FELIX SATER TWICE-CONVICTED CAREER CRIMINAL, ADVISOR TO DONALD TRUMP, SUED BY BTA BANK

Felix Sater, the career criminal known to be a longtime advisor to Donald Trump and the Trump Organization, has been sued, in US District Court in Manhattan, by BTA Bank of Kazakhstan, and the country's capital, Almaty.  The Suit seeks tens of millions of dollars in damages for laundering stolen embezzled funds, for punitive damages, and for other relief.

The Complaint alleges that Sater laundered "the stolen funds through at least five separate schemes in the United States." One of those projects is "the Trump Soho scheme" at page 32 of the 61 page Complaint.  You can read the Complaint here.

Sater is infamous here in the State of Florida for engaging in a major fraud in a South Florida construction project; the investors who were victims could not know that Sater has been convicted in a $40m stock fraud case, because a Federal Judge in New York sealed the conviction, due to the fact that Sater was a Confidential Informant for law enforcement. 

https://www.documentcloud.org/documents/5780579-BTA-Bank-v-Felix-Sater.html 

Chronicles of Monte Friesner - Financial Crime Analyst

Contributed by Kenneth Rijock - Financial Crime Consultant

MONTE FRIESNER EXPOSES TRANSPARENCY INTERNATIONAL REPORT ON MONEY LAUNDERING THROUGH REAL ESTATE IN CANADA

Transparency International Canada has published a 60-page report entitled Opacity: Why Criminals love Canadian Real Estate (and how to fix it). It details the ease through which money launderers place their clients' dirty money into Canadian real estate, and how their successful operations have driven up prices past the ability of many legitimate buyers to become homeowners. You may access the complete text here.

http://www.transparencycanada.ca/wp-content/uploads/2019/03/BOT-GTA-Report-WEB-copy.pdf

Chronicles of Monte Friesner - Financial Crime Analyst

Contributed by Kenneth Rijock - Financial Crime Consultant

PILATUS BANK CHAIRMAN LENT OUT MILLIONS TO COMPANIES HIS FAMILY, FRIENDS AND HE CONTROLLED

Reliable sources inside Iran have confirmed the reports from Malta that Pilatus Bank Chairman/owner Ali Sadr Hasheminejad improperly lent out millions of Euros to insiders; companies controlled by himself, and close relatives and friends, all in Iran and that none of those loans were ever repaid. Many local Maltese businessmen lost access to their accounts, and it appears that they will sustain a total loss; Some were forced to close. Large depositors, who were reportedly linked to one major client, also have been unable to recover their money, since the banking license was withdrawn.

Investigators in Malta found that the bank's entire loan portfolio, which was delinquent and  non-performing, was concentrated in only a few bank clients. These borrowers failed to make required interest payments while the bank was in operation, placing the loans in default. In truth and in fact, the chairman looted his own bank.

There are no reliable figures on the amount left in the bank; one source said total liquid deposits were originally €100m, but published figures show €309m, which appears to be inflated. 

Chronicles of Monte Friesner - Financial Crime Analyst

Contributed by Kenneth Rijock - Financial Crime Consultant

USA LAW ENFORCEMENT IN THE REPUBLIC OF PANAMA KNEW ABOUT ALI SADR HASHEMINEJAD'S ACTIONS FOR IRAN IN 2011

US law enforcement agencies were aware of Ali Sadr Hasheminejad's activities on behalf of Iran as early as 2011, when he sought to purchase, in bulk, Panama's coveted bearer-share corporations. Information which recently surfaced in Hasheminejad's US money laundering case confirmed that warrants were issued, upon court approval, to search sixteen e-mail addresses connected to the defendant, his business associates, and extended family members, in 2014. He was a target long before the Pilatus Bank application was ever filed.

Why the Government of Malta would issue Pilatus a banking license to the Iranian, (although he held himself out as a Kittitian, due to his St Kitts & Nevis CBI passport), is a mystery. Any enhanced due diligence search would have uncovered Hasheminejad's substantial and longtime ties to government officials in the Islamic Republic of Iran.

Was the transaction facilitated through the artful payment of bribes ? We cannot say, but no director of compliance worthy of that title would have approved Pilatus Bank's application. Something corrupt certainly occurred to make that approval happen.

Chronicles of Monte Friesner - Financial Crime Analyst

Contributed by Kenneth Rijock - Financial Crime Consultant

HAMAS THE INTERNATIONAL TERRORIST GROUP REOPENS UNREGISTERED PANAMA FUND TO RAISE MONEY IN EUROPE

Amin Abu Rashid who is reputed to be Hamas' most senior terrorist fundraiser in Europe, and the Dutch national Okke Ornstein; often uses Okke Van Ooijen to evade immigration alert and who has a long record of felony white-collar crime activities in Panama and elsewhere, have reopened Ornstein's defunct Tulip Fund in Europe, with the alleged goal of selling gold to support Palestinian housing in the Gaza Strip and in Syria. They are operating their fraud from the Netherlands, where Ornstein has been hiding from judgment creditors. 

Panama's National Securities Commission, back in 2002, issued an alert against Tulip Universal Project SA d/b/a The Tulip Fund, as it had no license in Panama to market securities, and constituted a fraud upon the investing public. Ornstein, who was fraudster Mark Harris' general manager, was banned from ever entering Panama, upon pain of further incarceration, after his third felony conviction there. He has since picket up a fourth conviction in the Netherlands, as well as a FIVE MILLION DOLLAR ($5 MILLION DOLLAR) money judgmentagainst him. We have previously reported upon his activities in the Republic of Panama, including his time spent in prison.

The Tulip Fund operators claim that it is selling gold coins, for $1000 each, with the profits to go towards rebuilding homes in the Palestinian Territory of Gaza, and in Syria, where a large number of Palestinians reside. They have not disclosed the actual value of the coins they are selling to the public.

Given that funds raised by the pair, supposedly for Hamas, were later diverted to Ornstein's personal use, and Hamas was seeking Ornstein for that money, one must assume that the resurrected Tulip Fund is also a scam, and investors should avoid it at all costs. Do not respond to solicitations or emails with any reference to the Tulip Fund. Ornstein is currently facing additional prison time in the Netherlands; Rashid's location is unknown.

Chronicles of Monte Friesner - Financial Crime Analyst

Contributed by Kenneth Rijock - Financial Crime Consultant

NOTE WELL THE ABSENCE OF THE CARIBBEAN ISLANDS OF ST KITTS, ANTIGUA AND DOMINICA AT MEETING WITH US PRESIDENT

It was not an accident, or oversight, that the leaders of St Kitts & Nevis, Dominica and Antigua & Barbuda were not invited to the meeting this week with the President of the United States. All three East Caribbean States listed here are on record of supporting the Maduro regime in Venezuela, not to mention the Castro regime in Cuba.

In truth and in fact, their lack of support for the foreign policy of the United States has long been noted, as well as the fact that all three states have increasingly fallen under the financial and political influence of the Peoples' Republic of China, continue to operate dodgy CBI programs, its leaders exert undue influence upon their courts, often at the expense of the Rule of Law. 

From a risk management viewpoint for compliance professionals, those who are charged with evaluating Country Risk should continue to show Antigua, Dominica and St Kitts at elevated levels. 

Chronicles of Monte Friesner - Financial Crime Analyst

Contributed by Kenneth Rijock - Financial Crime Consultant

MONEY LAUNDERING THROUGH PAYMENT SERVICE PROVIDERS USING OFFSHORE TAX HAVENS; SUCH AS CAYMAN ISLANDS

In the wake of the Danske Bank money scandal, Danish law enforcement agencies are examining whether payment services providers assisted Russian organized crime in moving and cleaning dirty money that flowed through the bank. The fact that some (but only a small segment) payment service providers employ offshore jurisdictions more commonly known as tax havens, or offshore financial centers, has raised the possibility that some money laundering is occurring, mixed into legitimate payment processing for online commerce.

The insurance industry has identified Malta, Cayman Islands and Cyprus as major avenues through which payment service providers process their clients' financial transactions, which raises risk levels, due to the fact that Russian organized crime groups are deeply engaged in money laundering through those two EU countries. Additionally, the fact that both jurisdictions offer Citizenship by Investment (CBI/CIP) passports and nationalities for sale means that PSP "clients" could be posing as Maltese or Cypriot nationals, which are low-risk, when in truth and fact they are from extremely high risk countries.

Finally, the fact that payment service providers can funnel the money through multiple jurisdictions, en route to the client, which looks suspiciously like layering, raises risk levels significantly. Does the industry need AML/CFT supervision ? Absolutely, but first the threats must be properly identified and made known to the financial institutions that may be facilitating it.

Chronicles of Monte Friesner - Financial Crime Analyst
Contributed by Kenneth Rijock - Financial Crime Consultant

UNITED STATES TREASURY IMPOSES SANCTIONS UPON VENEZUELA'S STATE-OWNED GOLD MINING OPERATION

The Department of the Treasury, pursuant to Executive Order 13850,  has imposed sanctions upon Venezuela's illicit state-run gold mining corporation, CVG Compañia General de Mineria de Venezuela CA, more commonly known as Minerven. The company has been accused of causing major ecological damage to the environment, of forcibly relocating indigenous tribes in its mining operations, some of which have been deemed unsafe and damaging to the health of the miners in its employ.   

The company's president, ADRIAN ANTONIO PERDOMO MATA, was also designated, as well as a number of his immediate relatives, some of whom appear to reside in Coral Gables, Florida. He is linked to a major money laundering network whose principals have been indicted in the United States. See Raul Gorrin case. PEPs linked to Perdomo sanctioned include:

(1) MARIA ALEXANDRA PERDOMO-ROSALES  a/k/a MARIA A DE PERDOMO

(2) MAYELA ANTONIA TARASCIO-PEREZ  a/k/a MAYELA DE PERDOMO
(3) GUSTAVO ANTONIO PERDOMO ROSALES

Much of the gold the Maduro regime has acquired in this manner has been illegally sold abroad, in Turkey and the UAE,without the knowledge and required approval of the National Assembly. There are persistent reports that some of the generals and colonels in the Venezuelan military have received a substantial portion of the gold, diverted while being carried on military transport, to insure their loyalty to the regime.

Please note that at least one of the shell companies linked to the individuals, CONSTELLO INC.  was incorporated in St. Kitts and Nevis, Whether Perdomo, or any of his extended family, hold CBI passports from St. Kitts is not known at this time. CONSTELLO NO. 1 CORPORATION is said to be registered in Delaware.

Chronicles of Monte Friesner - Financial Crime Analyst  

Contributed by Kenneth Rijock - Financial Crime Consultant

AMERICAN BANK THAT IS CARD ISSUER PAIRS WITH CANADIAN MONEY SERVICE BUSINESS (MSB) TO GIVE IRANIANS PREPAID CARDS

Question: when is an Iranian not an Iranian for the purposes of OFAC sanctions ? When he holds a CBI passport from a European or East Caribbean jurisdiction, and, when holding prepaid cards cleverly obtained from a dodgy US issuer, he believes that he has artfully evaded sanctions, allowing him to invest Iranian government funds in North America with impunity, and without being discovered. 

One of America's largest prepaid card issuers has partnered up with a money service business located in the Province of Ontario, Canada. The MSB is owned and controlled by Iranian nationals; it is a shell company that shares its offices with an active money service business. Some of the ethnic Iranians involved appear to have Anglicized their names. The firm is reportedly a party to a civil suit brought against it, relevant to the recent RCMP investigation of a massive money laundering operation involving Iranian agents. 

The American financial institution, which has been the subject of repeated regulatory action in the past, and law enforcement investigations,  is located in the State of South Dakota, which is home to a large number of prepaid card issuers, due to its bank-friendly legislation. Unfortunately, due to strong industry lobbying efforts in Washington, prepaid cards loaded with large sums can still enter and exit the United States without being subject to any reporting requirements.  See El Chapo case Testimony reminds us that FINCEN has failed to stop Prepaid Card Money Laundering.https://rijock.blogspot.com/2019/03/el-chapo-case-testimony-reminds-us-that.html

Both the US bank and the Canadian MSB have reportedly recently acquired tech companies to assist in concealing their illegal sanctions evasion operations.   

 The obvious object of the scheme is to skirt around US and Canadian sanctions by constructing the legal fiction that the Iranian nationals who have acquired Citizenship by Investment (CBI/CIP) passports and nationality, and therefore have dual nationality, exempting them from sanctions, as if they are Iranians living outside Iran. It is doubtful that a court of competent jurisdiction will agree with the legal sufficiency of this position, and come down hard on offenses and individual officers as offenders. 

"Maltese"  or "Antiguan" or " St Kitts" CBI citizens, who are in truth and in fact legally Iranian nationals, entering the United States or Canada, pursuing foreign policy objectives of the Islamic State of Iran, be they terrorist financing, espionage, acting as Unregistered Agents of a Foreign State, or money laundering, among other serious felonies, will subject both the US bank, and the Ontario money service business, to serious criminal charges. We wonder if the US bank, and MSB leadership fully understand the probable consequences of their actions. Do they arrogantly believe this scheme is legitimate ?

Chronicles of Monte Friesner - Financial Crime Analyst  

Contributed by Kenneth Rijock - Financial Crime Consultant

CARIBBEAN ISLAND OF DOMINICA ADDED TO EUROPEAN UNION TAX HAVEN BLACK LIST

It is not surprising that the Commonwealth of Dominica was added this week to the EU "Tax Haven" Blacklist. Promised reforms have not been implemented, and we are not seeing any money laundering arrests, let alone convictions. Offshore banks continue to operate with impunity, and seemingly without any regulatory oversight.The leadership appears to have little interest in reining in the  conduct of foreign money launderers. 

The Country's Citizenship by Investment (CBI) program remains in operation, albeit on a reduced basis, due to smaller demand, notwithstanding the EU policy on the money laundering and terrorist financing dangers such programs stimulate, if not encourage.  The opaque nature of the Commonwealth's corporations remains in place, as does its repeated efforts to attract suspect Venezuelan "flight capital" of dubious origin. No wonder the EU wants its nationals to steer celar of Dominica.

On the political side, the radical Socialist agenda of the dominant Labour Party, and its leadership, verging on hero worship of Maduro and the Castro regime, further alienates EU regulators, who worry about money laundering and terrorist financing.

The EU action against Dominica is well-founded, and serves to alert EU Members to the threats posed by that jurisdiction. We hope that EU banks and nationals conduct themselves accordingly.   

Contributed by Kenneth Rijock - Financial Crime Consultant
Chronicles of Monte Friesner - Financial Crime Analyst