GOZNYM MALWARE HACKERS; ALSO WANTED FOR MONEY LAUNDERING