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Case 1:19-Cr-00064-GHW Document 82 Filed 10/26/20 Page 1 of 33
Case 1:19-cr-00064-GHW Document 82 Filed 10/26/20 Page 1 of 33 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - x : UNITED STATES OF AMERICA : : - v. - : 19 Cr. 64 (GHW) : NATALIE MAYFLOWER SOURS EDWARDS, : a/k/a “Natalie Sours,” : a/k/a “Natalie May Edwards,” : a/k/a “May Edwards,” : : Defendant. : : - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - x THE GOVERNMENT’S SENTENCING MEMORANDUM AUDREY STRAUSS Acting United States Attorney Southern District of New York Kimberly J. Ravener Daniel C. Richenthal Assistant United States Attorneys - Of Counsel - Case 1:19-cr-00064-GHW Document 82 Filed 10/26/20 Page 2 of 33 TABLE OF CONTENTS PRELIMINARY STATEMENT .............................................................................................. 1 BACKGROUND..................................................................................................................... 2 I. The Offense ...................................................................................................................... 2 A. The Defendant, FinCEN, and an Overview of Her Offense ............................................ 2 B. The Defendant’s Initial Communications with Reporter-1 and Her Unsubstantiated Complaints Concerning FinCEN .................................................................................. 4 C. The Defendant’s Unrelated Sharing of SARs with Reporter-1 ........................................ 6 D. The Defendant’s Running -
Fincen Files and Professionals of Integrity
10/1/2020 FinCEN Files and Professionals of Integrity Hello all, Last month saw the latest leak of documents to reveal the vast scale of money laundering enabled by banks and regulators throughout the world. Following the Panama and Paradise Papers, and the Lux and Luanda Leaks, the FinCEN Files once again shed light on how the global elite have been able to move vast sums of dirty money around the world, highlighting how some of the biggest banks and nancial institutions have continued to allow suspicious transactions to take place. At the heart of the FinCEN scandal is the leak of more than 2000 so-called Suspicious Activity Reports (SARs) led with the US Treasury Department’s Financial Crimes Enforcement Network. Details of these les and their links with illegal activities will doubtless continue to emerge in the coming weeks and months, but the initial information highlights not just the role of nancial institutions, but also - as Oliver https://mailchi.mp/globalintegrity/fincen-files-and-professionals-of-integrity-2503638 1/9 10/1/2020 FinCEN Files and Professionals of Integrity Bullough has pointed out in his Oligarchy newsletter - the signal failure of western politicians to properly resource investigators and prosecutors to act on the SARs. The FinCEN Files' revelations serve to underline the relevance of the focus on this month’s newsletter: promoting integrity in professional elds, as well as one of the key GI-ACE themes on international architecture, which includes Jackie Harvey's recent piece on practical research on benecial ownership. Thank you, Paul Heywood, Director of GI-ACE https://mailchi.mp/globalintegrity/fincen-files-and-professionals-of-integrity-2503638 2/9 10/1/2020 FinCEN Files and Professionals of Integrity Cities of Integrity: Building Integrity in Urban Planners Our Cities of Integrity research team closed off this year’s Southern Africa City Studies Conference by bringing together leading voices on the topic of corruption and the desire for integrity in South Africa's local governance sphere. -
Tom Burgis October 19Th, 2020 INTRODUCTION Tom Burgis Is an Investigations Correspondent at the Financial Times, Based in London
Rise of a New Kleptocracy: How Dirty Money is Conquering the World | Tom Burgis October 19th, 2020 INTRODUCTION Tom Burgis is an investigations correspondent at the Financial Times, based in London. Previously, he was the paper's west Africa correspondent, based in Lagos, and Johannesburg correspondent. His latest book, “Kleptopia: How Dirty Money Is Conquering the World,” chronicles the world of dirty money and its complex web of criminals, money launderers, and politicians who enable it. The Washington Post calls it a “magisterial account of the money and violence behind the world’s most powerful dictatorships.” His book, "The Looting Machine: Warlords, Tycoons, Smugglers and the Systematic Theft of Africa's Wealth," was published in 2015. The New York Times called it a "brave, defiant book." Burgis won top prize for investigative reporting at the 2015 Society of Publishers in Asia awards and FT's Jones-Mauthner Memorial Prize in 2013, and was short-listed in 2015 for the European Press Prize and Young Journalist of the Year at the 2010 British Press Awards. Before joining the FT, he did a stint in Chile and traveled the world covering globalization and its discontents. WHY DO I CARE? Tom Burgis weaves together four stories that reveal a global web of corruption: the whistle blower from Basingstoke, England who stumbles on the secrets of a Swiss bank, an ex-Soviet billionaire building a private empire, the righteous Canadian lawyer with a tycoon ex-minister and bank founder client, and a Brooklyn crook protected by the CIA. Glimpses of this shadowy world have emerged over the years. -
Lender List 2021
LENDERS LIST 2021 www.cml.org.uk/lenders-handbook/ Does the lender accept personal searches and, if yes, what are the lender’s requirements? Lender Answer Accord Buy to Let Yes, subject to the requirements listed in Part 1 and provided you give an unqualified Certificate of Title. You must ensure that the search firm subscribes to the Search Code maintained by the Council of Property Search Organisations and monitored by the Property Codes Compliance Board. Accord Mortgages Ltd Yes these are acceptable provided 1) the search firm subscribes to the Search Code as monitored and regulated by the Property Codes Compli- ance Board (PCCB) 2) the requirements listed in Part 1 of this Handbook are met and 3) provided you give an unqualified Certificate of Title. Adam & Company Yes, provided they are undertaken by a reputable search agent who has adequate professional indemnity insurance and you can still give a clear Certificate of Title. Adam & Company Yes, provided they are undertaken by a reputable search agent who has International adequate professional indemnity insurance and you can still give a clear Certificate of Title. Ahli United Bank (UK) plc Please refer to Central Administration Unit Aldermore Bank PLC Yes, subject to the requirements set out in paragraph 5.4.7 and 5.4.8 of Part 1. We recommend that any firm carrying out a personal search is registered under The Search Code monitored by the Property Codes Compliance Board. Allied Irish Bank (GB), a Refer to AIB Group (UK) plc, Central Securities (GB) trading name of AIB Group (UK) Atom Bank plc Yes provided that they are undertaken by a reputable search agent who subscribes to the search code, as monitored by the Property Codes Com- pliance Board, is registered with the Council of Property Search Organisa- tions, has adequate professional indemnity insurance and where you can still give a clear certificate of title. -
Bank of England List of Banks
LIST OF BANKS AS COMPILED BY THE BANK OF ENGLAND AS AT 31 October 2017 (Amendments to the List of Banks since 30 September 2017 can be found on page 5) Banks incorporated in the United Kingdom Abbey National Treasury Services Plc DB UK Bank Limited ABC International Bank Plc Diamond Bank (UK) Plc Access Bank UK Limited, The Duncan Lawrie Limited (Applied to cancel) Adam & Company Plc ADIB (UK) Ltd EFG Private Bank Limited Agricultural Bank of China (UK) Limited Europe Arab Bank plc Ahli United Bank (UK) PLC AIB Group (UK) Plc FBN Bank (UK) Ltd Airdrie Savings Bank FCE Bank Plc Al Rayan Bank PLC FCMB Bank (UK) Limited Aldermore Bank Plc Alliance Trust Savings Limited Gatehouse Bank Plc Alpha Bank London Limited Ghana International Bank Plc ANZ Bank (Europe) Limited Goldman Sachs International Bank Arbuthnot Latham & Co Limited Guaranty Trust Bank (UK) Limited Atom Bank PLC Gulf International Bank (UK) Limited Axis Bank UK Limited Habib Bank Zurich Plc Bank and Clients PLC Habibsons Bank Limited Bank Leumi (UK) plc Hampden & Co Plc Bank Mandiri (Europe) Limited Hampshire Trust Bank Plc Bank Of America Merrill Lynch International Limited Harrods Bank Ltd Bank of Beirut (UK) Ltd Havin Bank Ltd Bank of Ceylon (UK) Ltd HSBC Bank Plc Bank of China (UK) Ltd HSBC Private Bank (UK) Limited Bank of Cyprus UK Limited HSBC Trust Company (UK) Ltd Bank of Ireland (UK) Plc HSBC UK RFB Limited Bank of London and The Middle East plc Bank of New York Mellon (International) Limited, The ICBC (London) plc Bank of Scotland plc ICBC Standard Bank Plc Bank of the Philippine Islands (Europe) PLC ICICI Bank UK Plc Bank Saderat Plc Investec Bank PLC Bank Sepah International Plc Itau BBA International PLC Barclays Bank Plc Barclays Bank UK PLC J.P. -
Illicit Financial Flows in Authoritarian States When There Is No Rule of Law
Illicit Financial Flows in Authoritarian States When There is No Rule of Law By Jodi Vittori 21 MARCH 2021 | GLOBAL INSIGHTS SERIES JODI VITTORI Illicit Financial Flows in Authoritarian States: When There is No Rule of Law he COVID-19 pandemic is proving a boon for corrupt, authoritarian leaders and their cronies, allowing them to expand opportunities T for crime and graft while curtailing oversight and accountability. Worldwide, Freedom House has assessed that democracy and human rights have deteriorated in eighty countries since the new coronavirus outbreak began.1 The problem is at its worst in highly repressive states and weak democracies where safeguards on democracy already were insufficient.2 As many klepto- At the same time, as Transparency International notes, the monumental influx of domestic and foreign resources provided to fight the pandemic have opened up more opportunities cratic regimes use for rent-seeking activity and its deleterious effects. Meanwhile, governments often have the pandemic as even more discretion to allocate resources and funds with weaker transparency, account- ability, and anticorruption oversight and enforcement mechanisms to provide checks on an excuse to clamp their behavior.3 It is thus no surprise that according to the aforementioned October 2020 down on media and Freedom House report, respondents in 45 countries considered “corruption and money in politics” to be among the top three issues associated with the COVID-19 response.4 civil society freedoms, As opportunities for kleptocracy increase, efforts to expose and reform illicit financial flows transparency, and focus usually—and often correctly—on financial centers situated in democracies. Those who accountability, it engage in kleptocratic activity are assumed to prize the overall, long-term political stability that derives from consolidated democratic systems and rule of law. -
Anti-Money Laundering and Sanctions Enforcement and Compliance in 2020 and Beyond December 10, 2020
Anti-Money Laundering and Sanctions Enforcement and Compliance in 2020 and Beyond December 10, 2020 Panelists: Stephanie L. Brooker Ella Alves Capone M. Kendall Day Adam M. Smith Moderator: F. Joseph Warin MCLE Certificate Information • Most participants should anticipate receiving their certificate of attendance via email approximately four weeks following the webcast. • Virginia Bar Association members should anticipate receiving their certificate of attendance six weeks following the webcast. • Please direct all questions regarding MCLE to [email protected]. 2 Agenda 1. Introduction 2. Regulatory, Legal, and Advisory Updates 3. AML / Sanctions Topics in the Spotlight 4. Recommended Best Practices 5. AML and Sanctions in the New Administration 3 Introduction U.S. Enforcement Agencies and Regulators f Enforcement Responsibilities Banking Regulators and Enforcers DOJ (Civil, Criminal, and SEC (Civil) Forfeiture) OCC Fed FinCEN (Civil) CFTC (Civil) FDIC NCUA FINRA (SRO) OFAC (Civil) DFS 5 U.S. Enforcement Agencies Secretary Janet Yellen (Nominee) Attorney General William Barr (Senate Confirmed) Steven Mnuchin (Senate Confirmed) Deputy Attorney General Under Secretary for Terrorism and Jeffrey Rosen Financial Intelligence (Senate Confirmed) Justin Muzinich (Acting) FinCEN Director National Security Division Criminal Division Ken Blanco Assistant Attorney General Assistant Attorney General (Career) John Demers Brian Rabbitt (Senate Confirmed) (Acting) OFAC Director Chief, Money Laundering Andrea Gacki and Asset Recovery Section (Career) Deborah Connor (Career) 6 International Enforcement Agencies and Regulators Reserve Bank of India (“RBI”) Hong Kong Securities and Futures Commission (“SFC”) Switzerland’s Office of the Attorney General and Financial Markey Supervisory Authority (“FINMA”) Canada’s Financial Transactions and European Commission & Reports Analysis Hong Kong Monetary Centre EU Member State Authorities • Germany Authority (“HKMA”) (“FINTRAC”) • Netherlands • France • Italy Australian Transaction Reports and Analysis Centre (“AUSTRAC”) 7 Types of U.S. -
List of PRA-Regulated Banks
LIST OF BANKS AS COMPILED BY THE BANK OF ENGLAND AS AT 2nd December 2019 (Amendments to the List of Banks since 31st October 2019 can be found below) Banks incorporated in the United Kingdom ABC International Bank Plc DB UK Bank Limited Access Bank UK Limited, The ADIB (UK) Ltd EFG Private Bank Limited Ahli United Bank (UK) PLC Europe Arab Bank plc AIB Group (UK) Plc Al Rayan Bank PLC FBN Bank (UK) Ltd Aldermore Bank Plc FCE Bank Plc Alliance Trust Savings Limited FCMB Bank (UK) Limited Allica Bank Ltd Alpha Bank London Limited Gatehouse Bank Plc Arbuthnot Latham & Co Limited Ghana International Bank Plc Atom Bank PLC Goldman Sachs International Bank Axis Bank UK Limited Guaranty Trust Bank (UK) Limited Gulf International Bank (UK) Limited Bank and Clients PLC Bank Leumi (UK) plc Habib Bank Zurich Plc Bank Mandiri (Europe) Limited Hampden & Co Plc Bank Of Baroda (UK) Limited Hampshire Trust Bank Plc Bank of Beirut (UK) Ltd Handelsbanken PLC Bank of Ceylon (UK) Ltd Havin Bank Ltd Bank of China (UK) Ltd HBL Bank UK Limited Bank of Ireland (UK) Plc HSBC Bank Plc Bank of London and The Middle East plc HSBC Private Bank (UK) Limited Bank of New York Mellon (International) Limited, The HSBC Trust Company (UK) Ltd Bank of Scotland plc HSBC UK Bank Plc Bank of the Philippine Islands (Europe) PLC Bank Saderat Plc ICBC (London) plc Bank Sepah International Plc ICBC Standard Bank Plc Barclays Bank Plc ICICI Bank UK Plc Barclays Bank UK PLC Investec Bank PLC BFC Bank Limited Itau BBA International PLC Bira Bank Limited BMCE Bank International plc J.P. -
Anti-Money Laundering Trends and Challenges
EUROPE, MIDDLE EAST AND AFRICA INVESTIGATIONS REVIEW 2021 © Law Business Research 2021 EUROPE, MIDDLE EAST AND AFRICA INVESTIGATIONS REVIEW 2021 Reproduced with permission from Law Business Research Ltd This article was first published in June 2021 For further information please contact [email protected] © Law Business Research 2021 Published in the United Kingdom by Global Investigations Review Law Business Research Ltd Meridian House, 34-35 Farringdon Street, London, EC4A 4HL © 2021 Law Business Research Ltd www.globalinvestigationsreview.com To subscribe please contact [email protected] No photocopying: copyright licences do not apply. The information provided in this publication is general and may not apply in a specific situation. Legal advice should always be sought before taking any legal action based on the information provided. This information is not intended to create, nor does receipt of it constitute, a lawyer–client relationship. The publishers and authors accept no responsibility for any acts or omissions contained herein. Although the information provided is accurate as of May 2021, be advised that this is a developing area. Enquiries concerning reproduction should be sent to Law Business Research, at the address above. Enquiries concerning editorial content should be directed to the Publisher – [email protected] © 2021 Law Business Research Limited ISBN: 978-1-83862-594-8 Printed and distributed by Encompass Print Solutions Tel: 0844 2480 112 © Law Business Research -
Day One: March 24Th
Day One: March 24th 09:00 FinTech Network Welcome: Hannah Kitchen, Conference Organiser 09:15 Chairperson’s Introduction & Welcome: Graham Cressey, Open Data Stream Lead, FinTech Innovation Lab, Accenture 09:30 Open Banking and Digital Ecosystems: BBVA's key learnings. • Explore digital ecosystems as one of the key points for the connection and relationship between consumers and service providers today • Discuss if the need for financial services is efficiently met and how to improve current inefficiencies • Analyse how Open banking is an enabler of these relationships and the new opportunities it brings for innovation and growth Ana Climente, Head of Open Banking Spain, BBVA 10:00 Leveraging the Core Values of your Business Model in an Open Banking Environment • Gain insight on the methods Handelsbanken is employing to integrate an open value chain into their existing unique business model • Learn why Handelbanken’s branches are a key component of creating an open value chain and how they ensure synergy between branches and corporate strategies • Hear Handlesbanken’s case study on how collaboration is a key element for creating a business model fit for the 2020 open banking landscape Malin Lignell, Digitalisation and Innovation, Handelsbanken 10:30 Panel Discussion: Driving Open Banking Forward – Regulatory Guidance • Review recent regulatory activity relating to open banking and hear an overview of expected future developments to ensure your compliance strategies align • Discuss collaboration between banks and regulators to understand -
Symbiosis: Your Bank Has Your Trust
Your bank has your trust. Can fintech make you love it? Sponsored by SYMBIOSIS: YOUR BANK HAS YOUR TRUST. CAN FINTECH MAKE YOU LOVE IT? CONTENTS 2 Executive summary 3 About this report 5 Introduction: Symbiosis 6 Section one – customers 10 Case study: With power comes responsibility 11 Section two – compliance 15 Case study: Fit for purpose? 15 Case study: Who do you trust? 16 Section three – cost of capital 19 Case study: nCino: the need to streamline 20 Section four – symbiosis 25 Case study: The Swedish design ethic 26 Conclusion 27 Appendix 1 © The Economist Intelligence Unit Limited 2017 SYMBIOSIS: YOUR BANK HAS YOUR TRUST. CAN FINTECH MAKE YOU LOVE IT? EXECUTIVE SUMMARY What will become of the nuns, the homeless and the Bank of England governor, Mark Carney, as retail banking goes fully digital? Since the 1970s Banco Popular of Spain has relied on unique contracts with the Catholic Church for nuns to supply back- office support. Digitalisation, email and apps may render their non-spiritual roles obsolete. And in the Nordic region, cash is fast becoming a rarity. Banks no longer worry about germ-laden banknotes and robbers equipped with guns. But how do you give money to the homeless if physical money no longer exists? Luckily, Denmark’s MobilePay has an app for that. What if fiat money disappears entirely? Will Mr Carney be made redundant if crypto-currencies become the norm? No, but government-sanctioned e-currencies are a real possibility. The fourth global retail banking report from The Economist Intelligence Unit finds an industry in flux but more certain about its future. -
Informational Materials
Received by NSD/FARA Registration Unit 9/24/2020 4:43:51 PM View this email in your browser CMP WRKlYE'NlN BiRLESTiRKi Gi3C(i OO The story, part of a broader look at the role of banks in money laundering known as the FinCEN Files, focused on Reza Zarrab. a Turkish-lranian money launderer who worked with Turkey’s state-owned Halkbank to move billions of dollars through an underground network of shell companies and gold smugglers to help Iran evade international sanctions. Zarrab was arrested in Miami in 2016 as he arrived for a Florida vacation with his Turkish pop-star wife Ebru Gunde§, and their young daughter. He pleaded guilty to fraud and money laundering, and became a government witness in return for leniency. He is expected to testify next year in a separate trial of Halkbank. A former insider in the Zarrab organization, who smuggled suitcases of gold and cash across international borders, told OCCRP and Courthouse News that the Turkish government approved Zarrab’s operations. He also implicated Berat Albayrak, Turkey’s Minister of Treasury and Finance and son-in-law of President Recep Tayyip Erdogan, in Zarrab’s conspiracy. The Istanbul Anatolian Courthouse on Wednesday placed a gag order, preventing some Turkish media from reporting on the Zarrab stories published by OCCRP and Courthouse News. However, people in Turkey are still able to safely read Internet Archive copies of OCCRP’s FinCEN Files’ investigations about the government’s n /er ent and how Zarrab smuggled Russia’s money. Received by NSD/FARA Registration Unit 9/24/2020 4:43:51 PM Received by NSD/FARA Registration Unit 9/24/2020 4:43:51 PM Turkey’s main opposition party, The Republican People’s Party (CHP), submitted a parliamentary inquiry to Vice President Fuat Oktay consisting of six main questions from the investigation.