1782 article part 2
This 28th post in the “Divorce & Hidden Money” series mentions the petition Helga Glock filed in the U.S. to collect financial records for her Austrian alimony & asset distribution case against gun mogul Gaston Glock.

Part 1 of the instant post notes that if your divorce is outside of the U.S. you may search for assets your spouse hid in the U.S. by filing a 28 U.S.C. § 1782 petition (hereinafter “the petition”).  You can employ the petition to gather financial evidence possessed by a wide variety of witnesses who reside in the U.S.  In some cases these witnesses can range from a financial institution to a paramour.

Helga Glock employed the petition to search for assets gunmaker Gaston Glock allegedly hid from her during the couple’s divorce in Austria.  Helga Glock filed the petition in a U.S. federal court in Atlanta, Georgia on March 18, 2013.  The petition alleged Gaston Glock started concealing his U.S. &/or other assets.  The petition argued that Helga Glock therefore needed to collect financial records in the U.S. for her alimony & asset distribution case in Austria.

As the pages available here partly demonstrate, Helga Glock used the petition to request financial records from Glock, Inc. & two other businesses apparently related to Gaston Glock. Helga Glock succeeded with the petition/ultimately gathered various financial records because of it.  A federal court of appeals has also ruled that Helga Glock could now use these records in her RICO lawsuit in the U.S. against Gaston Glock.

Image: iQoncept/Shutterstock.com

Copyright 2015 Fred L. Abrams

Divorce Image 1782 Petition

This 27th post in the “Divorce & Hidden Money” series looks at a way to search for assets in the U.S. when your underlying divorce case is brought outside of the U.S.

If your underlying divorce case is commenced in a foreign country, how do you search for secret bank accounts or other kinds of assets your spouse hid in the U.S?  You may be able to search for assets your spouse hid in the U.S. by filing a petition in U.S. federal court pursuant to 28 U.S.C. § 1782 (hereinafter “the petition”).

By filing the petition you might elicit evidence from bank & other witnesses who reside in the U.S. You could use the petition to gather evidence about any of your spouse’s U.S.-based: bank accounts; stocks & bonds; business entities; real estate; intellectual property licenses; etc. To file a legally sufficient petition, you must satisfy three statutory requirements:

  1. the bank or other witness the subject of your petition must reside or be found in the district where the court sits;
  2. the evidence possessed by the witness will be used in a foreign case;
  3. you must be an interested party.

The 28 U.S.C. § 1782 petition¹ below was granted via an April 12, 2012 order from the U.S. District Court in Delaware.  This petition sought evidence from a witness in Delaware regarding alimony in a Turkish family court case:

(Click On The Translated Copy Of The Petition)

¹The § 1782 petition has been partly sanitized for privacy reasons.

First Image: Bildagentur Zoonar GmbH/Shutterstock.com

Copyright 2015 Fred L. Abrams

realestatearticle

Searching For Assets Laundered Through Real Estate” shows how one divorcing husband washed & hid assets during his divorce.  The following is a sanitized case study from the Egmont Group of Financial Intelligence Units.  It is about “O” & “R” who may have similarly employed real estate in a scheme to hide assets.  O & R might have been narcotraffickers washing their illicit proceeds by purchasing real estate in Europe:

 

08011

Photo: Gemenacom/Shutterstock.com

Case Ref. 08011: courtesy of the Egmont Group of Financial Intelligence Units

Copyright 2015 Fred L. Abrams

Corruption Proceeds Illustration

Transparency International leads the fight against public corruption which includes bribery & theft by government officials.  It basically says that corruption proceeds are transferred offshore & are one of the sources of illicit financial flows.  How do financial investigators across the globe search for these illicit assets?  One way they search is by looking for money laundering red flags.  The following discusses red flags in the case of Vladimir Kuznetsov, a former Russian diplomat at the United Nations.  These red flags were structuring bank deposits; forming an offshore corporation; & using an offshore bank account to hide assets/hinder an asset search:

Mr. Vladimir Kuznetsov ‘s October 19, 2007 criminal judgment mentions his $73,671 fine and prison sentence of 51 months for violating 18 U.S.C. § 1956 (h), conspiracy to commit money laundering.  According to a press release, Mr. Kuznetsov had conspired with Mr. Alexander Yakovlev– a United Nations’ procurement officer who was taking bribes.  The press release explains that Mr. Kuznetsov had laundered money while he was the highest ranking Russian diplomat at the United Nations.  According to his superseding indictment, Mr. Kuznetsov had been a member of the Advisory Committee on Administrative and Budgetary Questions, which advises the United Nations’ General Assembly.

As part of Mr. Kuznetsov’s laundering scheme, he had received $32,000 from Antigua via two New York financial accounts.  Most significant however, was his use of an offshore bank account at Antigua Overseas Bank Ltd. as the repository of hundreds of thousands of dollars in bribery proceeds.  Mr. Kuznetsov had opened this account in the name of his offshore company Nikal Ltd.,  which he had formed in about 2000.  Although Mr. Kuznetsov was not finally convicted of it, his indictment had also alleged that he had structured bank deposits in violation of  31 U.S.C. § 5324.

Structuring bank deposits, (a.k.a “smurfing”), indicates an attempt to avoid bank reporting requirements and can be a red flag of money laundering.  Other red flags of money laundering in Mr. Kuznetsov’s case included his use of the offshore corporation Nikal Ltd. to open his Antigua Overseas Bank Ltd. account.  The transfer of the $32,000 from Antigua to Mr. Kuznetsov in New York was also a red flag, especially because Antigua is a tax haven/high-risk location vulnerable to money laundering.

Illustration: marcovarro/Shutterstock.com

Copyright 2008-2018 Fred L. Abrams

Real Estate Leskovskiy
A divorcing spouse can hide marital assets by laundering them in a scheme to purchase real estate.

This 26th post in the “Divorce & Hidden Money” series describes one way assets may be laundered through the purchase of real estate.  It supplies the hypothetical situation of “Mark,” a high net worth businessman in the U.S. who hid assets during his divorce.

To hide assets from both his divorcing wife & the IRS, Mark secretly formed a shell company which he used to open an offshore bank account.  Mark hid his beneficial ownership of the shell company & bank account by hiring nominees (i.e.  intermediaries).  Mark employed the nominees as directors of his shell company & they acted as nominee bank signatories on Mark’s offshore bank account.

After Mark opened the offshore bank account, Mark relied on illicit cash couriers, (a.k.a “money mules”), to smuggle the undeclared revenue/cash Mark had accumulated from his business in the U.S.  After the illicit cash couriers smuggled Mark’s cash offshore, Mark deposited it into the offshore bank account he opened in the name of his shell company.  Through his lawyer, Mark then used the cash in this bank account to purchase real estate located in an offshore tax haven.  Mark’s lawyer titled Mark’s newly acquired real estate in the name of Mark’s shell company; and Mark successfully hid his beneficial ownership of the real estate from his wife & the IRS.

A search for assets hidden by a high net worth spouse like Mark, should try to determine whether real estate could have been used as a concealment tool.  When real estate transactions are used to launder or otherwise hide assets, red flags involving lawyers are usually present.  According to pp. 12-13 of a 2013 money laundering report by the Eastern and Southern African Anti-Money Laundering Group¹ these red flags can include the use of: large amounts of cash; intermediaries; money laundering havens; complex structures; business entities and trusts:

“a) Use of large amounts of cash to purchase property involving legal practitioners who do not report STRs [Suspicious Transaction Reports] giving the conclusion that they are either complacent in the money laundering or give a blind eye to circumstances relating to the payment where they could have asked more questions;

b) Distorting information on ownership by using intermediaries and false particulars during purchase of the property through a legal practitioner;

c) Legal practitioners facilitating quick money laundering havens through aborted property transactions where the initial deposited amount has to be paid back or transferred to another account from the legitimate client/trust account of the
lawyer;

d) Instances where legal practitioners have assisted with setting up complex structures to purchase real estate; and

e) Avoiding exposure of the beneficial owner by using the legal practitioner to purchase the property through a company or a trust.”

¹Typologies Report On Money Laundering Through The Real Estate Sector In The ESAAMLG Region Courtesy of: The Eastern and Southern African Anti-Money Laundering Group.

Image: Vycheslav Leskovskiy/Shutterstock.com

Copyright 2015 Fred L. Abrams

Talking Points Photo

The following is a list of Asset Search Blog posts which discuss data brokers; private investigators; bankers; suspected tax fraudsters; etc.  As these posts show, asset searches & asset recoveries sometimes raise privacy &/or criminal law issues.

A)  Data Brokers, Data Mining & Your Privacy

  1. Data Brokers Searching For Your Assets, Bank Accounts & Other Personal Information?
  2. Government Data Mining & An Asset Search

B) Possible Illegal Asset Searches

  1. Private Investigators & Their Clients Facing Criminal Prosecution Over Illegal Asset Searches
  2. Private Investigators: A Surreptitious Search For Money Hidden In Divorce & Other Cases
  3. Private Investigators: 5 Things To Be Aware Of When Hiring A PI For A Bank Account Search
  4. Searching For Assets By Using Insiders At A Bank
  5. Searching Law Enforcement Data Bases For Your Personal Information?

C)  Criminal Prosecution For Hiding Assets

  1. An Asset Search, Tax Fraud & Divorce
  2. Prosecuting Offshore Bankers Who Allegedly Help Tax Evaders Hide Assets From The IRS
  3. Red Flags & The IRS Search For Attorney Memmott’s Assets
  4. Concealing Assets In More Than $150 Trusts?

Image: zsirosistvan/Shutterstock.com

Copyright 2015 Fred L. Abrams

New York County Lawyers’ Association, 14 Vesey Street, N.Y. N.Y. 10036, October 13, 2015, 5:30 PM to 9:00 PM.

This course “Whistleblowers, Secret Swiss Bank Accounts & Recovering Hidden Assets” will cover: detecting hidden assets including secret Swiss bank accounts; the IRS & SEC whistleblower programs; and other asset recovery issues.  Fred Abrams will be the program’s chair and Charles Bott QC, Head of Carmelite Chambers will be traveling to New York to participate in it.  Jack Blum, Esq., (featured on CBS’ 60 Minutes on February 8, 2015), will speak during the course about the largest leak in Swiss banking history and whistleblowing.  Jordan Thomas, Esq. who worked on some of the SEC’s biggest cases before becoming a partner at Labaton Sucharow LLP, will also speak at the course.  Attendee registration is available here through the New York County Lawyers’ Association or by calling the Association at (212) 267-6646.

Carmelite Chambers, 9 Carmelite Street, London EC4YODR, International Fraud & Asset Recovery ConferenceJune 23, 2014, 11:40 AM to 1:00 PM. 

Fred Abrams and distinguished lawyers Jack Blum and Jordan A. Thomas, will present “The Ins & Outs Of Recovering Assets Via Whistleblowers & Other Tipsters”.  This program first analyzes how vast sums of money can be hidden in cases as diverse as tax and securities fraud and divorce.

It then describes ways whistleblowers or other tipsters may help sniff out these monies and discusses: the problems whistleblowers face in the real world, the advantages and disadvantages of the different whistleblower programs, and the difficulty lawyers face in dealing with whistleblowers either as clients or as tipsters.

The program also focuses on the ethical concerns gatekeepers like attorneys, accountants, officers and directors have, in reporting illegal behavior in both the civil and criminal contexts. Registration is available through Carmelite Chambers.

New York County Lawyers’ Association, 14 Vesey Street, N.Y. N.Y. 10036, April 18, 2013, 6:00PM-9:00PM.

Swiss Banks, Smuggling & Other Asset Recovery Issues

New York City Bar Association, 42 West 44th Street New York, NY 10036, September 27, 2012, 6:00PM– 9:00 PM.

Recovering Assets Via Whistleblowers & Other Tipsters

New York County Lawyers’ Association, 14 Vesey Street, N.Y. N.Y., June 21, 2011, 6:00-9:00 PM.

Following The Money Trails From Marital Assets To Nazi-Looted Art

The Suffolk County Bar Association, 560 Wheeler Road, Hauppauge, N.Y., May 24, 2011, 6:00-9:00 PM.

Following The Money Trails From Marital Assets To Nazi-Looted Art

New York County Lawyers’ Association, 14 Vesey Street, N.Y. N.Y., May 25, 2010, 6:00-9:00 PM.

Ethically Accessing Financial Intelligence From Warsaw To Wilmington, In Criminal & Civil Cases“.  At this program, Fred Abrams will share his sanitized financial fraud case files and some others. He will especially focus on suspected asset concealment schemes with cross-border elements, which can sometimes be facilitated by everyone ranging from divorcing spouses to politically exposed persons and Ponzi-schemers.

The program will be presented with an eye towards giving attendees an understanding of how assets may be recovered when they have been laundered or otherwise hidden across the globe by their beneficial owners. To be discussed, are the pending financial fraud investigations of Ex-Turks & Caicos premier Michael Misick, Minneapolis money manager Trevor Cook and investigations by prosecutors in Poland.  Other covered topics include:

  • Conducting An Ethical & Legally Sufficient Asset Search
  • Bank Customer Identification at Swiss and other banks
  • Eliciting Evidence From Foreign Bank Witnesses
  • Forced Collection Proceedings In Multiple Jurisdictions
  • Financial Fraud Trends In 2010

8th Annual OffshoreAlert Financial Due Diligence Conference, which will take place at The Ritz-Carlton, South Beach in Florida:

  • America’s Home-Bred Offshore Financial Centers – Delaware, Nevada & Wyoming“, May 3, 2010 at 1:30 PM-2:30 PM.
  • Investigation & Intelligence: How to Gather Financial Intelligence and Evidence from OFCs“, May 4, 2010 at 11:00 PM-12:15.

The Suffolk County Bar Association, 560 Wheeler Road, Hauppauge, N.Y., May 6, 2009, 12:00-3:00 PM.

Show Me The Money: Hidden Assets, Madoff Securities and Other Famous Frauds“, Zhenli Ye Gon hid over $207 million cash in various compartments, suitcases, closets and false walls in his Mexico City home. Walter Anderson concealed $365 million in income by using bearer share stock certificates and shell companies. Former UBS banker Stanley Birkenfeld hid assets by smuggling diamonds in a tube of toothpaste while an airline passenger at Swiss-U.S. border crossings. Now governmental authorities and others are following the money trail of Mr. Bernard Madoff’s $50 billion Ponzi scheme hoping to interdict any illicit assets he may have concealed.

This program discusses some of the red flags of asset concealment, especially offshore. Through its coursebook and PowerPoint presentation, it explains how criminal proceeds or probate, marital, bankruptcy estate and other assets may be hidden “under the radar” through multiple jurisdictions, foreign bank accounts and agents or nominees. It also describes how some may be able to use discovery / forced collection proceedings to recover such assets, which have been concealed during a financial fraud.

Among other things, “Show Me the Money: Hidden Assets, Madoff Securities and Other Famous Frauds” discusses the following issues relevant to the matrimonial, bankruptcy, commercial or other litigator who is trying to find assets hidden in multiple jurisdictions:

  • Recognizing The “Red Flags” Of Asset Concealment
  • Creditor’s Rights / Legal Remedies: Forced Collection Proceedings Even In A Major Money Laundering Country Such As Switzerland
  • Discovery Through Letters Rogatory / Legal Assistance Requests
  • Bank Secrecy Laws
  • Domestic Privacy Law Issues

New York County Lawyers’ Association, 14 Vesey Street, N.Y. N.Y., March 30, 2009, 6:00-9:00 PM.

Show Me The Money: Hidden Assets, Madoff Securities and Other Famous Frauds“, as is described by the attached press release.

Brooklyn Bar Association, 123 Remsen Street, Brooklyn, New York 11201, February 3, 2009, 6:00-9:00 PM.

“Finding Hidden Assets During Divorce & Child Support Cases”, includes a discussion of the  following issues:

  • Asset Concealment Methods / The Red Flags
  • Asset Search Tips For Divorce & Child Support Cases
  • A Low-Cost Asset Search
  • A Divorce & Trade Based Money Laundering
  • Computer Forensics & An Asset Search
  • Suing When Marital Assets Are Hidden In Divorce / Fraudulent Conveyances
  • Divorce, Rico & An Asset Search
  • Using Letters Rogatory During An Asset Search
  • An Asset Search & Federal Privacy Laws

Queens County Bar Association, 90-35 148 Street, Jamaica, New York 11435, November 13, 2008, 6:00-9:00 PM.

Finding Hidden Assets During Divorce & Child Support Cases” discusses various asset concealment methods relevant to the matrimonial / family lawyer.

New York County Lawyers’ Association, 14 Vesey Street, N.Y. N.Y., June 19, 2008, 6:00-9:00 PM.

Finding Hidden Assets During Divorce & Child Support Cases” provides the matrimonial / family lawyer with the countermeasures which can be effective against even those most determined to hide assets. Through its PowerPoint program and coursebook, it explains how offshore bank accounts, shell companies, multiple jurisdictions and other methods may be used to hide millions during equitable distribution and / or child support proceedings. Among others, the following issues are covered:

  • Asset Concealment Methods / The Red Flags
  • Case Studies: Money Laundering, Bearer Shares, Nominees & Other Financial Fraud Methods
  • Motions & Pleadings
  • Asset Search Strategies

The Association of the Bar of the City of New York, 42 West 44th Street New York, NY 10036, April  24, 2008 @ 6:00-8:30 PM.

Finding Hidden Assets: What Every Divorce, Bankruptcy & Commercial Litigator Needs To Know“–  Through case studies of divorce, bankruptcy and debt collection proceedings, this program examines how assets are sometimes hidden in the U.S. and in offshore tax havens.  Fully discussed are the use of pretrial discovery, pleadings and other courtroom strategies, against even those most determined to hide millions in assets.

American Academy Of Matrimonial Lawyers, Massachusetts’ State ChapterWestin Hotel, 70 Third Avenue, Waltham Massachusetts, February 13, 2008 @7:30 PM.

Money Laundering, Marital Assets & Divorce“–  This presentation analyzes how marital assets may be hidden domestically and abroad during a divorce. Through handouts and the case study of a divorcing spouse who laundered money in Switzerland, the following are discussed:

  • Money Laundering
  • Domestic Shell Companies
  • Nominees
  • Offshore Bank Accounts
  • High-Risk Geographical Locations, Both Domestic & Abroad
  • Asset Search Indicia

Letters Rogatory / Requests For Legal Assistance pursuant to Massachusetts General Law Chapter 223A  §10; Fed. R. Civ. P. 28 (b) & 4 (f) (2) (B).

The Suffolk County Bar Association, 560 Wheeler Road, Hauppauge, N.Y., January 29, 2008, 12:00-2:30 PM.

Finding Hidden Assets Both Domestic & Abroad“–  Learn what countermeasures are often effective against those most determined to hide assets in cases of divorce, debt collection & bankruptcy.  Among many others, the topics discussed are:

  • Asset Search Indicia
  • Asset  Protection, A Case Study
  • Detecting Hidden Assets & Laundering
  • Badges Of Fraud / Fraudulent Conveyances
  • Letters Rogatory / Requests For Legal Assistance
  • Tips For Working With Private Investigators
  • Legal Strategies / Suing Non-Parties Hiding Assets
  • Criminal Issues

New York County Lawyers’ Association, 14 Vesey Street, N.Y. N.Y., November 5, 2007, 6:00-9:00 PM.

Discovery Of Offshore Assets In Your Client’s Court Case“–How to proceed in court when assets are hidden offshore in a divorce / child support case, bankruptcy matter, white-collar crime, etc. Areas covered include: detecting money laundering circuits and hidden assets; making pre-trial motions; U.S. criminal tax and foreign laws; and reporting tax fraud.

Nassau County Bar Association, 15th & West Streets, Mineola, N.Y., Nov. 1, 2007, 12:00-2:00 PM.

Hiding Assets: An Insider’s View“–The case study of a scheme in the U.S. to hide assets in a Cayman bank which ended in a homicide.  The “know your customer”/customer identification rules of banks in the Cayman Islands, Switzerland, the United Kingdom, and the United States are all examined.  “Hiding Assets” also considers how the practices of offshore banks and financial institutions can effect U.S. anti-money laundering efforts pursuant to the U.S. Patriot Act and / or the Bank Secrecy Act.

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Spotting the red flags/the money laundering indicators is one way to search for hidden assets.  The red flags may help you sniff out money or other assets concealed in matters ranging from a high net worth divorce to a securities fraud.  Financial Intelligence Units part of the Egmont Group employ red flags to search for money hidden across the globe by terrorist financiers; narco-traffickers; kleptocrats & others.  As more fully set forth here, red flags include:¹

  1. Large-scale cash transactions.
  2. Atypical or uneconomical fund transfer to or from foreign jurisdiction.
  3. Unusual business activity or transaction.
  4. Large and/or rapid movements of funds.
  5. Unrealistic wealth compared to client profile.
  6. Defensive stance to questioning.

The case study below, (sanitized for privacy reasons), is also from the Egmont Group.²  It is about a homicide; public corruption; fraud; & the laundering of $9.5 million dollars in “Economy F.”  The money was washed through a corporate bank account; lawyers’ trust accounts; & bank accounts belonging to money mules.  The Financial Intelligence Unit (“FIU”) involved in the case analyzed Suspicious Transaction Reports (“STRs”); issued orders freezing monies; etc.

ECONOMY F: A CASE STUDY

     The Economy F police received a criminal complaint from a government department involving fraud and theft. The facts related to the predicate offenses indicated that staff working in the government department colluded with an external crime syndicate to assist in obtaining copies of legitimate vendor payments, which were subsequently duplicated and processed to the benefit of various accounts indirectly linked to the syndicate. The initial loss exposure amounted to approximately US$573,000. Police requested Economy F’s FIU’s assistance in blocking the accounts that received the proceeds of crime, with an additional request to identify other possible players.
     The FIU interacted with the relevant accountable institutions and subsequently issued several postponement orders, resulting in US$317,000 of the initial proceeds being secured. This enabled the prosecuting authority to obtain a preservation order to secure the proceeds. These interventions were brought immediately after the police provided proof of the nexus between the criminal offense and the funds that were still available in the identified bank accounts.  Upon analysis of the STRs and bank records received of the accounts, the FIU identified various other payments originating from different government departments, which were unknown to the police at that stage, amounting to US$9.5 million.
Continue Reading An Asset Search Seeking Laundered Money Hidden Across The Globe

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An asset search may reveal that your spouse is hiding assets from you during your divorce.  You might then be able to sue your spouse & possibly others for fraudulently concealing assets.  As this 25th post in the “Divorce & Hidden Money” series shows, you may be able to sue on the ground that assets were  fraudulently conveyed away from you:

Before leaving New York, the divorcing husband in Skiff-Murray v. Murray¹ fraudulently conveyed his business and former marital residence to his newly created Nevada corporation.  Violating a restraining order, the husband next conveyed the residence from his Nevada corporation to his aunt and uncle.  The aunt and uncle then mortgaged the residence to a third party.

According to the Court in Skiff-Murray, the divorcing husband had “…made it impossible for plaintiff [the wife] to enforce her judgments for child support arrears or obtain the maintenance, distribution of marital property and counsel fees awarded in the judgment of divorce.”  After the divorce was over, the now ex-wife filed a lawsuit against the aunt; uncle & others. The lawsuit alleged the residence had been fraudulently transferred.  It asked the Court to set the transfer aside under N.Y. Debt. Cred. Law. §§ 270 – 281, which is the codified version of the Uniform Fraudulent Conveyance Act. Continue Reading Divorce & Hidden Money: Suing Your Spouse For Fraudulently Conveying Assets

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If you are a divorcing spouse, judgment creditor or anyone else who believes they may need to do a bank search to locate hidden assets parked offshore, read this post to see how individuals sometimes hide their assets.  It covers the legal remedies that may be available to you in your asset search for offshore bank accounts.  This post was first published in 2013 and was called “Hidden Assets Offshore & A Bank Search To Find Them.”

Beneficial owners around the world are able to secretly transfer assets across international borders into offshore bank accounts.  The beneficial owners sometimes do this by money laundering through multiple jurisdictions; bulk-cash smuggling; back-to-back loans; shell companies; nominee incorporation services & gatekeepers like lawyers.  Legal remedies are however, usually available for finding hidden assets transferred offshore.  These remedies may even include seeking a court order directing a Swiss or other offshore bank to perform a bank search and disclose bank customer information.

MONEY LAUNDERING

The link chart below describes how one divorcing husband concealed both undeclared revenue and marital assets via multiple jurisdictions.¹  The husband laundered millions from the U.S., through a Swiss bank and a German one.  Prior to the equitable distribution hearing in his divorce, the husband alleged he had a liability of $29 million owed to a prime bank in Germany because of an arm’s length business loan.  As this link chart reveals, the supposed arm’s length loan was back-to-back , (i.e. a fully collateralized loan in which the borrower and the lender are one and the same):

(Click On The Link Chart To Enlarge)

Continue Reading An Asset Search To Find Secret Offshore Bank Accounts