READ LEBANESE/HEZBOLLAH TERRORIST FINANCIER NAZEM SAID AHMAD's GLOBAL MONEY LAUNDERING THROUGH LUXURY GOODS OPERATION

A GLOBAL NETWORK*

With operations in Beirut, Lebanon; Dubai, United Arab Emirates; Johannesburg, South Africa; and Hong Kong, Nazem Said Ahmad directs a global network of family members, associates, and companies that take advantage of the permissive nature of the global diamond, precious gems, and art market to facilitate payment for, and shipment and delivery of, luxury goods. The network utilizes legal and illegal arrangements to coerce both witting and unwitting participants into falsely engineering certificates, which are required under the Kimberley Process, to manipulate diamond prices and taxes, and to give their business the appearance of legitimacy. The network also uses aliases, front companies, and fraudulent paperwork to enable Nazem Said Ahmad to purchase or consign high-priced luxury goods and artwork from auction houses and galleries worldwide. The network undervalued invoices for imported goods and cleared bulk items through seaports, leveraging Hizballah’s influence at these ports of entry to move assets into Lebanon without paying the applicable taxes and duties.

Nazem Said Ahmad eludes safeguards within the U.S. and international financial system by using associates and front companies that transact on his behalf, while also clandestinely storing large amounts of currency outside the reach of Lebanese banking officials and regulators. To circumvent cash reserve restrictions set by central banking authorities and avoid scrutiny by the Lebanese and international banking communities, the network facilitated a complex scheme of bulk cash transfers, intra-network accounting book transfers, and payments from personal bank accounts and credit cards for business transactions. Nazem Said Ahmad’s associates, along with their legitimate and illegitimate businesses, played an important role in the overall scheme by engaging in “layering,” the name used for the stage in a money laundering operation that disconnects proceeds from the nefarious activity that generated them. Trusted couriers transported cash and other tangible assets, such as diamonds and art, for the financial benefit of Nazem Said Ahmad, his family, and his close associates.

The luxury goods and art market has been an ideal avenue for Nazem Said Ahmad and his co-conspirators to move funds out of Lebanon, capitalizing on schemes to overvalue and undervalue artwork and Nazem Said Ahmad’s background as an experienced collector to exploit the industry’s practices. Since 2012, Nazem Said Ahmad has acquired over $54 million in works of art from major auction houses, galleries, and exhibitions, or even directly from artists’ studios, often concealing his beneficial ownership by having official invoices drawn up using cover companies, family members, or business associates as the owners.

Map of international money laundering and sanctions evasion network of Hizballah Financier Nazem Said Ahmad

 

KEY FACILITATORS AND ASSOCIATES

Nazem Said Ahmad’s Family Members

Firas Ahmad, Nazem Said Ahmad’s son, handles many of his father’s business affairs in South Africa. Firas Ahmad is the director of South Africa-based diamond company Mega Gems (PTY) LTD (Mega Gems) and controls another diamond company, Thula Uzwe Trading, also in South Africa.

Firas Ahmad obfuscated his ultimate beneficial ownership of Mega Gems through a front company, Oriental Dynasty Limited, directed by his wife, Rim Nasser, who acted as a nominee shareholder. Concealment of his ultimate beneficial ownership is a common tactic used by Nazem Said Ahmad, which his children have also adopted to insulate themselves from legal scrutiny and assist in sanctions evasion schemes on behalf of their father.

Since 2018, Nazem Said Ahmad’s daughter, Hind Ahmad, has brokered deals on behalf of her father, as well as coordinating the creation of an alias to help her father evade sanctions and purchase artwork from U.S. companies. Hind Ahmad also acted as a broker for the sale of art in the ultimate beneficial interest of her father, including approaching witting and unwitting studios and galleries to change the provenance line of certain pieces to make their onward sale more attractive to prospective buyers. Hind Ahmad directly owns and operates two galleries, Artual Gallery in Beirut, Lebanon and DIDA in Abidjan, Côte d'Ivoire. She is also indirectly associated with several other galleries but has obfuscated her connections to these entities to insulate them from the impact of her father’s designation.

Rami Baker, Nazem Said Ahmad’s brother-in-law, is a close friend and business associate who served as a proxy for Nazem Said Ahmad in many companies in Lebanon and Angola. On behalf of Nazem Said Ahmad, Rami Baker is the proxy owner of United Investment Group SAL, a Beirut-based real estate company that develops luxury real estate projects. Rami Baker is also the trustee for the 76 Benmore Gardens Trust that manages the expansive property portfolio owned by the Ahmad family in the Johannesburg area, including the home inhabited by Firas Ahmad, Rim Nasser, and their family. Rami Baker also owns a Romania-based company, Collecting Bee SRL.

Nazem Said Ahmad’s wife, Rima Baker, served as a proxy for Nazem Said Ahmad for both the purchase as well as the consignment of works of art in his collection. Additionally, the network used her name to circumvent UK anti-money laundering procedures covering art market transactions related to a purchase of a work of art from a London-based gallery in the interest of Nazem Said Ahmad.

Rima Baker is the majority shareholder of Beirut-based Park Ventures SAL and a Beirut-based real estate company Debbiye 383 SAL. Park Ventures SAL handled the shipping and logistics of importing millions of dollars of art from U.S. and foreign art galleries into Beirut, and circumvented U.S. sanctions through a proxy ownership structure that purposefully registered shares of the company in the names of Rima Baker and Hind Ahmad.

Hind Ahmad’s husband, French-Senegalese national Da’ud El Riz, facilitated the acquisitions by his wife and conducted personal and professional business transactions for the benefit of his wife and her galleries. Several of these transactions were the subjects of a scheme to undervalue invoices in a manner that would allow the network to circumvent taxes and duties levied on high-value imports by the Lebanese government.

 

Nazem Said Ahmad’s Business Associates and Accountants

Mohamad Hijazi directs Dubai-based White Star DMCC, a front company that was used as the primary financial front for Nazem Said Ahmad to purchase art imported both legally and illegally into Lebanon. Mohamad Hijazi maintained a financial ledger that detailed cash transactions, intra-company book transfers, personal bank account transfers, and credit card transactions, in addition to the use of White Star DMCC’s multiple bank accounts for cross-border payment settlements. Many of the transactions listed in the ledgers recorded the movement of cash to Lebanon for use by Nazem Said Ahmad or remitted to Firas Ahmad or Rami Baker for their personal or business operations. Mohamad Hijazi also coordinated with Hind Ahmad to create an alias to facilitate the purchase of artwork from U.S. companies, and his identification was used to circumvent UK anti-money laundering procedures covering transactions related to the purchase of a work of art from a London-based gallery in the interest of Nazem Said Ahmad.

Sundar Nagarajan acted as Nazem Said Ahmad’s primary international accountant, providing material support through his management of, and accounting for, businesses in Nazem Said Ahmad’s network. Sundar Nagarajan was the central manager of financial ledgers detailing the network’s operations in Hong Kong, the United Arab Emirates, and South Africa. Sundar Nagarajan also facilitated payment for and shipment of art that Nazem Said Ahmad purchased from major auction houses and galleries.

In many cases, Nazem Said Ahmad would personally negotiate the purchase of art from artists and galleries via email or messaging on a social media platform. He would then direct Ali Mossalem and Mohamad Ismail, both Beirut-based accountants in Nazem Said Ahmad’s employ, to coordinate all logistics related to the payment of invoices, shipment, and delivery of art, including the customs process at Lebanese ports of entry.

Mohamad Ismail facilitated the payment, shipment, and delivery of art that Nazem Said Ahmad purchased, including acting as a personal courier to ferry works of art from European galleries to Lebanon. Mohamad Ismail also coordinated the collection of rental income for tenants of properties owned by Park Ventures SAL and coordinated with outside accountants to prepare tax documents for companies such as Park Ventures SAL and Blue Star Diamonds SAL—Offshore, a Lebanese company previously designated for its connection to Nazem Said Ahmad.

Mohamad Ismail directs, owns, or controls several trading companies, including Lebanon-based Ismail General Trading; Lebanon-based Joud General Trading; Sofia, Bulgaria-based TIA Trading 2013 OOD; and Lebanon-based Associates of Partners SAL.  

Ali Mossalem also coordinated with Hind Ahmad regarding the creation of false invoices for pieces of artwork on behalf of Nazem Said Ahmad and conspired to draw up false invoices under the name of Rami Baker or United Investment Group SAL.

Ali Osseiran, who directs three Dubai-based companies, Best Diamond House DMCC, G and S Diamond FZE, and Bexley Way General Trading LLC, facilitated the payment, shipment, and importation of works of art purchased by Nazem Said Ahmad from major auction houses and international galleries. Dubai-based company IDIAMS DMCC was involved in several of these art purchases. Maricel Francisco is an employee of Bexley Way General Trading LLC who has handled payments for art purchases through companies controlled by Ali Osseiran.

Fadi Sader, a dual Canadian-South African national of Lebanese origin, has provided material support to Firas Ahmad. Fadi Sader directs, owns, or controls Hong Kong-based House of Art Limited, Hong Kong-based Fadico HK Limited, and South Africa-based Fadico S A CC. Mega Gems, a company directed and indirectly owned or controlled by Firas Ahmad, acted as a sister company with House of Art Limited to serve as the network’s conduit to clientele in Asia looking to purchase polished stones or finished jewelry, with Mega Gems serving as the intermediary to rough diamonds in Africa. Fadi Sader and his businesses also acted as a hub for art and luxury goods to be sold at or purchased from Hong Kong-based auction houses or other vendors in the Pacific, including acting as a courier for a work of art purchased on behalf of Nazem Said Ahmad, personally transporting the item from a Hong Kong auction house to Lebanon.

Mohamad Wehbe, a Lebanese national and co-director of Mega Gems and sole director of Gavia Tradings (PTY) LTD, provided material support to Firas Ahmad by handling a variety of business operation functions for Firas Ahmad’s business ventures in South Africa. This included assisting Firas Ahmad in changing the ownership structure of South Africa-based Thula Uzwe, allowing Firas Ahmad to be the authorized representative for rough diamond purchases, with the hopes of expanding the company into new markets. Mohamad Wehbe was also a director of South Africa-based, real estate holding companies Oxfocento (PTY) LTD and Diotrix (PTY) LTD.

Bassem Murad is a Belgian national who owns, controls, or directs Antwerp, Belgium-based M.S.D., South Africa-based MSD Capital (PTY) LTD, Dubai-based MSD DMCC, and South Africa-based MSD SPRL Diamond Trading. Both Bassem Murad and MSD SPRL Diamond Trading are involved in the business venture for the design, development, and construction of a new diamond center to house the offices and facilities for Mega Gems and other diamond businesses owned or directed by the directors of Oxfocento (PTY) LTD and Diotrix (PTY) LTD. Bassem Murad also conducted transactions or acted as a pass-through for funds in the interest of Firas Ahmad in a money laundering layering scheme.

Hussein Nachar is a longtime associate of Nazem Said Ahmad, who operated with the total confidence of Nazem Said Ahmad while the 50 percent owner of DRC-based company, Primo-Gem Diamond, which was associated with money laundering, tax evasion, the blood diamond trade, and financial support to Hizballah. Between 2020 and 2021, Hussein Nachar and Ali Nachar engaged in transactions with Firas Ahmad, many of which were likely in cash and circular in nature, a practice which is known to be an indicator of money laundering.

Fadi Abbas Saad conducted transactions for funds in the interest of Firas Ahmad in a money laundering layering scheme. Fadi Abbas Saad was also Firas Ahmad’s proxy director and shareholder of Oriental Dynasty Limited from 2015 to 2018, prior to Firas Ahmad’s wife Rim Nasser relieving him of this position.

 

Additional Businesses

Dubai-based diamond company Amana Diam DMCC was used as a pass-through business in a money laundering scheme on behalf of Rami Baker. Antwerp-based diamond company Helics Gemb BVBA acted as a broker for Amana Diam DMCC for sales of over $18 million in the first half of 2022 and was likely engaged in suspicious trades in diamonds.

 

Individuals and Entities Designated Today

Sundar Nagarajan, Ali Mossalem, Mohamad Hijazi, Firas Ahmad, Mohamad Ismail, Hind Ahmad, Rima Baker, Rami Baker, Ali Osseiran, Ibrahim Ghaddar, Mohamad Khawaja, White Star DMCC, Best Diamond House DMCC, Bexley Way General Trading, G&S Diamonds FZE, United Investment Group SAL, and Idiams DMCC are being designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Nazem Said Ahmad. 

Rim Nasser, Fadi Sader, Mohamad Wehbe, Bassem Murad, Ali Nachar, Fadi Abbas Saad, Hussein Nachar, and Fadico HK Limited are being designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Firas Ahmad. 

Amana Diam DMCC is being designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Rami Baker. 

Daoud El Riz is being designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Hind Ahmad.

Maricel Francisco is being designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Ali Osseiran.

Helics Gemb BVBA is being designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Amana Diam DMCC.

Gavia Tradings (PTY) LTD and Oxfocento (PTY) LTD are being designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, directly or indirectly, Mohamad Wehbe.

MSD SPRL Diamond Trading is being designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Oxfocento (PTY) LTD.

High Rise Property Investments (PTY) LTD is being designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Oxfocento (PTY) and Diotrix (PTY) LTD.

Mega Gems (PTY) LTD, Oriental Dynasty Limited, and Thula Uzwe Trading are being designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, directly or indirectly, Firas Ahmad. 

House of Art Limited is being designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Mega Gems (PTY) LTD.

Artual Gallery and DIDA are being designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, directly or indirectly, Hind Ahmad.

*NOTE: we are publishing here the information that appeared earlier this year on the US Treasury website, as it has not received anywhere near the exposure in the financial press that it deserves.

DON'T EXPECT MEANINGFUL REFORM ON CBI PASSPORT PROGRAMMES FROM THE EAST CARIBBEAN STATES: IT'S ALL A MATTER OF RAMPANT CORRUPTION

Whilst the United Kingdom, whose policy of visa-free access to several of its former East Caribbean territories is about to be rescinded, for totally valid national security reasons, Britain has agreed to keep it in place, provided that meaningful reforms, which greatly reduce risk, are enacted and enforced. The problem is, we simply cannot trust the five East Caribbean CBI states to change how they do business, due to systemic official corruption a/k/a greed, and the lure of easy money to dysfunctional and failing island economies.

The UK, according to reliable reports, has laid down the law to its straying former caribbean possessions. If they truly want to retain visa-free entry rights for their citizens, which of course include their CBI passport purchasers, they must initiate enhanced due diligence upon all applicants, must have actual applicant interviews, and must require personal visits by the recipients to pick up their travel and citizenship documents upon approval. This is in line with what are best practises in the economic passport industry.

However, given the past history of these states' allowing dodgy applicants to be approved without any meaningful customer due diligence, and ignoring the need to verify both Source of Funds and Source of Wealth, making the application process a sham, and allowing some very unsuitable transnational criminals, corrupt PEPs, and several other types of what we can only describe as the Usual Suspects to buy passports for cash, we cannot trust the jurisdictions to do the right thing. Bribes and kickbacks, as well as behind-the-scenes sales of diplomatic passports to the same applicants, all add up to a perfect storm of unacceptable, and yes even criminal, behaviour. 

They're not going to clean up their activities, due to the lucrative nature of the corrupt operation of their CBI agencies, as well as the non-attorney sales representatives abroad, who are totally unregulated, making it more likely each time that serious shortcuts in CDD occur, and that criminals will continue to be approved, notwithstanding their amendment of regulations and policies, and public relations efforts.

It is humbly suggested that the UK Home Secretary yank the visa-free access to the remaining four EC CBI states forthwith, and only reinstate such privileges if and when true reforms occur on the ground in St. Kitts, Antigua, St. Lucia & Grenada, and only return such status to Dominica if and only if real EDD is implemented and observed. To do otherwise will not reduce the threat to national security that presently exists, due to rampant abuse. Stop visa-free access to reduce risk, please. 

__________________________________

For Further Reading:

Did the UK Revoke Visa-free Access Privileges for Dominica's Citizens due to entry of Terrorists with CBI Passports?

READ DFSAs SCATHING REPORT ON SWISS BANK'S CHOICE OF PROFIT OVER COMPLIANCE OBLIGATIONS; SPEAKS VOLUMES

Compliance officers should take the time today to go on the website of the Dubai Financial services Authority, and read its Decision Notice on the Middle East branch of the Swiss Bank Mirabaud. The 48-page document, which imposes a major (USD$3m) civil fine upon the bank, reads like something out of a compliance lecture on what not to do. Whether it is discussing compliance failures regarding Politically Exposed Persons (Peps), massive due diligence shortcomings, the report shows that the bank totally and completely ignored banking best practices, while taking in fees that actually exceeded customer profits. Perhaps the names of the bank's senior officers might be an appropriate method of deterring others. Frankly, heads should roll in the bank's executive suite, and I don't just mean in Dubai.  

Obviously, the bank, whose obsession over fees trumped its compliance obligations, deserves to be named & shamed. We tip our hat to the DFSA for showing that Dubai's regulators are not only taking their obligations seriously, that they will specifically detail AML failures of financial institutions as a warning regarding what they will not tolerate in their financial marketplace. 

Go on the DFSA website and read the report:

dfsa.ae/what-we-do/enforcement/regulatory-actions 

RUSSIAN COMPANIES AND INDIVIDUALS SANCTIONED BY EU FOR CONDUCTING DISINFORMATION CAMPAIGNS AGAINST UKRAINE, INCLUDING FAKE WEBSITES

Name Identifying information Statement of Reasons Date of listing ‘1578. Timofey Vladimirovitch VASSILIEV Тимофей Bладимирович ВАСИЛЬЕВ A.k.a. Timofey VI Тимофей ВИ Function: Head of the Department for strategic guidance of ANO Dialog POB: Moscow, Russian Federation Nationality: Russian Gender: male Timofey Vassiliev is the Head of the Department for strategic guidance of ANO Dialog, a Russian non-profit organisation created by the Moscow Department of Information and Technology (DIT) in 2019 and linked to the presidential administration, which has been disseminating online propaganda about the illegally annexed territories in Ukraine. Timofey Vassiliev, runs the popular “fact-checking” Telegram account and subsequent domains “War on Fakes” which spread disinformation about the Russian war of aggression against Ukraine. Therefore, Timofey Vassiliev is responsible for supporting and implementing actions and policies which undermine and threaten the territorial integrity, sovereignty and independence of Ukraine. 28.7.2023 1579. Ilya Andreïevitch GAMBACHIDZE Илья Андреевич ГАМБАЧИДЗЕ Function: Founder of Structura National Technologies and Social Design Agency Nationality: Russian Gender: male Ilya Gambachidze is the founder of Structura National Technologies and Social Design Agency, two Russian entities involved in the Russian-led digital disinformation campaign “RRN” (Recent Reliable News) aiming at manipulating information and sharing disinformation in support of the Russian war of aggression against Ukraine. Ilya Gambachidze formerly worked as a counsellor to the Vice-President of the Duma, Piotr Tolstoi. Structura National Technologies and Social Design Agency has been identified as the key actor of the campaign, responsible for the creation of fake websites impersonating government organisations and legitimate media in Europe (primarily Germany, France, Italy, Ukraine and the United Kingdom) and for boosting the pro-Russian “RRN” campaign on social media. Therefore, Ilya Gambachidze is responsible for supporting and implementing actions and policies which undermine and threaten the territorial integrity, sovereignty and independence of Ukraine. 28.7.2023 1580. Aleksandr Gennad’yevich STARUNSKY Александр Геннадьевич СТАРУНСКИЙ Function: Founder of the Institute of the Russian Diaspora DOB: 12.6.1970 Gender: male TIN: 771989171763 Aleksandr Starunsky is a Russian military intelligence officer and former commander of GRU PsyOps unit 54777. He is a founder of the Institute of the Russian Diaspora, a GRU front organisation and an integral part of the media organisation Inforos. The Institute of the Russian Diaspora owns an online media presence called russkie.org which disseminates Russian disinformation and propaganda about the war of aggression against Ukraine. Therefore, Aleksandr Starunsky is responsible for supporting and implementing actions and policies which undermine and threaten the territorial integrity, sovereignty and independence of Ukraine. 28.7.2023 1581. Anastasia Sergeevna KIRILLOVA Анастасия Сергеевна КИРИЛЛОВА Function: General Director of Inforos DOB: 13.12.1986 Gender: female TIN: 771674318370 Anastasia Kirillova is a founder and General Director of Inforos, an online news agency responsible for setting up more than 270 media proxy online news outlets that disseminate propaganda in support of the Russian war of aggression against Ukraine. It is a front organisation for Unit 54777 of the Russian military intelligence service GRU, responsible for psychological operations. Therefore, Anastasia Kirillova is responsible for supporting and implementing actions and polices which undermine or threaten the territorial integrity, sovereignty and independence of Ukraine. 28.7.2023 1582. Nina Viktorovna DOROKHOVA Нина Викторовна ДОРОХОВА Function: General Director of Inforos DOB: 20.11.1965 Gender: female TIN: 505202442068 Nina Dorokhova is a founder and General Director of Inforos, an online news agency responsible for setting up more than 270 media proxy online news outlets that disseminate propaganda in support of the Russian war of aggression against Ukraine. It is a front organisation for Unit 54777 of the Russian military intelligence service GRU, responsible for psychological operations. Therefore, Nina Dorokhova is responsible for supporting and implementing actions and policies which undermine and threaten the territorial integrity, sovereignty and independence of Ukraine. 28.7.2023 1583. Sergey Yurievich PANTELEYEV a.k.a. PANTELEEV Сергей Юрьевич ПАНТЕЛЕЕВ Function: Intelligence officer in GRU unit 54777 DOB: 15.3.1972 POB: Lugansk, Ukraine Gender: male TIN: 772916129659 Sergey Panteleyev is a member of GRU unit 54777 and founder of the Institute of the Russian Diaspora, a GRU front organisation and an integral part of Inforos’s online disinformation network. The Institute of the Russian Diaspora owns an online media presence called russkie.org which disseminates Russian disinformation and propaganda about the war of aggression against Ukraine. Therefore, Sergey Panteleyev is responsible for supporting and implementing actions and policies which undermine and threaten the territorial integrity, sovereignty and independence of Ukraine. 28.7.2023 1584. Denis Valerievich TYURIN Денис Валерьевич ТЮРИН Function: GRU officer DOB: 1.4.1976 POB: Moscow Gender: male TIN: 772807385405 Denis Tyurin is a GRU intelligence officer and founder of Inforos, an online news agency responsible for setting up more than 270 media proxy online news outlets that disseminate propaganda in support of the Russian war of aggression against Ukraine. It is a front organisation for Unit 54777 of the Russian military intelligence service GRU, responsible for psychological operations. Therefore, Denis Tyurin is responsible for supporting and implementing actions and policies which undermine and threaten the territorial integrity, sovereignty and independence of Ukraine. 28.7.2023’

Entities   Name Identifying information Reasons Date of listing ‘245. Social Design Agency a.k.a. “Agentsvo Sotsialnogo Proektirovania aka ASP” Address: Moscow Bolshoy Kislovsky per, 1, building 2 Type of entity: Technology and Information Company Place of registration: Russia Date of registration: established 2001 Principal place of business: Russia Social Design Agency is a Russian IT company closely linked to Russian political power. Since 2022, it has been involved in the Russian-led digital disinformation campaign “RRN” (Recent Reliable News) aiming at manipulating information and sharing disinformation in support of the Russian war of aggression against Ukraine. Social Design Agency has been identified as a key actor of the campaign, responsible for the creation of fake websites impersonating government organisations and legitimate media in Europe (primarily Germany, France, Italy, Ukraine and the United Kingdom) and for boosting the pro-Russian “RRN” campaign on social media. Therefore, Social Design Agency is materially supporting actions which undermine and threaten the territorial integrity, sovereignty and independence of Ukraine. 28.7.2023 246. Structura National Technologies a.k.a. “Struktura” Russian: ООО “ГК СТРУКТУРА” Address: Moscow municipal district Arbat per Bolshoy Kislovskii 1 building 2 premises/room. i/42 Type of entity: Technology and Information Company. Place of registration: Russia Date of registration: established 2009 Registration number: TIN 7703438908 Principal place of business: Russia Structura National Technologies is a Russian IT company closely linked to Russian political power. Since 2022, it has been involved in the Russian-led digital disinformation campaign “RRN” (Recent Reliable News) aiming at manipulating information and sharing disinformation in support of the Russian war of aggression against Ukraine. Structura National Technologies has been identified as a key actor of the campaign, responsible for the creation of fake websites impersonating government organisations and legitimate media in Europe (primarily Germany, France, Italy, Ukraine and the United Kingdom) and for boosting the pro-Russian “RRN” campaign on social media. Therefore, Structura National Technologies is materially supporting actions which undermine and threaten the territorial integrity, sovereignty and independence of Ukraine. 28.7.2023 247. ANO Dialog AHO Диалог Address:119021, st. Timura Frunze, d.11, p.1, BC Demidov, Moscow Type of entity: Autonomous non-profit organisation Place of registration: Russia Date of registration: 2019 Registration number: TIN 9709056472 Principal place of business: Russia ANO Dialog is a Russian non-profit organisation created by the Moscow Department of Information and Technology (DIT) in 2019 and closely linked to the presidential administration. It is headed by Alexey Goreslavsky, former deputy head of the President's Department for Public Projects (OPS). ANO Dialog has been disseminating online propaganda about the illegally annexed territories in Ukraine. ANO Dialog provides instructions to the Readovka Telegram channel that publishes disinformation about the war of aggression against Ukraine in support of the Kremlin’s propaganda. ANO Dialog is linked to the popular “fact-checking” Telegram account and subsequent domains “War on Fakes”, run by ANO’s Head of Strategic Areas Development of ANO Dialog, Timofey Vasiliev, that disseminates fake news and propaganda about the Russian war of aggression against Ukraine. Therefore, ANO Dialog is materially supporting actions which undermine and threaten the territorial integrity, sovereignty and independence of Ukraine. 28.7.2023 248. Inforos OOO IA ООО ИА ИНФОРОС Address: 117218, MOSCOW, Intracity territory of the city of federal significance municipal district academic, 13 Krzhizhanovskogo str., k. 2, office 511 Type of entity: Media organisation Place of registration: Moscow Date of registration: 2/6/2003 TIN: 7727214569 Principal place of business: Moscow Inforos is an online news agency responsible for setting up more than 270 media proxy online news outlets that disseminate propaganda in support of the Russian war of aggression against Ukraine. It is a front organisation for Unit 54777 of the Russian military intelligence service GRU, responsible for psychological operations. The propaganda disseminated by Inforos and its various proxy outlets aims to propagate the idea of Ukraine as a “Nazi state” and to falsely paint the war of Russian aggression as a “proxy war” of “the west” against Russia and thus to undermine western support for Ukraine. Therefore, Inforos is materially supporting actions which undermine and threaten the territorial integrity, sovereignty and independence of Ukraine. 28.7.2023 249. Institute of the Russian Diaspora ИНСТИТУТ РУССКОГО ЗАРУБЕЖЬЯ Address: 117218, MOSCOW CITY, str. Krzhizhanovskoy, d.13, str.2 Type of entity: “Advising on commercial activities and management” Place of registration: Moscow Date of registration: 3/11/2005 Registration number: TIN: 7727536630 Principal place of business: Moscow The Institute of the Russian Diaspora is a GRU front organisation and an integral part of Inforos’s online disinformation network. It was co-founded by Inforos-founder Denis Tyurin. Additionally, Denis Tyurin has registered the official propaganda website of the Institute himself, using an official Inforos email address. The Institute owns an online media presence called russkie.org which disseminates Russian disinformation and propaganda about the war of aggression against Ukraine. Therefore, the Institute of the Russian diaspora is materially supporting actions and policies which undermine and threaten the territorial integrity, sovereignty and independence of Ukraine. 28.7.2023’

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WE NAME FRAUDSTER SEEKING TO CASH IN ASSETS OF HUNGARIAN HOLOCAUST VICTIMS IN GERMANY

This is Hungarian businessman BALAZS NEMETH, who, with the full support of senior officials in Hungary, at the ministerial level, he is seeking third parties, to pose as the heirs of murdered Holocaust victims, and to cash in German 1924 Recovery Bonds stolen from Jewish Hungarians in 1944 who were assassinated and sent to concentration caps for extermination. Nemeth, who alleges he purchased the bonds thirty years ago from the heirs of PESTI MAGYAR KERESKEDELMI BANK, a Jewish-owned bank in Budapest, acquired the bonds from the Hungarian descendents of Nazi associates who hid them for  decades in Swiss warehouses. 

Nemeth is reportedly a former agent of the Hungarian Secret Service, and closely connected to a number of government officials within Hungary's far-right government. he has previously threatened journalists who named him online.

  

Nemeth is openly soliciting for frontmen to make fraudulent application to the Government of Germany, which is redeeming the bonds, alleging that they are the heirs of the Holocaust victims, who received the bonds from surviving family members. His entire operation is a well-planned fraud, and any compliance officers whose bank receive any requests for assistance are warned that they may unwittingly end up participating in not only an organized fraud in Germany, but a Human Rights violation which could result in severe penalties. Consult with legal counsel forthwith if your bank has been involved in any way.

See our prior articles on the subject. Use our search box to find them on the Blog.

Artfully Hidden in Switzerland for Decades, Assets of Holocaust Victims Surface in the Hands of Heirs of Hungarian Nazis who Seek to Redeem them (July 2, 2023).

80 Years after the Holocaust, The Descendants of Hungarians who Committed Atrocities try to Cash in German Bonds of the Victims (May 31, 2023).

If any readers wish additional information about this matter, kindly email me at: miamicompliance@gmail.com

THE UK TELLS ITS FORMER EAST CARIBBEAN TERRITORIES TO REFORM THEIR RUNAWAY CBI PASSPORT PROGRAMMES

If you, like us, were wondering why the Federation of St. Christopher and Nevis, more commonly known as St. Kitts**, recently enacted major reforms of its freewheeling Citizenship by Investment (CBI/CIP) economic passport sales programme, there's a reason. Though there has not been any official announcement, it is generally understood that the United Kingdom has specifically expressed its expectation that a number of reform must occur amongst the surviving four East Caribbean states* whose citizens still enjoy visa-free entry there.

Failure to comply with the "request" definitely has possible adverse consequences. The fact that the Commonwealth of Dominica, one of the CBI states, has recently lost its visa-free access, which is the centerpiece of the attractiveness of CBI passports purchased from those Commonwealth Members who sell them, has got the attention of governments which previously ignored calls for reform, as they continued the lucrative practice of selling passports to undesirable applicants. Things have now changed, however, as the golden goose of US Dollars, sent in by applicants from Russia, Iran, Syria, China and yes even North Korea, is in danger of flying away.

What are the reforms? Here are the important ones:

(1) Perform Enhanced Due Diligence on all applicants.

(2) Insure that all applicants actually have an interview with the agency that processes the applications.

(3) Require all applicants to physically retrieve their passports in the jurisdiction that issues them.

There are others, but these requirements elevate the passport/citizenship application process to the level of Best Practises, and should go a long way towards eliminating the abuse of these programmes all of which have spawned the facilitation of transnational financial crime, international sanctions evasion, and in some cases, terrorist financing. The UK is now saying that it has to stop, or the precious visa-free access will be, like Dominica, be rescinded, which causes legitimate West Indians from those jurisdictions the expense and delay of visa application, interviews, and costs that they have previously avoided, due to their Commonwealth status.

We trust that the other EC CBI states will now follow suit. Our sources confirm that there is fear and loathing in Antigua & Barbuda, notwithstanding protests from its PM sounding suspiciously like anti-Colonialism propaganda. Of course, the next question we have is when they will be receiving a similar letter over in the Republic of Malta, the only surviving EU Member still selling economic passports to all comers. Our advice to the UK Home Secretary: don't delay, please.

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* Antigua & Barbuda, St. Kitts and Nevis, St. Lucia and Grenada. 

**The government of St. Kitts and Nevis has announced several changes to the Citizenship by Investment (CBI) Program, intended to boost investor confidence in the program and bolster the country’s reputation. The changes include a new Sustainable Island State Contribution (SISC) investment option for foreign nationals investing at least USD 250,000 (or USD 300,000 for a family of two or USD 350,000 for a family of three and four) to help advance St. Kitts and Nevis into a sustainable island state; namely, to increase local food production; transition to green energy; diversify the economy; attract and support sustainable industries; evolve the creative economy; recover from the impact of the COVID-19 pandemic; and expand social protection. The program replaces the previous Sustainable Growth Fund option which had a minimum investment threshold of USD 125,000 for a main applicant, half the amount required under the new SISC. Another change includes that all investors applying for CBI are now required to undergo an interview and background due diligence checks conducted by independent professional firms based in the United Kingdom, United States, or the European Union, commissioned by the government of St. Kitts and Nevis. Previously, this was not required. Other changes include limitations on the methods by which the CBI program can be advertised internationally.