Friday, October 30, 2009

117 - K1 Gets Killed

Bafin, the German financial regulator, sanctioned Mr. Helmut Kierner's K1 Group four times from 2001 to 2004. This past Wednesday, the authorities in Germany raided K1 Group and accused the fund-of-funds management company of fraud. According to the arrest warrant, Barclays Bank will probably lose USD220-million. Other top tier global investment banks will lose large amounts.

Hedge funds thrive on opacity. Funds-of-funds do the same. They never wish to reveal their investment strategies, even to those who front them cash for leverage or potential/actual investors. It's usually a game of "Trust us, we know what we're doing."

In today's marketplace, opacity can no longer be justified. Too many actual funds are frauds. Too many fund-of-funds either invest in frauds (as their due diligence leaves much to be desired) or are frauds investing in ghost funds.

It's a safe bet that the regulatory boom will come down on the hedge fund industry. Bureaucrats and others who most likely never enrolled in first year economics will draft or vote on legislation.

Sarbanes Oxley (SOX) was a knee-jerk response to Enron, WorldComm and other demons from the Dot Bomb craze at the turn of the century. Expect the same reaction in the coming months regarding the hedge fund industry. Sympathy could be offered, however it's drowned in the contemptuous arrogance so willingly flaunted just a short while ago.





From
October 30, 2009

Barclays faces £130m loss from ‘fraud’ at German fund

Barclays may have lost as much as $220 million (£130 million) from investments with K1 Group, the German hedge fund whose founder, Helmut Kiener, is at the centre of a fraud inquiry.

The British bank’s investment, fed into K1 between 2006 and 2009, is “mostly lost”, according to an arrest warrant for Mr Kiener. The former advertising salesman was arrested on Wednesday night on suspicion of fraud and breach of trust relating to K1, a fund of hedge funds. He was still in police custody last night after a judge extended his detention yesterday.

Mr Kiener and K1 are also being investigated by the FBI. Barclays said that it was co-operating with inquiries, but would not comment further. Sources close to the bank said that provisions will have been made for any potential losses.

Other banks believed to have lost money in K1 include JPMorgan Chase, BNP Paribas and Société Générale.

Mr Kiener has been in the spotlight since prosecutors in Würzburg, Bavaria, said on Wednesday that they were investigating his activities. Police removed files after searching his home and office in Aschaffenburg. Mr Kiener’s lawyers said yesterday that no one was available for comment.

German prosecutors said that one other person was being investigated in the inquiry, but declined to say whom.

Mr Kiener, who is relatively unknown among professional investors, turned to fund management after selling advertising in telephone directories.

K1 Group’s website described him as a psychologist and inventor of the “K1 fund allocation system”. The business had almost $1 billion under management, Army Yan, a K1 manager in Hong Kong, told Hedgeweek, an industry newsletter, in February.

Bafin, the German financial regulator, censured Mr Kiener four times between 2001 and 2004. Two censures were overturned on appeal.

The criminal inquiry into K1 comes as European and American regulators, encouraged by Germany, plan new restrictions on the hedge fund industry.This month, Raj Rajaratnam, the founder of Galleon, the US hedge fund, was charged with insider trading in the biggest case of its kind for more than a decade. He denies all allegations.

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Thursday, October 29, 2009

116 - IT Department Nightmare

It would appear that Adeniyi Adeyemi, 27, of Brooklyn, New York, is a bank's worst Information Technology Department nightmare. It is alleged that he stole the identities of 150 employees of the Bank of New York Mellon and pilfered the accounts of various charities and non-profit organisations.

It is alleged he laundered the profits through various brokerage accounts and money orders in the names of the stolen identities. There is evidence to suggest that his illegal activity was camouflaged through internet access to unprotected or cracked WiFi networks accessible in his apartment building.

In a delightful twist of fate, one of the charities allegedly defrauded by Mr. Adeyemi is the International Association of Women Judges. His arraignment on the charges in State Supreme Court was before Justice Carol Berkman.

It is unlikely she will be impressed with the man placed before her.




DISTRICT ATTORNEY - NEW YORK COUNTY

NEWS RELEASE
October 28, 2009

Contact: Alicia Maxey Greene
212-335-9400

Manhattan District Attorney Robert M. Morgenthau announced today a 149-count indictment of a computer technician for stealing the identities of more than 150 employees of the Bank of New York Mellon and using these identities to orchestrate more than $1.1 million in thefts against charities and non-profits, among other institutions.

The defendant ADENIYI ADEYEMI, 27, of Brooklyn, has been indicted on charges of grand larceny, identity theft, money laundering, scheme to defraud, computer tampering, and unlawful possession of personal identification information. The crimes charged in the indictment occurred between November 1, 2001 and April 30, 2009.

The investigation leading to today’s indictment revealed that ADEYEMI was employed as a computer technician at the headquarters of the Bank of New York at 1 Wall Street and other Bank of New York locations in Manhattan. In the course of his tenure at Bank of New York, ADEYEMI stole the personal identifying information of dozens of Bank of New York employees, mainly in the Information Technology Department, where he was assigned. In the years that followed, ADEYEMI used the employees’ personal identifiers to open over 30 bank and brokerage accounts in their identities with several financial institutions, including E*Trade, Fidelity, Citi, Wachovia, and Washington Mutual. These accounts served as dummy accounts for the purpose of receiving stolen funds. ADEYEMI then stole money from the bank accounts of charities and non-profit organizations and funneled it into the dummy accounts, later withdrawing the stolen funds or transferring them to a second layer of dummy accounts. In the interests of facilitating donations, many charities readily disseminate their banking details on the Internet, making them easy prey for unauthorized withdrawals by identity thieves, particularly those with computer expertise such as ADEYEMI. Most of ADEYEMI’s theft was perpetrated over the Internet.

For example, in July 2006, ADEYEMI opened a dummy account with E*Trade, an online brokerage, in the name of a Bank of New York employee from the Information Technology Department. Over the course of the ensuing two months, ADEYEMI transferred money online from the bank account of Goodwill Industries of Greater New York and Northern New Jersey into the dummy account. By the time the fraud was uncovered, ADEYEMI had stolen $120,000 from Goodwill Industries. ADEYEMI spent nearly $70,000 of that total on money orders from the United States Postal Service (USPS), and withdrew the remainder in cash or transferred it to other dummy accounts. Other victimized organizations include Iris Ministries, the Kalgidhar Trust, the Sudanese American Community Development Organization, Ravi Zacharias International Ministries, AFK Foundation, the American Community School at Beirut, the Jacksonville Humane Society, American Friends of Birdlife International, the International Association of Women Judges, the Space Generation Advisory Council, and the American Association for Clinical Chemistry.

ADEYEMI also stole from the Bank of New York employees themselves. Exploiting his theft of their personal identification information, ADEYEMI changed the contact information associated with the employees’ online banking profiles, took control of their online banking capabilities, and wired money from the employees’ personal bank accounts to dummy accounts he had established. To avoid scrutiny, ADEYEMI structured all such wire transfers to be just under $10,000, the threshold at which all financial institutions must report transactions to the United States Treasury. ADEYEMI stole more than $128,000 by compromising Bank of New York employees’ online banking profiles in this manner. Among other purchases, ADEYEMI used these stolen proceeds to buy additional USPS money orders. All told, ADEYEMI purchased more than $100,000 in USPS money orders using stolen funds. ADEYEMI redeemed these money orders, among other things, to pay personal expenses such as rent on his apartment and his credit card bills. ADEYEMI also redeemed USPS money orders to ship substantial volumes of goods overseas, primarily to Nigeria.

ADEYEMI came under surveillance by the New York/New Jersey Electronic Crimes Task Force of the United States Secret Service when suspicious Internet activity traced back to wireless Internet connections in ADEYEMI’s apartment building, and mail connected to the fraud was delivered to the various apartments within the building. In executing a court-authorized search warrant of ADEYEMI’s apartment on April 30, 2009, investigators found dozens of Bank of New York employees’ credit reports on his computer, along with many other documents containing personal identifying information of more than 150 Bank of New York employees. In a storage locker ADEYEMI rented, the investigative team found notebooks containing hundreds of names, social security numbers, account numbers, and other personal data, along with numerous credit cards in Bank of New York employees’ names. Investigators also recovered $30,000 in cash from ADEYEMI’s apartment. ADEYEMI was arrested in the course of the search warrant execution, and has remained in custody since.

ADEYEMI has been indicted on one count of Grand Larceny in the First Degree, 138 counts of counts of Identity Theft in the First Degree, one count of Money Laundering in the First Degree, one count of Computer Tampering in the First Degree, two counts of Money Laundering in the Second Degree, three counts of Grand Larceny in the Second Degree, two counts of Scheme to Defraud in the First Degree, and one count of Unlawful Possession of Personal Identification Information in the Second Degree.

Grand Larceny in the First Degree and Money Laundering in the First Degree are class B felonies which are punishable by up to 25 years in prison. Computer Tampering in the First Degree, Money Laundering in the Second Degree, and Grand Larceny in the Second Degree are class C felonies which are punishable by up to 15 years in prison. Identity Theft in the First Degree is a class D felony which is punishable by up to 7 years in prison. Scheme to Defraud in the First Degree and Unlawful Possession of Personal Identification Information in the Second Degree are class E felonies which are punishable by up to 4 years in prison.

The investigation is continuing. ADEYEMI will be arraigned today in State Supreme Court before Justice Carol Berkman, Part 71.

Mr. Morgenthau thanked the Bank of New York Mellon, particularly Vice President for Corporate Security George Sulfaro, for the bank’s assistance in uncovering the scope and depth of the data breach; and the New York/New Jersey Electronic Crimes Task Force (ECTF) of the United States Secret Service, particularly Special Agent Prasanth Kurian, lead investigator on the case, and Special Agent Robert Novy, supervisor of the ECTF.

Mr. Morgenthau also thanked investigators from the following institutions: JPMorgan Chase Bank, E*Trade, Fidelity Investments, Bank of America, Wachovia, the New York Police Department, and the United States Postal Inspection Service.

Assistant District Attorney Ehren Reynolds is handling the prosecution of the case and presented it to the Grand Jury, under the supervision of Assistant District Attorney Antonia Merzon, Chief of the Identity Theft Unit. Investigative Analysts Lindsay Kosan and Michelle Ragusa assisted in the investigation, and Senior Forensic Examiner Richard Brittson also assisted. The District Attorney’s Investigation Bureau assisted in the investigation, under the supervision of Chief Joseph Pennisi.


Wednesday, October 28, 2009

115 - Don't just worry about regulators

The former CEO of Family Bank and Trust Co. of Chicago, Illinois, would be paying a price for willingly turning a blind eye towards deposits of illicit drug cash (related to crystal methamphetamine) being dumped into his bank.

Not filing Currency Transaction Reports has landed them in hot water with the United States District Attorney for Northern Illinois. According to press reports, the scheme was uncovered thanks to an undercover narcotics investigation.

Undercover law enforcement can be just as dangerous as banking regulators.


114 - 1980s Wall Street - The Sequel

The Royal Canadian Mounted Police (RCMP) Integrated Market Enforcement Team (IMET), the Ontario Securities Commission (OSC) and the United States Securities and Exchange Commission (SEC), FINRA, IIROC and the Manhattan DA have all teamed up to expose the insider trading of Stanko Joseph Grmovsek.

Gromovsek and his old law school pal Gil Cornblum generated millions from insider trading before the announcement of mergers or acquisitions generally in Canada. Cornblum would communicate the particulars of impending corporate transactions and Grmovsek would engage onshore and offshore entities to undertake profitable speculative positions in the associated securities. The two of them would split the loot.

It is no exaggeration to state that the methods used by both Grmovsek and Cornblum come right out of the techniques employed by Dennis Levine, Ivan Boesky and other investment banking hoodlums of the 1980s. It would appear that both men took copious notes from Dennis Levine's "Inside Out" autobiography, fantastically believing that such archaic methods would succeed in the high-tech environment of 1996-2008, the time period of their shenanigans.

The chief weapon of sea pirates, however, was their capacity to astonish. Nobody else could believe, until it was too late, how heartless and greedy they were.

- Kurt Vonnegut (1922 - 2007), Breakfast of Champions


113 - Intoxication of Sundanese Oil

Robert J. Cabelly, 61, of Washington D.C. is a former United States State Department employee who appears to have put his previous work experience to use in the private sector by facilitating transactions for the Republic of Sudan, a country considered by the United States as a terrorist haven.

It would appear that Cabelly understood the value of Sudanese oil in parching the thirst of (presumably non-American) oil companies.

Would Cabelly have been classified as a politically-exposed person? Probably not. Would the Cook Islands' financial intelligence unit have reported him? Perhaps, if he had been sloppy with the payments provided by the "foreign oil company". The Cook Islands Financial Intelligence Unit may have reported him to FinCEN, leading into an investigation of Cabelly's actual business dealings as oppose to the tripe he allegedly passed on to the State Department.



Jerome K. Jerome (1859 - 1927)




Tuesday, October 27, 2009

112 - Lawyers Accepting Dirty Money? Cannot be!

The debate grows in the United States whether lawyers can accept "dirty money" from their clients in order to secure accurate legal representation. Or are the lawyers money laundering for their clients?

The legal gymnastics are far from over. Below is the latest shot across the Bar bows. Given the fact that turkeys will never vote for Christmas, is there any doubt on what ruling will inevitably prevail?



111 - High Volume Grilling

Rumour has it that Yam Yam's Southern Cooking Barbecue of Portland, Oregon, laundered $300K of cocaine money a month.

In order to successfully pull off the ruse, Yam Yam's senior management would need to convincingly portray the illusion of that level of BBQ sales volume. Assuming a plate of grits goes for $6, that's 50,000 orders a month, or 1666 per day.

That's a very popular restaurant. I wonder if their bankers ever paid them a visit to see that astounding volume for themselves.

Common sense + Know Your Customer = Risk Management

110 - Paying Full Sticker Price

Scottrade had ample warning to modify its AML regime but chose otherwise. Somehow one employee tasked with the manual examination of tens of thousands of transactions per day doens't seem to pass the "reasonable efforts" test.

Now it faces a USD600,000 fine and increased scrutiny from regulatory agencies. Third party software providers smell blood and will be undoubtedly quoting their transaction monitoring systems at full sticker price.

The recent FATF paper on the Securities Sector will be of use at Scottrade.


==========


For Release:
Contacts:

Monday, October 26, 2009
Nancy Condon (202) 728-8379
Brendan Intindola (646) 315-7277

Scottrade Fined $600,000 for Inadequate Anti-Money Laundering Program

Firm Failed to Adequately Monitor for Suspicious Transactions

Washington, D.C. — The Financial Industry Regulatory Authority (FINRA) announced today that it has fined Scottrade $600,000 for failing to establish and implement an adequate anti-money laundering (AML) program to detect and trigger reporting of suspicious transactions, as required by the Bank Secrecy Act and FINRA rules.

FINRA requires brokerage firms to establish and implement anti-money laundering policies, procedures and internal controls reasonably designed to detect and cause the reporting of any suspicious transactions that could be related to possible violations of laws or regulations - regardless of whether those transactions are associated with suspicious movement of funds into or out of accounts.

"Each firm's AML program must be tailored to its business model, including the technological environment in which the firm operates," said Susan L. Merrill, FINRA Executive Vice President and Chief of Enforcement. "In this case, despite the large volume of on-line trading at Scottrade, the firm failed to establish any systematic or automated surveillance until 2005. Then, the automated system the firm implemented remained inadequate because it focused only on suspicious trading that was accompanied by suspicious money movement."

Specifically, FINRA found that between April 2003 and April 2008, Scottrade failed to establish and implement an adequate AML program tailored to its business model, which primarily consists of providing an on-line platform for customers trading in securities. In 2003, Scottrade handled about 49,000 customer trades per day, and its volume grew to about 150,000 daily trades in 2007. Among the risks inherent to Scottrade's brokerage model and the firm's substantial trading volume are an increased risk of identity theft, account intrusions and the use of customer accounts to launder money using securities or other financial instruments, or to violate securities laws.

FINRA has advised firms that in designing their AML program, they should consider factors such as their size, location, business activities, the types of accounts they maintain and the types of transactions in which their customers engage. FINRA also has instructed on-line firms such as Scottrade to consider conducting computerized surveillance of account activity to detect suspicious transactions.

From April 2003 through January 2005, Scottrade did not have any systematic or automated program designed to detect potentially suspicious money movement or securities transactions. Instead, the firm used a manual system to monitor accounts for suspicious activities. This system relied almost exclusively on internal personnel, including branch, cashiering and margin employees, to identify and refer potentially suspicious activity to the firm's risk management department for further review.

Until June 2004, Scottrade's AML compliance officer/director of risk management was the sole employee specifically charged with investigating referrals to determine whether activity was "suspicious" and therefore reportable. In June 2004, the firm hired a risk management analyst to assist with this review. Neither the compliance officer, the analyst nor anyone else at Scottrade specifically monitored transactions for potentially suspicious trading activity. FINRA found that the sheer volume of on-line trading, along with the firm's reliance on inadequate internal resources, rendered the lack of an automated system to detect suspicious activity unreasonable.

In February 2005, Scottrade implemented a proprietary, automated system to monitor for suspicious transactions that was inadequate because it was primarily designed to monitor for and detect suspicious money movement.

Under Scottrade's automated filter-based system, when suspicious activity triggered one of the filters, it generated an alert to the AML analysts responsible for investigating the alerts. The analysts only reviewed for potentially suspicious trading activity if there was money movement into or out of an account that independently triggered one of the filters. On average, 1,300 alerts were generated monthly, but not all alerts were reviewed. In September 2006, the firm implemented a proprietary volume report for purposes of detecting "pump-and-dump" account intrusions and unauthorized trading activity resulting from such account intrusions. Scottrade did not utilize this volume report to detect suspicious trading activity by bona fide account holders.

FINRA also found that Scottrade's AML procedures failed to provide adequate written guidance to its employees as to how to detect or review transactions for potentially suspicious activity and failed to provide adequate written guidance to its AML analysts for detecting and investigating potential suspicious trading.

In concluding this settlement, Scottrade neither admitted nor denied the charges, but consented to the entry of FINRA's findings.

Investors can obtain more information about, and the disciplinary record of, any FINRA-registered broker or brokerage firm by using FINRA's BrokerCheck. FINRA makes BrokerCheck available at no charge. In 2008, members of the public used this service to conduct 11.6 million reviews of broker or firm records. Investors can access BrokerCheck at www.finra.org/brokercheck or by calling (800) 289-9999.

FINRA, the Financial Industry Regulatory Authority, is the largest non-governmental regulator for all securities firms doing business in the United States. FINRA is dedicated to investor protection and market integrity through effective and efficient regulation and complementary compliance and technology-based services. FINRA touches virtually every aspect of the securities business—from registering and educating all industry participants to examining securities firms; writing and enforcing rules and the federal securities laws; informing and educating the investing public; providing trade reporting and other industry utilities; and administering the largest dispute resolution forum for investors and registered firms. For more information, please visit our Web site at www.finra.org.

Monday, October 5, 2009

Articles of Interest 109 - Where there's smoke...

An otherwise excellent article from the Miami Herald stops short of asking who in their right mind approved an exemption for “Sir” Allen Stanford to funnel money from Florida to Antigua without the application of AML and other legislation.

Such a conduit was created in 1998 at a time when Antigua was in the crosshairs of the Financial Action Task Force (FATF) as a money laundering sink and general den of iniquity. Did anyone in Florida think to revoke Stanford International Bank’s “special” permission to circumvent the rules? If that conduit had been turned off, would the hoax of SIB’s “certificates of deposit” been shut down as well?

“All animals are equal but some animals are more equal than others.”

- George Orwell (1903 – 1950), Animal Farm



This Article of Interest appears with many others in the ManchesterCF blog – http://manchestercf.blogspot.com



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http://www.miamiherald.com/news/florida/v-print/story/1265650.html


Posted on Sat, Oct. 03, 2009
Allen Stanford Ponzi case puts lawyers in spotlight

BY MICHAEL SALLAH AND ROB BARRY
msallah@MiamiHerald.com

With federal agents threatening to put his bank out of business, Allen Stanford turned to the powerhouse Miami law firm of Greenberg Traurig. Stanford International Bank and other banks in Antigua were suspected of laundering money and were close to being cut off from the global banking community.

Not only did the firm save his bank, it helped Stanford eliminate his competition and become a top Antiguan regulator -- just years before prosecutors say he began stealing millions in one of the largest frauds in U.S. history.

Now a decade later, with Stanford charged in the massive criminal case, the law firm is being pulled into a widening inquiry of the $7 billion Ponzi scheme that wiped out thousands of investors.

Though not under criminal investigation, Greenberg Traurig is facing a legal review of its actions on this tiny island that was the center of his banking kingdom.

The court-appointed receiver trying to recover money for victims is demanding records of the legal work provided to the disgraced banker -- including that of Greenberg. The effort is the latest by the receiver to untangle the complex deals spun by Stanford as well as the conduct of his lawyers.

The demand for the records has put a rare spotlight on Greenberg Traurig and another firm, Hunton & Williams, which now holds the records.

``I'm sure one of the things they will look at is what did Greenberg Traurig know, and when did they know it, and did they have any liability?'' said Ross Gaffney, a former FBI agent who investigated Stanford.

Greenberg Traurig's effort to help Stanford in 1998 was one in a string of instances in which the Florida law firm propelled Stanford's business interests and helped rescue him from crisis.

The Miami Herald sought interviews with five lawyers who represented Stanford while working for the law firm, but only two responded.

Those lawyers, citing confidentiality concerns, declined comment, saying they were simply giving legal support and were unaware of any illegal schemes by Stanford.

Cesar Alvarez, the firm's chief executive officer, also declined to be interviewed.

THE MO
NEY PIPELINE

The request for the legal files represents one of the most aggressive moves waged by the receiver to search for assets from Stanford's far-flung banking network.

While he presses for the files, The Miami Herald found that at least two of the deals -- one in Miami and the other in Antigua -- provided cover for Stanford from regulators while he reaped millions from investors.

With the help of Greenberg lawyers, Stanford created a money pipeline between Miami and Antigua in 1998 that became a cornerstone of the banking empire.

With lawyer Carlos Loumiet negotiating with Florida regulators, Stanford set up a special trust office in downtown Miami that could move millions overseas without reporting anything to the government.

The unusual arrangement -- created over the objections of Florida's chief banking lawyer -- let Stanford open the office without submitting to fraud checks or money-laundering requirements.

Over the next decade, the Miami center sold millions in Stanford's key investments -- certificates of deposit -- the checks stuffed in pouches and sent in jets to Antigua.

The Miami office became ``the locomotive that pulled the train,'' said Steven Riger, a vice president at Stanford's Miami brokerage.

While the Miami office was the generator, Antigua was the recipient.

But as the Miami office was being created, a series of scandals on the island forced Stanford to call on his lawyers to help change the island's banking system -- and keep the pipeline alive.

The U.S. Treasury was considering blacklisting all offshore institutions in Antigua -- cutting off access to U.S. currency -- because of money laundering and fraud.

With his fortune at risk, Stanford waged an expensive effort to fight back. The banker met with Prime Minister Lester Bird and agreed to personally pay for a task force to rewrite the banking laws.

The task force, which included Loumiet, met in Miami and Antigua's capital to look for ways to avert a shutdown of the banks.

Also on the panel: Greenberg lawyer Patrick O'Brien, a former Miami U.S. Customs chief who had led major drug crackdowns; and Lloyd Harrell, a former FBI agent from Texas. Another lawyer, Yolanda Suarez, had left Greenberg Traurig to become Stanford's legal counsel.

``The intention was to make the regulator independent of the government,'' said Lebrecht Hesse, an Antiguan official who helped draft the laws.

But the 1998 legislation ushered in a new regulatory agency -- with Stanford on the board -- in a move that gave Stanford sweeping protection from regulators for the next 10 years.

``Stanford effectively became the man who controlled the regulator,'' said Rodney Gallagher, a former member of the British High Commission in Barbados who investigated Stanford for money laundering.

One incident highlighted the power Stanford gained in Antigua owning the largest bank.

The new agency demanded all the island's secret offshore banking records, including those belonging to Stanford's competitors. But head regulator Althea Crick refused to turn them over.

What followed was an event that shook the island's politics and infuriated U.S. agents.

Harrell, O'Brien and others pulled up to the two-story government building that held the records and seized the filing cabinets after Crick left for the day, hauling them to another building, Harrell said.

Harrell, 70, said the takeover in February 1999 was approved by the new regulatory board, including Errol Cort, an advisor to Prime Minister Bird.

``It was of no benefit to Stanford,'' he said. ``It was not done under the cover of darkness. We needed those files on a daily basis.''

However, records show Cort was a director of Stanford Trust Company and one of Stanford's Antiguan lawyers. He did not respond to repeated interview requests. O'Brien, also a board member of the new agency, declined to be interviewed.

U.S. agents condemned the seizure, saying Stanford orchestrated the event for himself.

``It was outrageous,'' said Jonathan Winer, former deputy assistant Secretary of State for International Narcotics and Law Enforcement Affairs.

Winer said he had warned members of the task force, including O'Brien and Cort, that the U.S. State Department considered Stanford to be playing a dangerous role.

``I said it was unacceptable what they were doing,'' he said. ``That was no clean-up of the laws, not when you have a private-sector person paying for it. I didn't care about the details; it was all dirty.''

In addition, Stanford -- who surrendered his banking license in Montserrat years earlier during a crackdown on money laundering -- had been the focus of recent investigations by British and FBI agents.

U.S. authorities struck back, condemning the records seizure and saying key provisions in the legislation weakened efforts to fight money laundering.

In April 1999, the U.S. Treasury fired off a rare warning to American banks, blasting Stanford's new role in the island's banking system.

``The Authority's board of directors includes representatives of the very institutions the Authority is supposed to regulate, thus raising serious concerns that those representatives are in fact in control,'' said William Baity, director of the U.S. Treasury's Financial Crimes Enforcement Network.

Baity also said the new legislation banned whistleblowers from going outside the regulatory system, a blow to law enforcement agents. British authorities followed suit with a similar warning days later.

As a compromise, Stanford stepped down from his position, and Antigua officials agreed to change the laws crafted by the task force. A year later, the island's banks were taken off the U.S. Treasury's trouble list.

But the momentum was in motion to help Stanford's bank for years to follow.

With the new regulatory agency enforcing new banking rules, most of the 56 offshore banks on the island were eliminated, swatting away much of his competition.

Harrell, the supervisor of banking, said the effort successfully ejected crooked Russian banks that were giving the offshore sector a bad name. He also credited O'Brien for drawing on law enforcement experience in investigating the problem banks.

``Nobody gives [Stanford] credit for what was trying to be done at the time,'' said Harrell. ``What we were trying to do was create an offshore sector that was a regulated sector.''

However, court records show Stanford's own bank was fabricating financial reports the same time he was taking over the regulatory agency.

Chief financial officer James Davis told prosecutors in August he and Stanford began doctoring bank reports in 1999 to show phony returns.

COVER ON THE INSIDE

With millions pouring into his Antiguan bank, Stanford switched to a new law firm, Hunton & Williams, after Loumiet joined the firm in 2001. By then, the foundation of Stanford's bank network -- including the lucrative Miami-Antigua connection -- was already laid.

Regulator Crick, who opposed the seizure of the offshore banking records, was ousted, replaced by Stanford's ally Leroy King in 2002.

King forged a close relationship with Stanford, providing cover to the banker -- and taking thousands of dollars in bribes, say U.S. prosecutors. Over the next six years, King took more than $200,000 from Stanford to run interference and make sure no one got too close to the banker's investment portfolio, the indictment states.

To complete their bond, Stanford and King struck a blood oath, cutting their fingers and pressing the flesh together in a pledge to never reveal their secret, said Davis, the Stanford financial officer.

Now indicted in the case, King refused to discuss the charges when a Miami Herald reporter went to his home in Antigua two weeks ago. A dual U.S. and Antigua citizen, King is fighting extradition to the United States.

Prosectors want to talk to King about the alleged bribes and the inner workings of Stanford's bank, which remained secret from U.S. regulators.

One of the big challenges for federal agents has been tracing the millions that flowed from the U.S. to Antigua over the years, especially from the Miami office. More than $800 million was generated in Miami through 2007 -- with estimates reaching $1 billion by the time the operation was shut down by federal agents in February.

Ralph Janvey, the court receiver, has been working with federal agents but is now pushing for more information directly from Stanford lawyers.

Loumiet and his firm have agreed to hand over records of legal work for Stanford's U.S. companies, but are fighting to keep details of Stanford's ventures in Antigua and other foreign countries confidential.

``There are legal issues regarding jurisdiction and client privilege that must be resolved before we proceed further,'' said Eleanor Kerlow, a spokeswoman for Hunton & Williams.

Judge David Godbey in Houston is expected to decide whether the firm must meet the receiver's demands.

Kristie Blumenschein, an attorney with the receiver's firm, said they are prepared to fight for the records.

Beyond searching for assets, Blumenschein said the receiver will be reviewing the actions of the lawyers dating to the 1990s. She would not elaborate, but experts said they expect Janvey to aggressively investigate any damage by lawyers in Antigua.

Thomas Tew, a Miami attorney and receiver in major fraud cases, said Janvey can also demand the lawyers be forced to testify about what they knew.

He said any conversations they had with Stanford about his ongoing crises are open to review, and not protected by attorney-client privilege.

``Those are what we call the keys to the kingdom, because so often they are the most candid conversations,'' Tew said. ``You want to understand and see what happened . . . that's why this is such a hot-button issue.''



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