Articles of Interest 091

Upsetting More than Regulators

If a bank fails to identify a money laundering scheme and report it properly to the authorities, is it liable for the losses incurred by those who fell victim to the scheme?

Legal risk traditionally meant the risk a bank faced in following the letter and the spirit of the law.  Does a new risk need to be added as a subsection of legal risk, namely civil litigation risk?

http://www.consumeraffairs.com/news04/2009/01/bofa_scam.html

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Bank Of America Sued In Internet Ponzi Scheme

Hundreds of millions of dollars collected in gigantic swindle

January 30th, 2009

Victims of an Internet-based Ponzi scheme have filed a lawsuit against Bank of America and the organizers of the scheme in the United States District Court for the District of Columbia.

Using elaborate misrepresentations, including numerous video postings on YouTube, organizers induced victims from around the country to purchase so-called "ad packages" from the following entities: AdSurfDaily, AdSurfDaily Cash Generator, Golden Panda Ad Builder, and La Fuente Dinero.

The scheme promised that participants could earn large rebates for viewing web advertisements and commissions for referring additional participants.

Hundreds of millions of dollars were collected from approximately 140,000 victims across the country, in amounts ranging from $500 to $250,000 at large rallies and through online deposits.

"We intend to hold all defendants accountable for this Ponzi scheme, including the Bank of America, and secure the return of all funds that were lost by innocent victims, said Steven N. Berk, a partner in the law firm of Chavez & Gertler LLP and a former federal prosecutor representing the plaintiffs in this case.

How does Bank of America figure into all of this?

The complaint alleges that a scheme of this magnitude could not have been possible without the involvement of a financial institution like Bank of America.

At least one other financial institution closed the accounts of the organizers for suspicious activity, according to a sworn government complaint. VISA also considered the enterprise suspicious and would not process charges directed to the scheme by would be victims. And the very popular PayPal payment system rejected efforts by participants to purchase "ad packages" using their system.

Nevertheless, the suit charges Bank of America, in the face of tell-tale signs of money laundering and other criminal conduct, provided both the imprimatur of legitimacy to the scheme and the banking infrastructure that facilitated many thousands of transactions for over two years.

Beginning in November of 2006, Bank of America allegedly allowed the scheme's main perpetrator carte blanche at the bank. The complaint claims the scammers opened and maintained at least 10 separate accounts for running an unlawful Ponzi scheme. These accounts were opened at a tiny Bank of America branch in Quincy, Florida under various "doing business as" designations.

The suit claims Bank of America looked the other way when these accounts amassed deposits in the tens of millions of dollars from thousands of individual transactions.

"We expect to establish that Federal banking regulations, including the Bank Secrecy Act, the USA Patriot Act and related anti-money laundering regulations, clearly required Bank of America to scrutinize the legitimacy of the tens, if not hundred of millions of dollars deposited into a branch in Quincy, Florida to fuel this scheme. Red flag after red flag was ignored by Bank of America. And with the assistance of Bank of America, this fraudulent scheme needlessly expanded" said Steven N. Berk, Counsel for the Plaintiffs.

Articles of Interest 090

Drugs and Guns

If there was any doubt that international narcotics could be intertwined with terrorist activity, the prosecution of Bashir Noorzai should answer all questions.

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News Release
FOR IMMEDIATE RELEASE
April 30, 2009
Garrison Courtney 
Office of Public Affairs
202-307-7977

Top Taliban Associate and Former Mujahideen Warlord Sentenced to Life in Prison on Heroin Trafficking Charges

APR 30 -- LEV L. DASSIN, the Acting United States Attorney for the Southern District of New York, announced that BASHIR NOORZAI, a former Mujahideen warlord and strong ally of the Taliban, was sentenced today to life in prison on heroin importation and distribution conspiracy charges. NOORZAI was found guilty of the charges following a jury trial before Federal Judge DENNY CHIN in September 2008. According to the evidence at trial:

NOORZAI, the leader of his namesake tribe, one of Afghanistan's largest and most influential tribes, owned opium fields in the southern province of Kandahar, Afghanistan, and had subordinates convert the opium into heroin at laboratories in Afghanistan's border regions. Heroin from these labs was later imported into the United States, hidden in suitcases and on ships. As early as 1990, NOORZAI had a network of distributors in New York City who sold his heroin.

During the Russian occupation of Afghanistan, NOORZAI raised his own army of Mujahideen fighters, financed and armed with drug proceeds. After the Russian army had quit Afghanistan, NOORZAI ruled western Kandahar, establishing and controlling his own police, border guards and courts.

NOORZAI met MULLAH MOHAMMAD OMAR in the 1980s while the two fought in the same Mujahideen faction. In the mid-1990s, when the Taliban was ascending to power in Afghanistan, NOORZAI used his influence in Kandahar to assist OMAR in securing the position of supreme leader of the Taliban. NOORZAI then provided the Taliban with arms, including AK-47 assault rifles, rocket propelled grenade launchers, and anti-tank weapons, as well as vehicles and a portion of the proceeds of his narcotics trafficking activities. In 2001, after the United States began military operations in Afghanistan, NOORZAI, at OMAR's request, provided the Taliban with 400 of his own fighters to wage a battle against Afghanistan's Northern Alliance in Mazar-e-Sharif.

In return for his financial and other support, the Taliban permitted NOORZAI to continue his drug trafficking activities with impunity. In addition, NOORZAI and his co-conspirators benefitted from advance knowledge of the Taliban's 2000 opium ban, and used that information to stockpile opium and sell it at a tremendous profit after the ban caused opium prices to spike.

At trial, NOORZAI was found guilty of both counts against him -- one count of conspiring to import heroin, and to manufacture and distribute heroin knowing that it would be imported into the United States, and one count of conspiring to distribute heroin.

NOORZAI, who faced a mandatory minimum sentence of 10 years, was sentenced by Judge CHIN to life imprisonment on each count in the Indictment. In sentencing NOORZAI, Judge CHIN found that he led a conspiracy involving hundreds of people, and that the conspiracy helped arm the Taliban with narcotics proceeds.

Prior to his arrest in 2005, NOORZAI had been designated by the Department of Justice to the Consolidated Priority Organization Target ("CPOT") list, a list of the most powerful and dangerous narcotics traffickers in the world. His successful prosecution is the result of a long-term investigation by this Office's International Narcotics Trafficking Unit, the Drug Enforcement Administration's New York Field Division, its Kabul, Afghanistan and Islamabad, Pakistan Country Offices, and
the New York Joint Terrorism Task Force, which includes special agents of the Federal Bureau of Investigation. The DEA's Special Operations Division also assisted in the investigation and prosecution.

"BASHIR NOORZAI's worldwide narcotics network supported a Taliban regime that made Afghanistan a breeding ground for international terrorism, a legacy that continues to destabilize the region," said Acting United States Attorney LEV L. DASSIN."Today's sentence definitively puts an end to Noorzai’s long criminal career."

The prosecution was handled by the Office’s International Narcotics Trafficking Unit. Assistant United
States Attorneys JOCELYN STRAUBER, ANJAN SAHNI, BOYD JOHNSON, and ANIRUDH BANSAL are in charge of the prosecution.

Articles of Interest 089

Lack of Proper Training

The former bank managers from Bank of China have been sentenced in the United States for laundering their embezzled funds through Hong Kong, Canada and Las Vegas casinos.  Sentences were imposed ranging from eight to twenty-five years in prison.

Given the general lack of creativity - especially when one has half a billion dollars at one's disposal - exercised by the BoC managers, money launderers would do well to seek the advice of others.  Where were multiple shell banks and international business corporations registered in faraway offshore financial havens?  Where were the hidden tricks that should be known to bankers employed with a global financial institution? 

Anti-money laundering training at BoC clearly does not delve into enough detail.

http://www.usdoj.gov/opa/pr/2009/May/09-crm-446.html

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FOR IMMEDIATE RELEASE
Wednesday, May 6, 2009
WWW.USDOJ.GOV

CRM
(202) 514-2007
TDD (202) 514-1888

Former Bank of China Managers and Their Wives Sentenced for Stealing More Than $485 Million, Laundering Money Through Las Vegas Casinos

Two former managers of the Bank of China and their wives were sentenced today after their convictions on Aug. 29, 2008, by a federal jury in Las Vegas on charges of racketeering, money laundering, international transportation of stolen property as well as passport and visa fraud.

U.S. District Judge Philip M. Pro sentenced Xu Chaofan aka Hui Yat Fai to 25 years in prison, Xu Guojun aka Hui Kit Shun to 22 years in prison, Kuang Wan Fang aka Wendy Kuang to eight years in prison and Yu Ying Yi to eight years in prison. All four defendants were sentenced to three years of supervised release and ordered to pay $482 million in restitution. Denaturalization proceedings against Kuang Wan Fang and Yu Ying Yi have been initiated by the government.

Evidence presented during the trial established the elaborate scheme to defraud the Bank of China of at least $485 million, orchestrated by former managers Xu Chaofan, Xu Guojun and a third former bank manager, Yu Zhendong aka Yu Wing Chung, who pleaded guilty in connection with this investigation and cooperated with the United States.  According to information presented in court, the scheme involved efforts by the bank managers to launder the stolen money through Hong Kong, Canada and the United States, among other countries, and then immigrate to the United States from China with their wives by obtaining false identities and entering into sham marriages with naturalized U.S. citizens.  Evidence also proved that the bank managers’ true wives, Kuang Wan Fang and Yu Ying Yi, assisted their husbands in laundering the proceeds of the fraudulent scheme and violated U.S. immigration laws by entering this country illegally and then securing U.S. citizenship and passports through fraudulent means. 

All five defendants were charged with engaging in a RICO conspiracy that began in 1991 and continued until October 2004 when the former bank managers and their wives were arrested.  The underlying racketeering activities included engaging in monetary transactions with stolen money, transportation of stolen money, passport fraud and visa fraud.  Evidence presented at trial established that the former bank managers created a number of shell corporations in Hong Kong and with the assistance of others funneled the bank’s money into these companies as well as numerous personal bank and investment accounts.  Assisted by their wives, relatives and others, the former bank managers then laundered the stolen proceeds through Canada and the United States.  Evidence presented at trial included a significant number of transactions with the stolen money through Las Vegas casinos, including bets at the casinos that ranged from $20,000 up to $80,000.

All five defendants also were convicted of engaging in a money laundering conspiracy and conspiracy to transport stolen money that began in 1998 and continued through October 2004.  These conspiracy charges focused on the laundering of the stolen money in the United States not only through casinos, but also through numerous bank accounts established in the United States by the defendants.

The two former bank managers were also convicted on three counts each of visa fraud – specifically, the possession and use of a fraudulently procured non-immigrant U.S. visa to enter and/or remain in the United States.  The two bank managers’ true wives were convicted of three counts each of passport fraud – specifically, the use of a U.S. passport secured through a false statement to enter or facilitate their stay in the United States.

"We will hold fully accountable those foreign nationals who abuse the financial systems of their home countries and who then, by fraudulent means, seek to live richly off their ill-gotten gains in the United States," said Assistant Attorney General Lanny A. Breuer.  "Despite the best efforts of these defendants to avoid detection, their scheme first to steal nearly $500 million from a Chinese bank, and then to hide themselves and the money in the United States, was exposed thanks to the tireless efforts of federal agents and prosecutors. With their hard work, and the work of countless others like them who are on constant guard against theft and fraud, the Department will continue to unravel the most complicated financial crimes."

"The defendants sentenced today engaged in a complex scheme from across the globe, using U.S. banks and casinos to launder more than $485 million stolen from the Bank of China.  Financial crimes like these know no borders.  By partnering in investigations such as this one, the FBI and our law enforcement partners in the United States and abroad can combine our collective resource to most effectively attack this worldwide criminal threat," said Assistant Director Kenneth W. Kaiser, FBI Criminal Investigative Division.

Xu Chaofan, Xu Guojun, Kuang Wan Fang and Yu Ying Yi were charged on Sept. 21, 2004, in an 11-count indictment with conspiring to violate, and substantive violations of, U.S. immigration law.  The third former bank manager, Yu Zhendong, pleaded guilty to engaging in a racketeering enterprise on Feb. 18, 2004, and voluntarily returned to China, where he was convicted for embezzlement for his role in the bank theft.  Yu Zhendong’s true wife, Yu Xuhui (aka Fion Yu), pleaded guilty on April 26, 2005, to unlawfully procuring U.S. citizenship.  She has agreed to voluntarily relinquish her American citizenship, but was permitted to remain in the United States with the couple’s children as long as she does not commit another crime.  Yu Zhendong’s fake American wife, Shanna Yu Ma (aka Yu Shuzhan) pleaded guilty to submitting a false statement to the Immigration and Naturalization Service, now part of the Department of Homeland Security, in support of Yu Xuhui’s application for naturalization.  Both Ma and Yu were sentenced in December 2007 to terms of probation.

This matter was prosecuted by Trial Attorney Krista Tongring and former Trial Attorney Cynthia Stone and of the Criminal Division’s Organized Crime and Racketeering Section and Assistant U.S. Attorney Ronald Cheng of the U.S. Attorney’s Office for the Central District of California.  Organized Crime Strike Force Chief Eric Johnson of the U.S. Attorney’s Office for the District of Nevada served as local counsel.  Significant assistance was also provided by Kyle Latimer of the Criminal Division’s Office of International Affairs.  The U.S. Attorney’s Office for the District of Nevada provided significant support for the prosecution and coordination of witnesses from throughout the United States and overseas.  The case was investigated by the FBI’s Las Vegas Field Office and U.S. Immigration and Customs Enforcement of the Department of Homeland Security.  Essential support was also provided by the FBI’s offices in Beijing and Hong Kong.  The government of the People’s Republic of China, in particular the Ministries of Justice and Public Security along with the Hong Kong Department of Justice and Hong Kong Police Force, also provided substantial assistance in producing evidence and making witnesses available, both for testimony at trial and videotaped depositions.

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09-446

Articles of Interest 088

Word from on High

Times are tough for financial institutions but regulatory expectations remain the same in the realm of anti-money laundering and counter-terrorist financing.  Reporting entities in Canada – and abroad – would do well to ask their supervisory agencies and financial intelligence units how the public sector is assisting them to defray the enormous expense of mounting an effective financial crime risk management regime.  For those worried about solvency risk vs. legal / regulatory risk, this is a realistic question.

“Lack of money is the root of all evil.”

- George Bernard Shaw (1856-1950)

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http://www.investmentexecutive.com/client/en/News/ImprimerDetail.asp?Id=49265&cat=8&IdSection=8&PageMem=&nbNews=&IdPub=

Don’t cut costs at expense of anti-money laundering efforts: OSFI

Senior director says it’s vital to take all the steps necessary to deter criminal elements

Wednesday, May 6, 2009

By James Langton

Financial services firms must not cut back on their efforts to fight money laundering despite the recession and the pressure to reduce expenses, regulators say.

Speaking to an information session on the fight against money laundering and terrorism financing in Toronto on Wednesday, Nicolas Burbidge, senior director, compliance division of the Office of the Superintendent of Financial Institutions, noted that the financial services industry has made progress in recent years against money laundering, but, he pointed out that “as cash has become harder to launder, criminals have become more creative in their efforts.”

Moreover, he noted that the financial crisis and the economic downturn have impacted the financial sector: “We understand the pressures on management to perform and to reduce expenses, but this should not occur at the expense of your anti-money laundering and anti-financing financing program. Your controls, and financial intelligence provided to FINTRAC, are critically important for the continued fight against financial crime, and the integrity of the Canadian and global financial systems.”

Burbidge said that “it is vital that Canada’s financial system continue to be seen as taking all the steps necessary to deter criminal elements that may seek to use the Canadian financial system for their own ends.”

That includes a commitment to the fight from the private sector.

Important changes were made to Canada’s anti-money laundering regime in 2008, he noted, but some firms haven't adopted all the necessary changes.

“Although many financial institutions have now developed adequate plans to implement these changes, other institutions are still lagging in some key areas. We have had to underline the need for these institutions to apply adequate resources, controls and procedures to ensure effective compliance can be achieved. We will continue to take action as needed in this area,” he said.

A requirement for financial institutions to develop an inherent risk methodology, which enables them to identify situations that are at higher risk for money laundering and terrorism financing, is one of the biggest changes Burbidge noted. And, he reported that OSFI’s work “indicates that many financial institutions, large and small, are challenged by this requirement.”

He added: “It is critical to the success of the risk-based approach in your AML/ATF program that the assessment of money laundering and terrorism financing risk gets done right. The required controls flow from the assessment of risk, and if risks are not adequately identified, then controls are likely to be weak.”

Articles of Interest 087

Why Lay Money Laundering Charges?

Former fund manager Arthur G. Nadel promised investors the moon but failed to deliver.  In fact, he now faces a possible 280 years in prison, an unpleasant reality at the tender age of 76.

Authorities charged him with wire fraud, securities fraud and mail fraud, but not money laundering.  In this case, laying additional charges may be pointless, especially when efforts are already being made to recover the victims' losses.  Yet laying a money laundering charge would send a strong message to the securities markets industry that the problem does indeed exist.

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For Immediate Release April 28, 2009

United States Attorney's Office Southern District of New York Contact: (212) 637-2600 Former Hedge Fund Manager Arthur G. Nadel Indicted on Fraud Charges LEV L. DASSIN, the Acting United States Attorney for the Southern District of New York, announced that ARTHUR G. NADEL, 76, of Sarasota, Florida, was indicted today on securities, mail, and wire fraud charges stemming from a ten-year scheme to defraud investors out of millions of dollars. NADEL previously was arrested in this case on January 27, 2009. As alleged in the fifteen-count Indictment filed in Manhattan federal court: From 1999 through January 2009, NADEL perpetrated a scheme to defraud investors in six different funds: (a) Victory IRA Fund Ltd.; (b) Scoop Real Estate LP; (c) Victory Fund Ltd.; (d) Valhalla Investment Partners; (e) Viking Fund, LLC; and (f) Viking IRA Fund, LLC (collectively the "Funds"). NADEL solicited prospective clients to invest in the Funds by making various misrepresentations about the performance and value of the Funds, including that the net asset value of each of the Funds was tens of millions of dollars. NADEL also claimed to investors that his purchases and sales of securities in the Funds had generated cumulatively more than $271 million in gains. In truth, NADEL’s trading resulted in an overall net loss in the Funds. To further the scheme, NADEL created and caused others to create false and fraudulent client account statements, among other documents, that reflected fictitious positive returns consistent with the returns NADEL represented to investors he had achieved. Based, in part, on NADEL's false statements, from 1999 through January 2009, more than 350 clients invested more than $360 million with the Funds. NADEL received tens of millions of dollars in management fees and performance incentive fees and, moreover, transferred and caused to be transferred millions of dollars in investor money in the Funds to accounts and entities that he owned and/or controlled. The investors in the Funds did not authorize NADEL to make these transfers, and NADEL failed to disclose them. NADEL is charged with six counts of securities fraud, one count of mail fraud, and eight counts of wire fraud. Each securities fraud count carries a maximum sentence of 20 years in prison and a maximum fine of $5 million, or twice the gross gain or loss from the offense. The mail fraud count carries a maximum sentence of 20 years in prison and a maximum fine of $250,000, or twice the gross gain or loss from the offense. Each wire fraud count carries a maximum sentence of 20 years in prison and a maximum fine of $250,000, or twice the gross gain or loss from the offense. If found guilty on all counts, NADEL faces a combined statutory maximum sentence of 280 years’ imprisonment. NADEL is also subject to mandatory restitution. The Indictment includes forfeiture allegations which would require NADEL to forfeit the amount of money involved in the charged crimes. NADEL is currently detained pending his meeting bail conditions set by United States District Judge DENISE L. COTE following NADEL's January arrest. NADEL is expected to be arraigned on the Indictment by United States District Judge JOHN G. KOELTL on April 30, 2009. Mr. DASSIN praised the work of the Federal Bureau of Investigation, and thanked the United States Securities and Exchange Commission for its assistance. He added that the investigation is continuing. Assistant United States Attorneys REED M. BRODSKY, MARIA E. DOUVAS, and JEFFREY ALBERTS are in charge of the prosecution. The charges contained in the Indictment are merely accusations, and the defendant is presumed innocent unless and until proven guilty.

Articles of Interest 086

Read the Small Print

It would appear that “Californian financier” Danny Peng forgot to read the small print on the enclosed form, in particular Section II Part 27.  A Currency Transaction Report applies to both cash coming in to a financial institution and cash going out.  Structuring transactions is considered “not cricket”.  If you’re going to allegedly defraud your investors of millions and then get rolled by the cops, don’t run down to the bank branch with a duffel bag and hope to fill it with cash before making a run for the border.

“One should absorb the colour of life, but one should never remember its details. Details are always vulgar.”

- Oscar Wilde, "The Picture of Dorian Gray"
Irish dramatist, novelist, & poet (1854 - 1900)

For financial institutions dealing with dubious private equity firms, ManchesterCF’s Financial Crime in Capital Markets course may be of interest.  For further information, visit  http://www.manchestercf.com/Files/MCF_Financial_Crime_Cap_Mkts.pdf

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If you are not interested in receiving the “Articles of Interest” e-newsletter from ManchesterCF, please reply to this message and write in the subject heading “Remove Subscription”.  Your e-mail address is never provided to outside third-parties.  If you wish to forward this message, please include all contents of this message to the receiver.  The contents of this electronic message are confidential and are intended for the recipient only.  If you have received this message in error, please contact the sender and delete the message.  All contents of this electronic message are protected by copyright where appropriate  – © Copyright ManchesterCF 2009

An overview of ManchesterCF is available athttp://www.manchestercf.com/Files/ManchesterCF_Overview.pdf

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http://online.wsj.com/article/SB124104989372970935.html#printMode


APRIL 30, 2009, 8:34 A.M. ET

Peng Confined to His Home
By MARK MAREMONT

California financier Danny Pang was released on a $1 million bond and confined to his Newport Beach home with electronic monitoring, according to a spokesman for the U.S. attorney in Los Angeles.

Mr. Pang, 42 years old, was arrested Tuesday on charges he structured dozens of large cash withdrawals in a way to avoid triggering federal reports designed to combat money laundering.

The criminal charges are separate from civil allegations filed Monday by the Securities and Exchange Commission that Mr. Pang ran a massive international fraud involving hundreds of millions of dollars. Mr. Pang stepped down earlier this month as CEO of Private Equity Management Group, or PEMGroup, of Irvine, Calif. His attorney has denied the SEC's fraud charges.

The release conditions were set Wednesday by a U.S. magistrate in Santa Ana, Calif. 

Articles of Interest 085

Who can you trust?

The global investment industry currently faces hard times.  In 2007, Goldman Sachs CFO David Viniar famously stated that daily market activities in some securities were 25 standard deviations from the norm.  It would appear that the bizarre is the new norm within today’s financial markets.

The United States Federal Bureau of Investigation (FBI) has laid fraud and money laundering charges against Anthony Vassallo, 29, for allegedly duping members of his church via a Ponzi scheme into investing USD40-million in a “hedge fund” returning 3.5% a month.  Former NFL star Clyde “Peter” Hall, 70, pleaded guilty to fraud (but not money laundering), as he had peddled phoney banking instruments worth millions of dollars to investors.  When the phoney investments went awry, he then charged investors for the service of attempting to recoup the same investor funds he had pilfered.  For both news releases, please see attached.

When financial markets turn downwards, incidents of fraud will rise.  When financial markets plummet off a cliff, reality takes a back seat.  If you can’t trust a Mormon or an NFL star, who can you trust?

“May you live in interesting times.”

- Chinese curse, date unknown

To expand employee knowledge in capital markets financial crime is to bolster the firm’s defences against implication in an expensive and damaging financial crime event.  For further information on ManchesterCF’s Financial Crime in Capital Markets course, visit http://www.manchestercf.com/Files/MCF_Financial_Crime_Cap_Mkts.pdf

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If you are not interested in receiving the “Articles of Interest” e-newsletter from ManchesterCF, please reply to this message and write in the subject heading “Remove Subscription”.  Your e-mail address is never provided to outside third-parties.  If you wish to forward this message, please include all contents of this message to the receiver.  The contents of this electronic message are confidential and are intended for the recipient only.  If you have received this message in error, please contact the sender and delete the message.  All contents of this electronic message are protected by copyright where appropriate  – © Copyright ManchesterCF 2009

An overview of ManchesterCF is available at http://www.manchestercf.com/Files/ManchesterCF_Overview.pdf