December 2009

My article "Money Laundering By Minneapolis Money Managers?" reports that a lawsuit against Patrick Kiley, Trevor Cook and other money managers, had raised the question of whether Associated Bank breached a duty to prevent suspected money laundering.  As I mentioned in that article, Associated Bank could have conceivably failed to follow a written Customer Identification Program under 31 CFR 103.121 ¶ (b) (2) (i).

After I wrote "Money Laundering By Minneapolis Money Managers?", two lawsuits were filed against Associated Bank raising these same issues.  The gravamen of said lawsuits, was that Associated Bank had supposedly been negligent in allowing suspected securities fraudsters to open and maintain a nominee bank account in the name of Crown Forex LLC.  Crown Forex LLC was reportedly a sham business entity and its Associated Bank account was possibly used as a laundering link to wash some of the proceeds of a suspected securities fraud.

The first of these lawsuits was briefly filed in Minneapolis federal court via a November 4, 2009, third amended complaint.  That Minneapolis lawsuit against Associated Bank, was soon voluntarily dismissed pursuant to a December 9, 2009 filing and the Court’s December 10, 2009, Order.  The second lawsuit against Associated Bank, (Herman Grad vs. Associated Bank NA, Brown County Case #2009-CV-002949), is however, still pending in Wisconsin. Continue Reading Associated Bank Sued For Supposedly Ignoring Red Flags

Today"s "Asset Search News Roundup" highlights hiding / smuggling cash at U.S.-Mexican border crossings and describes how fraudsters might select bank accounts to facilitate their financial frauds:

By claiming that proceeds of a judicial bribery scheme had been laundered from Italy into nineteen U.S. bank accounts, prosecutors sought asset forfeiture as described at "Using Multiple Jurisdictions To Launder Money".  That forfeiture case was mostly based on U.S. anti-money laundering laws which included 18 U.S.C. §1956 (Money Laundering) and 18 U.S.C. §1957 (Money Laundering of property from specified unlawful activity).

In two of the cases mentioned at "Following The Money Trail From Poland To Delaware", prosecutors from Warsaw and Koszalin had asserted that they too suspected money laundering.  In those cases the prosecutors sought the issuance of letters rogatory in Delaware by claiming that laundering could have occurred in violation off Article 299 of Poland’s penal law.

Like the foregoing prosecutors, litigants in the private sector may also allege that an adversary has fraudulently concealed assets in violation of U.S. and / or foreign money laundering laws.  To cite just one example, the RICO plaintiff more fully described at "Divorce, RICO & An Asset Search", claimed that her ex-husband had laundered money in violation of 18 U.S.C. §1956.Continue Reading Alleging Money Laundering In Private Sector Lawsuits

Holocaust-era assets and Mutual Legal Assistance Treaties are the subjects of this “Asset Search News Roundup”:

    1. My article “During A War Everybody Loots A Little Bit“, discusses Nazi-looted art.  A December 1, 2009, press release also raises this issue.  The December press release explains that U.S. authorities recently recovered a painting in a

Warsaw Prosecutors Eye Possible Money Laundering At 50 Platowcowa Street “, mentioned that a tip letter led prosecutors from Poland to seek a letter rogatory via the U.S. Attorney in Delaware on October 14, 2009.  The Warsaw prosecutors used this particular letter rogatory to try to elicit evidence about Prime Invest L.L.C. in Delaware

Attorney Arienne Irving’s December 4, 2009 Judgment of Acquittal pursuant to Fed. R. Crim. P. 29, raises the general issue of lawyers or clients who might use illegal eavesdropping equipment to "research" an adversary.  I previously wrote about violating privacy laws via eavesdropping at "Attorney Christensen’s Wiretap Conviction".  That article explained how former

Thehumanitarian non-profit Slovenian Red Cross operates in 12 regions with 916 local Red Cross organizations. Its former Secretary-General Mirko Jelenic however, is suspected of involvement in a criminal "breach of trust", as mentioned by Slovenian law. He might have used Slovenian Red Cross monies in a phony real estate sale agreed to in the year

This "Asset Search News Roundup" is about "politically exposed persons" who are accused of hiding cash during alleged bribe-taking.  One such person is Governor José Roberto Arruda of Brasilia.  "Brazil in shock as secret video catches ‘corrupt’ governor red-handed", reports that Brazilian Federal Police in "Operation Pandora" possess surveillance video