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Keeping Foreign Corruption out of the United States: Four Case Histories

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Keeping Foreign Corruption out of the United States: Four Case Histories United States Senate PERMANENT SUBCOMMITTEE ON INVESTIGATIONS Committee on Homeland Security and Governmental Affairs *** Carl Levin, Chairman Tom Coburn, Ranking Minority Member KEEPING FOREIGN CORRUPTION OUT OF THE UNITED STATES: FOUR CASE HISTORIES MAJORITY AND MINORITY STAFF REPORT PERMANENT SUBCOMMITTEE ON INVESTIGATIONS UNITED STATES SENATE RELEASED IN CONJUNCTION WITH THE PERMANENT SUBCOMMITTEE ON INVESTIGATIONS FEBRUARY 4, 2010 HEARING SENATOR CARL LEVIN Chairman SENATOR TOM COBURN, M.D. Ranking Minority Member PERMANENT SUBCOMMITTEE ON INVESTIGATIONS ELISE J. BEAN Staff Director and Chief Counsel ROBERT L. ROACH Counsel and Chief Investigator LAURA E. STUBER Counsel ADAM K. PARKS ICE Detailee JASON E. MEDICA ICE Detailee ADAM HENDERSON Professional Staff Member ROBERT KAPLAN Intern CHRISTOPHER J. BARKLEY Staff Director to the Minority JUSTIN J. ROOD Senior Investigator to the Minority MARY D. ROBERTSON Chief Clerk 7/10 Permanent Subcommittee on Investigations 199 Russell Senate Office Building – Washington, D.C. 20510 Main Number: 202/224-9505 Web Address: www.hsgac.senate.gov [Follow Link to “Subcommittees,” to “Investigations”] KEEPING FOREIGN CORRUPTION OUT OF THE UNITED STATES: FOUR CASE HISTORIES TABLE OF CONTENTS I. EXECUTIVE SUMMARY. ................................................. 1 A. Findings . ........................................................ 5 (1) Lawyers............................................................ 5 (2) Real Estate Agents.................................................... 5 (3) Escrow Agents....................................................... 5 (4) Lobbyist............................................................ 5 (5) Offshore Corporations................................................. 5 (6) University. ......................................................... 5 (7) Personal Accounts.................................................... 5 (8) Government Accounts................................................. 6 (9) Correspondent Accounts............................................... 6 (10) Vendor PEP Lists. ................................................... 6 B. Recommendations........................................................ 6 (1) World Bank PEP Recommendations...................................... 6 (2) Real Estate and Escrow Agent Exemptions. 6 (3) Attorney-Client and Law Office Accounts. 6 (4) U.S. Shell Corporations................................................ 6 (5) Immigration Restriction................................................ 6 (6) Visa Restriction...................................................... 7 (7) Professional Guidelines................................................ 7 (8) FATF Recommendations............................................... 7 II. FOREIGN CORRUPTION AND MONEY LAUNDERING....................... 8 III. OBIANG CASE STUDY: USING U.S. LAWYERS, REAL ESTATE AND ESCROW AGENTS, AND WIRE TRANSFER SYSTEMS TO BRING SUSPECT FUNDS INTO THE UNITED STATES............................................... 1 5 A. Background. .. ......................................................... 1 8 B. Obiang Use of Attorneys To Bring Suspect Funds Into the United States. 26 (1) Attorney Michael J. Berger............................................. 2 6 (a) Incorporating Shell Companies and Paying Bills. 2 7 (b) Bringing In and Moving Suspect Funds.. 2 8 i. Union Bank of California........................................ 30 ii. Bank of America. ............................................. 3 5 iii. Citibank ..................................................... 4 3 iv. PayPal....................................................... 4 5 (c) Compensation. .................................................. 46 (2) Attorney George I. Nagler.............................................. 4 7 (a) Incorporating Shell Companies...................................... 4 8 i (b) Bringing In and Moving Suspect Funds.. 5 1 i. Cal National Bank............................................. 5 1 ii. City National Bank............................................. 5 4 iii. Pacific Mercantile Bank......................................... 6 2 (c) Obtaining Insurance for Obiang Assets. 6 6 (d) Awareness of the Suspect Origins of Obiang Funds. 6 9 (3) Analysis............................................................ 7 0 C. Obiang Use of Real Estate and Escrow Agents To Purchase U.S. Property With Suspect Funds........................................................... 7 3 (1) Real Estate Agent Neil Baddin.......................................... 7 4 (2) Real Estate Agent John Kerrigan......................................... 8 1 (3) Analysis............................................................ 8 5 D. Obiang Use of a U.S. Escrow Agent To Purchase a Private Jet with Suspect Funds.. 8 5 E. Obiang Use of U.S. Wire Transfer Systems To Move Millions of Dollars in Suspect Funds........................................................... 9 7 (1) $73 Million Wired Through Wachovia Bank. 9 8 (2) $37 Million Wired Through Citibank.....................................101 F. Conclusion. .............................................................105 IV. BONGO CASE STUDY: USING LOBBYIST, FAMILY, AND U.S. TRUST ACCOUNTS TO BRING SUSPECT FUNDS INTO THE UNITED STATES. .......106 A. Background. ............................................................106 B. Bongo Use of U.S. Lobbyist To Purchase Armored Cars and C-130 Aircraft. 110 (1) Purchase of Armored Cars..............................................114 (2) Purchase of C-130 Aircraft.............................................120 (3) Conduit for Suspect Funds. ............................................139 (4) Analysis............................................................142 C. Bongo Use of a Daughter’s U.S. Bank Accounts To Move Suspect Funds Into the United States............................................................142 (1) HSBC Bank.........................................................143 (2) Commerce Bank. ....................................................145 (3) JP Morgan Chase.....................................................158 (4) Analysis............................................................159 D. Bongo Use of U.S. Trust Account. ..........................................159 (1) Fidelity Investments. .................................................161 (2) HSBC Bank.........................................................165 (3) Analysis............................................................171 E. Conclusion. .............................................................171 V. ABUBAKAR CASE STUDY: USING OFFSHORE COMPANIES TO BRING SUSPECT FUNDS INTO THE UNITED STATES...............................173 A. Background. .. ..........................................................174 B. Using Offshore Corporations To Bring Suspect Funds Into the United States.. 188 (1) Citibank............................................................189 (2) Chevy Chase........................................................202 (3) Wachovia Bank......................................................211 ii (4) Eagle Bank..........................................................221 (5) Suntrust Bank. ......................................................222 (6) Overview of Offshore Funds............................................226 C. American University and AUN..............................................233 D. Conclusion. .............................................................241 VI. ANGOLA CASE STUDY: EXPLOITING POOR PEP CONTROLS...............243 A. Background. .. ..........................................................244 B. An Angolan PEP: Moving Millions of Dollars For An Arms Dealer. 247 (1) Background.........................................................249 (2) Falcone Accounts at Bank of America. ...................................252 (3) Analysis............................................................261 C. An Angolan Government Official: Moving $50 Million at the Request of the Governor of the Angolan Central Bank. ......................................269 (1) Background.........................................................270 (2) First Attempt To Transfer the $50 Million. 272 (3) Second Attempt To Transfer the $50 Million. 282 (4) Analysis............................................................299 D. An Angolan Financial Institution: Moving Hundreds of Millions of Dollars For Banco Africano de Investimentos............................................299 (1) Background.........................................................299 (2) HSBC USA Accounts.................................................302 (3) BAI’s Hidden Owners.................................................303 (4) BAI’s Missing AML Policies and Procedures.. 312 (5) BAI Credit Cards.....................................................315 (6) No SCC Designation Despite PEP Involvement.. 319 E. Conclusion. ...........................................................323 # # # iii KEEPING FOREIGN CORRUPTION OUT OF THE UNITED STATES: FOUR CASE HISTORIES This Report examines how politically powerful foreign officials, their relatives, and close associates – referred to in international agreements as Politically Exposed Persons (PEPs) – have used the services of U.S. professionals and financial institutions to bring large amounts of suspect funds into the United States to advance their interests. Using four case histories, this Report shows how some PEPs have used U.S. lawyers, real estate and escrow agents, lobbyists,
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