NOW IT'S KYCA: KNOW YOUR COMPLIANCE ADVISER

FROM THE - CHRONICLES of Monte Friesner – Criminal & Intelligence Analyst and Consulaire for WANTED SA~
~Contributed & Written by Kenneth Rijock ~

Much has been made in the media about the multi-million dollar fine levied upon Gibraltar Private Bank, for its abject compliance failures, regarding its support of Scott Rothstein's Ponzi scheme, but there's a more important lesson here. Why didn't the bank's outside compliance adviser ever identify the problem ?

The bank's former president has filed a large civil suit, asserting that he was made a scapegoat by the bank's board, and blamed for the bank's willing role as a Ponzi banker, but the buck stops elsewhere. 

The bank had engaged a local Miami company as compliance adviser, after it came under the regulatory microscope. but it never warned the bank about a possible problem, even through all the red flags were there, and any competent competent firm should have caught them.

Scott Rothstein's law firm did not show up, on court dockets in all three South Florida Circuit Courts, as participating in anywhere the number of cases that would have been necessary to justify the huge "settlements" he sold to unsuspecting investors, who became his victims. Why wasn't this done, early on, by the bank's compliance adviser ?

The answer lies in the word competent; had the bank performed its own due diligence investigation upon the compliance firm, it would have quickly learned that the company had an abysmal record on rehabilitating financial institutions with AML/CFT issues, even though prior clients had laid out substantial fees for this service. What was wrong ?

Since 9/11, many opportunistic companies have eagerly dived into the anti-money laundering field, but a number of them are not qualified, by neither training nor experience, to offer effective advice to a financial institution that is often desperate for a quick fix to a regulatory defect.

Ask yourself these questions:

(1) Precisely what are the qualifications of the staff members at the company that make the firm a good candidate to solve your compliance problems ? Government, regulator or law enforcement experience ?

(2) What about the company's track record in its prior engagements ? How did their clients fare ? 

Therefore, you must vet your proposed compliance adviser thoroughly, often using outside resources, to be assured that you are not engaging posers, companies whose advice will not solve your problems, although they promise to get your bank off restrictions; Let the bank beware.

My advice to the directors of Gibraltar Private Bank, sue your former external compliance adviser for damages, for malpractice, in the form of a negligence action. Don't blame your former president.

MIAMI BANKS ARE NOT PREPARING AND ARE EVADING SUSPICIOUS ACTIVITY REPORTS

FROM THE - JOURNALS of Monte Friesner – Criminal & Intelligence Analyst and Consulaire for WANTED SA ~ Contributed & Written by Kenneth Rijock

SOME MIAMI BANKS ARE MONTHS OR YEARS BEHIND IN SAR FILINGS

A major Miami-area executive search firm was advertising recently for clerical staff, to prepare and file delinquent Suspicious Activity Reports for a bank, located here, that has a long and sordid history of AML compliance deficiencies.

 

The employment offer was for an extremely small hourly wage, which means that anyone who was qualified, through training and experience, to analyze the available information, and properly compose SARs, would not be applying for the job.

 

The bank officer who tried to cut corners by paying a pittance for this important compliance work should be terminated, in my humble opinion.

 

Moreover, the bank was, according to the executive recruiter, more than ONE YEAR BEHIND in its SAR filings. Where are the Federal auditors and regulators here ? No bank, even one with a robust AML/CFT program, should be late filing its SARs the next year.

 

The money launderers will be in, and out, of the bank, and long gone, well before the SARs are prepared and filed.

 

Apparently there are several other Miami banks with this same SAR delinquency. This is what happens when regulatory agencies only give offending banks repeated Cease & Desist Orders, when they catch them with violations.

 

The banks simply do not fear the regulators. Only when one of the most egregious violator loses its charter will the other banks institute truly effective AML/CFT compliance.

 

 

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MIAMI - HOT ZONE FOR VENEZUELAN OPPONENTS OF MADURO REGIME

FROM THE - JOURNALS of Monte Friesner – Criminal & Intelligence Analyst and Consulaire for WANTED SA ~ Contributed & Written by Kenneth Rijock

REPORTING ON VENEZUELAN MONEY LAUNDERING CAN BE HAZARDOUS TO YOUR HEALTH IN MIAMI 

Things are heating up in Miami, and I am not referring to the temperature; individuals who have been reporting on the rampant money laundering occurring in, through, and out of, the Bolivarian Republic of Venezuela, have been targeted, threatened and harassed, and there is more trouble coming to the Magic City.

 

Here is what we have seen lately:

 

(1) A Miami media figure, who has been extensively covering Venezuelan money laundering news, had a visit, at his home, from unknown visitors, who left a threatening note, warning him from continuing to expose the rampant laundering in Venezuela. Fortunately, he was not home at the time.

 

(2) Two Venezuelan expats, both known opponents of the regime, were the object of intentional automobile accidents, conducted by a pair of Cuban agents who have been conducting surveillance of individuals who are outspoken critics of the Maduro regime.

 

The obvious intent is to intimidate regime opponents. Please note that they are known to drive a white Range Rover while conducting surveillance.

 

It is doubtful that they have registered as agent of a foreign government, as Federal law requires. Remember that a Venezuelan agent in the "Suitcasegate" case was convicted for such unlawful activities in Miami a while back. Let's hope that Miami FBI office is watching the watchers.

 

(3) A Colonel in the Venezuelan Army, whose initials are R.V.L.P., is reportedly due to arrive in Miami this week, to supervise the campaign of intimidation.

 

Look for him to pose as a civilian, and a tourist. Unfortunately, CBP will probably allow him into the country, as he is not listed under any OFAC sanction, but he does pose a threat to the Miami Venezuelan community, as well as those agent whose identities thus far have remained unknown.

 

(4) One of Miami's more experienced politicians, who is based in Doral, the Miami-Dade municipality with the largest number of Venezuelans, and who is no friend of the Maduro regime, has promised to actually publish a blacklist of Venezuelan money launderers.

 

If he is referring to the list I am familiar with, and which I have discussed on this blog, its publication will greatly upset the Government of Venezuela, as well as cause compliance officers at Miami-area banks to run to their client lists, and then to their attorneys, for advice.

 

Notwithstanding any implied or express threats from Venezuelan or Cuban agents, we will continue to cover Venezuelan money laundering activities on this blog; please stay tuned, as things will certainly get ugly, but Miami can handle it.

 

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FAT CRIMINAL PRETENDS TO BE MUSIC PRODUCER

FROM THE - JOURNALS of Monte Friesner – Criminal & Intelligence Analyst and Consulaire for WANTED SA ~ Contributed & Written by Kenneth Rijock

 

CAREER CRIMINAL LIVED A LIFE OF LUXURY IN MIAMI UNTIL ARREST
 

Recently released from Federal Prison, the career white-collar fraudster lived the Miami Vice high life this summer; He stayed at several Miami luxury hotels, leaving behind unpaid bills that total $275,000 when he skipped out, only to vicitimize the next hotel. How did this happen ?

 

James Sabatino, with a number of Federal criminal convictions on his record, posed as a business executive for some of the entertainment industry's largest companies. using the alias "James Sabat," the fraudster obtained luxury accommodations at several Miami-area hotels, asking that the bills be placed on his purported company's tab.

 

While staying in luxury suites, Sabatino, who was at all times wanted by the law on other charges, reportedly ordered over $100,000 in high-end champagne, some of which was seized from his vehicle after his arrest, while staying at the most expensive rooms these hotels had to offer.

 

 Exactly how did this fraudster pull this off ?

 

(1) He showed up during the summer, the slow season for Florida hotels, when they welcome all the business that comes in the door with open arms.

 

(2) He went to hotels where his "employers" had previously booked rooms, and had current payment arrangements with the hotels for direct billing of accommodations charges. He had some prior experience in that industry, and was familiar with its policies and practices.

 

(3) Entertainers, and executives at prestigious entertainment companies, who spent extravagantly at hotels, are very desirable guests. They are also very demanding, colorful personalities, whose residence is thought by the hotels to raise their prestige, and therefore the demand by non-celebrities to stay there.

 

What did the hotels not do, and which, in my humble opinion, is compliance malpractice?

 

(A) Check with the "employers" to verify that "Sabat" was an executive authorized to stay there at company expense.

 

 (B) Check out the guest online; if you have someone's Florida driver's license, you can run the number through the Florida Department of Highway Safety, and  see if it is valid. If it is a fake, that's the biggest red flag you might ever see as a hotelier. If Sabatino gave his real license to the desk clerk, and it checks out, you then google that name.

 

Sabatino has been in prison several times, and once was charged with threatening the life of then-President Clinton,  and several Federal Judges, and threatened to blow up a courthouse in Fort Lauderdale.

 

All this would have been found, if the clerk had only done a minimal amount of research. he appears to be linked to organized crime, in both New York and Florida.

 

At five feet six inches tall, and 365 pounds, this fraudster does not fit the profile of a successful executive, but he picked the entertainment industry as his alleged employer, for it is known to have  many unconventional characters in its ranks.

 

The moral of the story: every business must perform a minimum of due diligence on its customers, lest it suffer a painful loss, as well as reputation damage, when the fraud becomes public. 

 

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