US STATE DEPARTMENT SANCTIONS FORMER PRESIDENT OF HAITI FOR DRUG TRAFFICKING

Note to compliance officers: He lives in Miami, Florida, but is known to travel to Haiti.

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A CLOSER LOOK AT FORMER BVI PREMIER ANDREW FAHIE'S CASE REVEALS MORE PARTICIPANTS THAN REPORTED BY MAJOR MEDIA; BVI NOW HAS THE ATTENTION OF THE UK FOREIGN SECRETARY

If you are a good compliance officer, you know that, while access to a Pre-Sentence Investigation Report (PSI) in Federal criminal cases is restricted and non-public, sometimes you can learn some important details when the prosecutor or defense counsel file objections to it, which are generally available to anyone reviewing the court file. The US Attorney's response to the PSI in former BVI Premier ANDREW FAHIE's case is an eye-opener about the level of corruption in the British Territory, which has local autonomy, and which has become a very public topic of concern for the United Kingdom's Foreign Secretary, DAVID LAMMY, if you follow UK politics.

The South Florida Asst. US Attorney who is handling the Fahie case pointed out that the ex-Premier should be determined by the Court to have a Sentence Enhancement as the Leader/Organizer of the criminal organization charged in the case, but there are only two other co-defendants. A closer look shows that Fahie recruited additional accomplices, that he had a degree of control and authority over them. and that he had what is known in the Sentencing Guidelines as Decision-Making Authority regarding them. There are other participants named in the reply, although we do not known whether they were charged or given immunity from prosecution for their cooperation.

Be aware that the fact that there were a larger group of players never appeared in major media's coverage of the case, because, frankly, most journalists have no legal research training, and did not know where to look to extract important additional information in minor court filings. The case was bigger than we thought, in the amount of criminal participants.

We do note that Foreign Secretary David Lammy, himself having Caribbean roots, has been repeatedly drawing attention to the situation in the British Virgin Islands, regarding rampant money laundering, opaque corporations, and systemic corruption, and unlike his predecessors, appears determined to actually do something about it. We will be watching to see what action he chooses to take take, and support him in his quest, without reservation. Clean up the BVI, Mr. Secretary.

MAJOR NEW EVIDENCE TO BE RELEASED IN SAINT LUCIA CIP SCANDAL, IMPLICATING THE COUNTRY'S PRIME MINISTER

We have received information, from a reliable source close to the plaintiffs in the RICO case involving allegations of illegal discounting of Citizenship by Investment (CBI/CIP) passports, and claims of the fraudulent diversion of billions of dollars from the Saint Lucia CIP program by a Chinese company, CARIBBEAN GALAXY REAL ESTATE LIMITED. Plaintiff MSR MEDIA is expected this week to make a bombshell announcement regarding the release of major evidence regarding the CIP scandal in Saint -Lucia. The information, which has been described as a revelation, is expected to be made public imminently. We are bringing you advance knowledge of its release, so that you will start to monitor breaking news this week, regarding the case.

The importance of the news is said to be that it implicates the role of Saint Lucia's Prime Minister, PHILIP PIERRE, in the CIP scandal. MSR has not expressed to the media which venue they will choose for this bombshell CIP revelation, but we will publish all the details as soon as they are made available.

SAINT LUCIA MINISTER RICHARD FREDERICK, TRYING TO DIVERT ATTENTION FROM CITIZENSHIP BY INVESTMENT SCANDAL, IS ALLEGED TO BE NARCOTICS TRAFFICKER IN U.S. DIPLOMATIC CABLE PUBLISHED BY WIKILEAKS

RICHARD FREDERICK, is a Minister for Housing and Local Government, within the Office of the Prime Minister of Saint Lucia, who has been leading a partisan political attack attempting to divert attention from the massive Citizenship by Investment passport sales scandal. Allegations have appeared in a number of confidential American diplomatic cables in 2006 containing information that he was implicated in the use of Saint Lucia as a transshipment point for drugs being smuggled into the United States, all of which have been published on the Internet by Wikileaks. One of the cables bears the name of the Deputy Chief of Mission and Charge d'Affaires in the American Embassy at the time. Wikipedia asserts that the figure of twenty five million dollars was involved.

Frederick, together with DEPUTY PRIME MINISTER ERNEST HILAIRE, is attempting to divert the attention of Saint Lucians from the CBI scandal made public by the filing, in the United States, of a RICO case that alleges tens of thousands of St. Lucia economic citizenships were illegally sold in China, at greatly discounted rates, that billions of dollars which belonged to the SLC government were stolen through fraud, and that Hilaire and others in Saint Lucia Government corruptly assisted a Chinese company, CARIBBEAN GALAXY REAL ESTATE LIMITED, in committing fraud and money laundering. He and Hilaire are blaming the Opposition, in an obvious partisan political attack upon former Prime Minister Allen Chastanet, while stonewalling all efforts to obtain information about the allegations.

Minister Richard Frederick

Frederick and Hilaire, in a private video program circulated on the Internet, blamed the plaintiffs in the RICO lawsuit, and made defamatory statements about them, as well as about Allen Chastanet. Hilaire has publicly refused to tell his constituents precisely how many passports his government authorized Caribbean Galaxy to sell in China, claiming that such information is restricted business data which only Galaxy can allow to be released, notwithstanding that these are government figures. The right to sell at least 28,000 passports are said to be issued by Hilaire's government, in a program that had no legal authorization under the CIP laws, and there may be substantially more passports involved.

Frederick, in a recent appearance, patronized Saint Lucia PM Pierre in a public setting at a meeting He continues to support Hilaire's efforts to block the disclosure of what Hilaire contends is restricted information about Saint Lucia's CBI/CIP program notwithstand the public outcry about its right to learn all details in the developing scandal. Reports that the RICO case will be expanded to include a number of Saint Lucian government officials continue to circulate, and we are monitoring the case, as we await the filing of an Amended Complaint.

CHINESE COMPANY IN SPOTLIGHT FOR SELLING ILLEGALLY-DISCOUNTED GRENADA CBI PASSPORTS IS PROMOTING U.S. VISA CAPABILITY

CHINA HENG SHENG DEVELOPMENT [SINGAPORE] PTE LIMITED (HS), one of the Chinese companies that we have identified through its own internal documents, as openly selling illegally-discounted Citizenship by Investment (CBI/CIP) passports, is hawking Grenada passports as an effective way to gain entry into the United States, which could pose a significant National Security Risk to America. Grenada is unique among the five East Caribbean states that sell Citizenship by Investment schemes, in that country's treaty with the United States allows its citizens to obtain an E-2 Business Investor Visa, which can ultimately lead to an EB-5 immigrant Visa.

(1) HS social media advertises the direct progression available to potential Grenada CIP applicants, through the Grenada passport, to the United States E-2 Visa, which the company appears to promise to prospective clients as a given, or that fees paid in by clients will be FULLY REFUNDED.

(2) Additionally, the company builds in the assignment of a shelf United States corporation, as a part of the package offered to applicants, which contemplates that each applicant will, upon receipt of his or her Grenada citizenship, apply for the US E-2 Visa forthwith.

(3) Given that two of the three sales facilities of HS are in China, being Hong Kong and Chungking( Chongqing), and the Chinese language webpages, it is assumed that Chinese nationals are the target market for HS. Since these clients are being offered discounted citizenships & passports, without any representation that effective due diligence has occurred, there is a well-founded fear that criminal elements, sanctions evaders, terrorist financiers, and foreign intelligence agents will obtain them, under aliases, which is a clear and present danger to the United States. The CBI RICO case in Florida, which alleges a similar set of facts, and whose claims are supported by the arrest of Chinese nationals with CBI passports, all engaged in criminal conduct around the globe, bears out the threat that HS represents.

(4) Our information is that the HS sales of Grenada CBI passports are currently being investigated by the plaintiffs in the RICO lawsuit, as potential additional defendants. Whether HS should contact plaintiffs or their counsel is a question outside the scope of this article, but the facts appear to indicate that there may be issues of liability that deserve further review.

(5) A final question: how is it that the CIU in Grenada, given the overt offering of illegally-discounted citizenships has occurred, and reportedly is still occurring, has not terminated all vendors involved, with prejudice, and cancelled all passports & citizenships improperly issued?

FORMER BVI PREMIER ANDREW FAHIE STARTS SERVING HIS 11+ YEAR PRISON SENTENCE FOR MONEY LAUNDERING AND NARCOTICS TRAFFICKING AT MIAMI'S FEDERAL DETENTION CENTER; WHY?

It appears that ANDREW FAHIE, the disgraced, convicted former Premier of the British Virgin Islands, is being housed at the Federal Detention Center (FDC) in Downtown Miami, which is designed to house pretrial detainees, and is therefore not a very comfortable place to serve one's sentence. This raises a question regarding why he remains at that facility, post-sentencing. Why hasn't he moved on?

The possible reason: he may have finally decided to start rendering cooperation to the Department of Justice, because if he is transferred to a permanent FCI out of the South Florida area, returning him to Miami to testify before a Grand Jury requires court approval, which might tip off individuals against whom he has incriminating evidence. Retaining him at Miami FCI simplifies his appearance and cooperation, and keeps potential targets in the dark.

Fahie did darkly admit, to a Confidential Informant during his case, that he had a prior history of similar criminal conduct, involving narcotics trafficking, and there have been persistent rumours that he has first-hand knowledge of cooperation of the Caribbean officials with narcotics traffickers. He may have been handed such a long sentence precisely to compel his subsequent cooperation, what is known as Substantial Assistance, which could result in a Sentence Reduction under Rule 35. We wonder if his former partners in crime in prior matters are having trouble sleeping of late. If he remains in custody at Miami FDC, they may have reason for concern.

THE IRS DIDN'T GO TO NEVIS FOR FUN AND SUN

That little photo you might have seen, about a State Department-escorted trip by representatives of the Internal Revenue Service to the Caribbean island of Nevis, which included a meeting with its Premier, MARK BRANTLEY, wasn't exactly a courtesy visit. Call it a candid exchange of views, but understand that Nevis' intentionally anonymous corporate shareholder laws bedevil even the most dedicated IRS Criminal Investigator. This clever nature of the island's corporation structure has been a thorn in the side of taxmen from the US and UK for decades, and there are no signs that it will change in the future, because it is extremely lucrative for its residents and government.

If you have read any of the articles about how the UK pointedly ignores its career nominee expats, you may have read about British citizen SARAH PETRE MEARS in the Guardian. Miss Mears reportedly was a director of over 1200 offshore companies, while residing in obscurity in Nevis' garden setting, blissfully signing scores of corporate documents delivered by courier from London financial service firms, without having read any of them, and collecting handsome income from her titular roles, in the process, What's wrong with this picture?

We reached out to her this week for comment, and she declared that she is no longer involved in that sordid director business, where nominees front for affluent Brits who choose an opaque company, immediately raising questions of tax evasion and/or money laundering. Our investigation of Miss Mears revealed that she also managed a restaurant and estate for British businessman Tim Roberts, but is no longer employed by him, and did not serve as his director, according to him . He advises that she is working for a company called SUNLINC, where we found her, under the name Sarah Petre, at a "destination management company." What that entails we leave to the reader's imagination.

If individuals whose ministerial functions facilitate financial crime, in any form, are not held to account for the willful blindness, then the Nevis system of concealing beneficial ownership will continue to afford those with substantial assets a convenient venue to deny the tax collector his due. The IRS and Inland Revenue should look into into all US and UK nationals that happen to have any connection with Nevis-domiciled companies.

ANOTHER CHINESE COMPANY, THOSE ONE LOCATED IN DUBAI, IS ILLEGALLY SELLING CBI PASSPORTS AT DISCOUNTED RATES

As we continue to closely monitor unfolding developments in the RICO litigation in the United States, which involve allegations of the widespread sale of illegally-discounted passports of Saint Kitts and Saint Lucia by a Chinese company, CARIBBEAN GALAXY REAL ESTATE LIMITED, we are examining the CIP programs of the remaining East Caribbean states that offer economic passports, looking for other violations of the laws that set minimum prices, including the regional MEMORANDUM OF AGREEMENT.

We have evidence that another Chinese company, SINGAPORE HENG SHENG (Grenada) DEVELOPMENT PTE, LIMITED, operating out of Dubai, UAE, is openly offering to sell Grenada CBI passports for USD$85,000, which is a small fraction of the legal minimum permitted under the laws that authorize the sale of citizenships, and the accompanying passports. Attached to this article is one of the documents in our possession; we have several more, which serve to confirm that Heng Sheng's sales are illegal, and which subjects all the passports sold thereby to termination and cancellation by the Government of Grenada, forthwith, without prior notice or hearing.

Additionally, We note from the Heng Sheng MARKETING AGREEMENT, of which we have several copies, gives the company's third-party vendors an illegal referral fee of $35,000 for sending the company each new customer. This is over and above the normal commission, and inasmuch as it is not disclosed to the purchasers, represents a second violation of Grenada's economic citizenship laws and regulations.

Since the announcement was made that there will be several additional defendants added shortly to the RICO lawsuit, but to date those names have not been made public, we do not know whether Heng Sheng, or its third-party vendors, will be included as a party defendants. When an Amended Complaint is filed, we shall promptly publish those details.

ICIJ REMINDS IS THAT NEVIS' DARK OFFSHORE INDUSTRY HAS OPAQUE BRITISH PLAYERS, WHICH THE UK WILL NOT RESTRAIN

This week's corruption offering from the INTERNATIONAL CONSORTIUM OF INVESTIGATIVE JOURNALISTS (ICIJ), and which was picked up by the prominent British publication, The Guardian, details the sordid use of expat UK nationals as nominee officers and directors in the offshore industry in Nevis.Those individuals, who serve on the books of hundreds, or even thousands, international business companies, make a good living by signing everything that they are instructed to endorse, while knowing absolutely nothing about the companies they are supposedly running.

Their total lack of knowledge regarding corporate affairs makes them perfect frontmen and women, because if subpoenaed, they cannot disclose anything, and they are the only people of record. The ICIJ specifically targeted Nevis, the quieter, but more financially implicated, part of the Federation of Saint Christopher & Nevis. More commonly known as St Kitts, which already is under a global compliance microscope, due to the filing of a billion dollar RICO suit for CBI fraud, money laundering & corruption, these new disclosures will most likely give Nevis an additional black mark, and cause increased Country Risk, especially in the American compliance sector.

The British Government, although claiming to rein in the abuse, by UK citizens, of the offshore nominee director loophole, has done little to hold its nationals' feet to the fire when, they participate in this financial obscenity, which deprives much of Europe of needed tax revenue, and hides the identities of the owners, as well as richly rewards UK financial advisors who perpetrate this practice.

As the names of some of the more egregious offshore nominees appear in the articles, compliance officers might want to check their bank records to see whether any appear as directors of companies that their bank services. You don't want to discover too late that you have been hoodwinked, and that what you thought was a clean client is, in truth and in fact, something else, which you never would have given approval to.

THE TERRORIST FINANCING CLUES: ARE YOU WATCHING FOR THEM?

If you are a compliance officer at an EU or UK bank that onboards affluent clients from the Middle East, you should be monitoring the press coverage of the war in Gaza, lest you miss something that results in your unwittingly banking terrorist funds. An article yesterday, where an Israeli General officer detailed what was found at the underground "residence" of Hamas leader YAHYA SINWAR, provides a small detail of note: Sinwar had a safe, in a room in which his personal effects were kept. That safe reportedly held millions in cash.

Take that to mean that the IDF confiscated only a small portion of the illicit wealth that the Hamas leader had "diverted" ( meaning stolen) from Qatari greenbacks delivered to Gaza for distribution to its government employees, charitable donations from well-meaning Scandinavian donors, Draconian tax revenues Hamas collected, drug profits earned abroad and a host of other terrorist financing schemes. He may not be the billionaire that Hamas "political wing" leaders living lavishly abroad are, but he is still a multi-millionaire nevertheless.Where's the rest of his cash? Spirited out of Gaza, most liekly, while the tunnels into Egypt were still functioning, and coming right into your bloody bank, unless you, as gatekeeper, stop it.

Remember, those carrying, and seeking to deposit, that fugitive cash will not only be members of his extended family, but members of his clan. If you cater to Middle Eastern clients, you has better be familiar with the identities of wealthy clans from the Palestinian Territories, so that you can differentiate legitimate affluent businessmen from terrorist bagmen. Do you have Arabic speakers in compliance, familiar with the methods of obtaining region-specific information for due diligence inquiries. I surely hope you are prepared to separate the wheat from the chaff, lest you draw both serious fines, and negative press, later when your compliance malpractice appears in EU media. Stop terrorist financiers, and their bagmen, at the door, please.

HAS THE UNITED STATES FINALLY TAKEN OFF THE GLOVES ON CORRUPT CARIBBEAN OFFICIALS ENGAGED IN MONEY LAUNDERING IN AMERICAN BANKS?

The conviction and sentencing of former British Virgin Islands Premier Andrew Fahie, which is only the second time in the last forty years that a sitting senior Caribbean government official has been convicted in an America courtroom, may be a sign that there has been a major change in how the United States intends to deal with criminal corruption from a region that directly impacts our financial institutions. If you are a keen student of modern history, you know that since the invasion of Grenada, American foreign policy has gone out of its way to ignore the rampant corruption that pervades senior leadership at most of the East Caribbean republics which are formerly British overseas territories.

When many of those senior officials deposit the proceeds of their crimes, which is a predicate act under our money laundering statutes, into correspondent accounts in New York and Miami, you do not see Federal indictments reach out to those bad actors, most likely so as not to appear overbearing, as the US is regarded there as the Colossus of the North, and perhaps threaten sensitive local feelings of sovereignty. Meanwhile, American banks, whose AML obligations have if anything increased since 9/11, accept the proceeds of crime, while the US Government warns them about De-Risking the same indigenous banks that sent the tained dollars. Our banks are now caught between facilitating money laundering and obeying American policies about giving foreign banks access to the American financial structure.

Whether we will see a change in our law enforcement policies in 2024 remains an open question. I challenge the Department of Justice to start strictly enforcing our money laundering laws, when it comes to senior Caribbean politicians who place their illicit wealth in American banks, and then invest it in income-producing real estate, so that they can enjoy an affluent lifestyle when they leave office. Indicting corrupt Caribbean officials will serve to introduce needed reform in those island republics, protect our banks from regulatory fines and civil penalties, or worse, and finally dispense justice where it is sorely needed.

ARE YOU PERHAPS ACCEPTING USD DEPOSITS THAT MIGHT HAVE COME FROM A BANK ROBBERY?

Buried in the after-action reports from the ongoing war in Gaza is the information that Hamas, in order to have the necessary Israeli currency it needs to pay the surviving terrorists who are still fighting, has broken into the country's commercial banks, opened their safes, and taken out all the cash. Since their people can only use Shekels inside Gaza, the caches of valuable US Dollars they steal will most likely end up in the hands of senior Hamas officials, many of whom have grown rich, due to opportunities they have had in the past to divert aid payments, UNRWA salaries, which are paid in Dollars, and many other corrupt means of securing hard currency for their future.

When the war comes to an end, it must be assumed that much of those greenback holdings will find their way into an EU bank or two, in the hands of individuals, conveniently holding valid Jordanian passports. Have your Arabic-speaking staff interview them at length, to determine whether their spoken language, including slang, marks them as Palestinians. If they are, then enhanced due diligence is in order, to rule out that they were inside Gaza during the war, and may be involved in terrorist financing, or terrorism itself.

The individuals will have a large amount of US currency, ignore any new bank clients with small quantities of cash; you are looking for these with large bankrolls that they wish to deposit, and therefore begin a journey of laundering that money through your bank. Are they fifty and one hundred dollar notes, and do they appear to be in good physical condition? if so, they may have very well come from a Palestinian bank's safe, taken straight out of a stack of bills held in storage, but which are the proceeds of a bank heist.

If you are a compliance officer at an EU bank with substantial international clientele from the Middle East, you will want to start closely examining anyone that fits my description, starting immediately after a Cease-Fire is announced,