Narco subs, drug cartels and Canada – new threats on the horizon to international security

By Christine Duhaime | October 26th, 2020

Narco subs

In the last few months, an increasing number of so-called narco subs, also called drug subs, have been intercepted in international waters by law enforcement (“LE“). A narco sub is usually a self-propelled semi-submersible (“SPSS“) used by drug traffickers to transport large quantities of illegal drugs for cartels to an international market.

SPSS are stealthy and often go unnoticed and have grown in popularity so much that US officials now estimate that more than 30% of cocaine trafficked into the US enters from SPSSs. Many SPSSs are self-driving.

Security concerns

Of concern for international security is the risk that such vessels may be used by terrorists or agents engaged in state-sponsored terrorism to transport weapons of mass destruction undetected, or to attack the US or Canadian coast along the Pacific Ocean. Terrorist organizations and drug cartels already have existing trade and money laundering relationships.

More sophisticated narco subs

In August 2020, a 100 foot narco sub was found by LE in Colombia in a river in the jungle, which if operational, could carry about US$200 million in cocaine. A few days after that discovery, Colombian LE seized a SPSS carrying US$18.2 million of cocaine being transported for Mexico’s leading cartel, the Jalisco New Generation Cartel (“CJNG“). Colombian LE believe the SPSS is owned by the CJNG.

On a small scale, a personal submersible was used by a Canadian in a kind of a James Bond move to smuggle cash and 265 pounds of illegal drugs along the bottom of the Detroit River from Canada to the US in June, 2020. The vessel was equipped with two cameras, wifi and operated at more than 13 miles per hour. It is the first known case of a personal fully submersible vessel being used underwater to smuggle drugs between Canada and the US.

Both pale in comparison, however, to the November 2019, detection and seizure of a 66 foot fully submersible submarine captured off Spain transporting US$100 million in cocaine from Colombia that has transited through a third country, likely Brazil and crossed the Atlantic Ocean.

Narco sub seized off Spain (Source: Guardia Civil)

Connections to Canada

The idea of Colombian and Mexican drug cartels using real submarines to transport illegal drugs originated around the early 1990s and has some connections to Canada.

Here’s how.

3 mobsters try to buy a Russian narco sub

Three people – a Russian mobster named Ludwig Fainberg, aka Tarzan, who immigrated to Miami, together with a Cuban drug trafficker who was then a fugitive named Nelson Tony Yester, and a supplier of luxury vehicles, “go fast” drug boats and equipment to drug cartels in Miami named Juan Almeida, traveled to Russia to buy a submarine for US$35 million from the Russian navy on behalf of the Cali Cartel. The Cali Cartel wanted a real submarine to be able to transport 40 tons of cocaine without being detected from Colombia to the United States and Canada.

The sale did not go through and the story of how a submarine from Russia was almost bought for the Cali Cartel was the subject of a documentary on Netflix called “Operation Odessa.”

Ludwig Fainberg in Russia looking for a submarine (Source: Miami New Times)

The three – Fainberg, Yester and Almeida were each indicted and subject to various prosecutions in connection with drug trafficking in the US. As they themselves say in the documentary Operation Odessa, their faces were plastered all over newspapers around the world and they were infamous.

Trailer for documentary Operation Odessa (Source: YouTube)

Fainberg flipped on Almeida for a reduced jail sentence of 33 months, subsequent to which he was deported to Israel, his last port of entrance before he had immigrated to the US.

Before moving to Miami, Fainberg set fire to businesses for the Mafia in New York when business owners refused to pay Mafia extortion payments, a job which he says he “enjoyed” and later moved to Miami where he opened a strip club and engaged in trafficking women from Eastern Europe.

“To be honest with you, I actually enjoyed it”, says Fainberg about his arson activities, torching businesses in New York City for the Mafia (Source: YouTube TsarTV channel)

Fainberg shows up in Canada

After his indictment and subsequent conviction in connection with activities of the Cali Cartel, Canada approved Fainberg’s entrance into Canada in 2000. Fainberg apparently married a woman in Ottawa and had some cash from somewhere which he planned to use to open a strip club in Canada with women from Eastern Europe that he said he could buy for $10,000 each from a broker in Russia (Benjamin Skinner, A Crime so Montrous: Face-to-Face Wirth Modern Day Slavery).

As noted by DEA special agent Alex Yasevich in this story on the Russian Mafia, they spread themselves across many criminal activities. Another Netflix documentary, The World’s Most Wanted, describes the story of Russian kingpin Semion Mogilevich, who used a Canadian issuer called YBM Magnex International to perpetrate a US$1 billion securities fraud. A 2010 Human Trafficking report published by Cambridge University noted that Mogilevich’s operations in Moscow and Budapest are also implicated in the trafficking of women, with relationships to crime groups in North and South America, further noting the fact that Fainberg used Slavic women to lure Colombia drug traffickers to his Miami strip club as an optimization of those relationships. Fainberg is apparently now back in Russia.

Don Aronow

Fainberg and Almeida were business associates with a person named Donald Aronow, who invented the “go-fast” boats that were used by cartels to run drugs up the coast to the US. Aronow was murdered in a gangland style hit on February 3, 1987, in Miami. Together with several others, he operated a marina called Fort Apache in Miami, frequented by drug traffickers. In a court proceeding, the marina was referred to as the Ester Palace where Almeida would treat customers as follows: “snow blind’em, eye wash’em and take their cake.”

Go-fast boats with turbo jet engines are used by drug smugglers

The esteemed Chief Judge A. Jay Cristol, a former Navy captain, wrote an entertaining judgment here in respect of some of these parties where he mused that transportation equipment sent to Colombia, such as Aronow’s go-fast boats, equipped with turbo jet engines that travel 600 miles at 60 miles per hour without refuelling were no doubt for sport fishing.

For the drug cartels to transition from go-fast boats to a submarine and reach out to the same group of drug trafficking transportation facilitators in Miami, makes sense. In addition to manufacturing and selling the cartels go-fast boats, they also procured military helicopters for drug cartels.

The identification, detection and interception of narco subs is usually performed by the US Coast Guard and other Coast Guards, together with national navies and drug enforcement agencies. Interceptions of narco subs can be very dangerous, as depicted in this video below.

US Coast Guard intercepts a narco sub (Source: YouTube Vice News channel)
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Laundering fish – new report points to China and US$23 billion IUU proceeds of crime problem

By Christine Duhaime | October 14th, 2020

China overfishing in distant waters

A new report from Future Directions International (the “Report“), based in Australia, is highlighting concerns about illicit proceeds and the fishing industry, particularly with China.

The Report, available here, says that China has the largest distant water fishing fleet in the world, estimated to be over 3,000 vessels, accounting for 40% of the distant fishing vessels worldwide. By comparison, the US has 300 distant water fishing vessels. The Report says that the Chinese fishing fleet is militarized and there is anecdotal evidence that the armed Chinese Coast Guard often accompanies Chinese fishing vessels to distant waters. The Chinese maritime militia is a subset of China’s national militia. China is the only fisheries superpower.

Fishing vessels from China off Zhoushan Islands (Source: Xinhua)

The Report notes that China has overfished its own waters, and moved to distant waters where it is exploiting the waters of other countries, particularly in Latin America and West Africa where enforcement tends to be weakest.

Illegal fishing off Canada

Illegal fishing also occurs off the coasts of Canada. This article here on homeland security, describes a two-month patrol by the US Coast Guard through the North Pacific Ocean in an international law enforcement operation to detect and deter illegal fishing. During the operation, the US Coast Guard conducted at-sea inspections on 11 foreign fishing vessels and reported 14 suspected violations involving three Chinese fishing vessels fishing for squid. As a result of the inspections, the fleet of 31 foreign vessels departed to avoid further inspection.

Chinese fishing vessel in North Pacific Ocean intercepted by US Coast Guard (Source: GTSC Homeland Security Today)

Global rankings of IUU

According to the IUU Fishing Index, available here, China ranked the worst in terms of illegal, unreported and unregulated fishing, referred to as IUU.

IUU fishing continuing

At the beginning of this year, China said it was taking steps to stop illegal distant water fishing originating from its vessels.

However, throughout June and July, 2020, Ecuador reported that there were 340 fishing vessels near the Galapagos Islands, most of which were Chinese flagged. The US Government took notice and commented on Twitter.

Ecuador claimed that at least 149 of those vessels turned off their tracking systems to prevent monitoring of their activities. When vessels go dark, their locations cannot be ascertained.

Argentina navy detaining Chinese fishing vessel, May 2020 (Source: Ministerio de Defensa)

A month earlier, Argentina arrested a Chinese vessel illegally fishing off its coast. It had gone dark as well, and when eventually detained, had 1,000 tons of dead fish on board. In June, in Ghana, a Chinese fishing vessel was arrested for IUU fishing a second time. And two weeks ago, Ecuador detected a whole fleet of 300 fishing vessels from China off its coast.

In 2016, Argentina sank a Chinese fishing vessel when it refused to heed calls to stop.

Argentina sinks a Chinese fishing vessel (Source: On Demand News)

In June 2018, the US Coast Guard and Chinese Coast Guard intercepted a Chinese vessel off Japan with 80 tons of chum salmon that had been fished illegally. The vessel, the Run Da, was apprehended using a 5.6 mile long drift-net on the high seas off the coast of Japan to catch chum salmon. There is a worldwide drift-net moratorium.

Canadian snow crab fishing in Québec’s St. Lawrence River (Source: Perishable News)

Over 3 billion people rely on fish as a primary source of protein, and sustainable fishing is a significant global food security issue. When it comes to poor nations, fish provides the necessary protein for over 158 million people. China alone accounts for one third of all fish consumption in the world.

The IUU fishing of squid is of growing concern. China accounts for up to 70% of squid captured in distant waters, controlling the supply, using unsound practices such as trawling nets between fishing vessels. Its unsound because it captures other fish (referred to as by-catch or collateral damage) and results in waste and greater environmental damage.

Blue crimes

China is not the only country engaged in IUU fishing by any means. The point of the Report, however, is that the scope and breadth of the activities from China in IUU fishing, presents a greater set of risks that impact global food security.

Crimes at sea, and in particular those that involve moving and laundering the proceeds of crime are so-called blue crimes. IUU is a type of blue crime that does not occur as an isolated predicate offence. Often it is associated with human trafficking, human smuggling, modern slavery and murder, as well as trade based money laundering.

Transnational criminal organizations

The Report also notes that illegal, unreported and unregulated fishing has become a new business for transnational criminal organizations (“TCO“), citing legal research from Professor Dr. Anastasia Telesetsky, a marine expert.

In earlier research, Professor Telesetsky found that the combination of flags of convenience, offshore shell companies in tax havens and little oversight of the shipping sector enables TCOs to engage in illegal distant water fishing. Responses by governments to view illegal distant water fishing as an issue of fishery management, as opposed to one of international organized crime, means that they approach the problem with the wrong lens to address the issue.

IUU fishing is US$23 billion in proceeds of crime

Experts estimate that between 1/8 to 1/3 of the global fishing industry is illegal, amounting to US$10 billion to US$23.5 billion in proceeds of crime that is laundered per year. In the US, officials estimate that between 20% to 32% of wild-caught seafood is illegal.

Governmental lack of capacity, coupled with lack of an approach of illegal fishing in terms of networking of criminality, means that criminals are outcompeting government counterparts in fisheries.

Maritime intel and security

A very cool intel tool that looks at the South China Sea (and beyond) that allows maritime researchers a bathymetric snapshot of the political landscape, the fisheries landscape, the military landscape, the legal claims landscape and the energy landscape, is the Maritime Awareness Interactive Map.

The US 7th Fleet maintains a continuous forward presence in the Indo Pacific maritime region, over 124 million square kilometres, and its operations encompass 36 maritime countries with over 50% of the world’s population. Its former commander, Navy Vice Admiral Robert L. Thomas Jr., said in 2016 that he was more concerned with the escalation of future skirmishes between national coast guards and fishing vessels in and around places like the South Luconia Shoals (off Malaysia), Second Thomas Shoal (off the Philippines) and Sharborough Reef (off the Philippines). An International maritime arbitration panel ruled that China has no claim to those areas, or waters surrounding them as an exclusive economic zone.

Command 7th Fleet (Source: Flickr, COMSEVENTHFLT)

Financial crime and food security

The 24 Hr Conference on Global Organized Crime on November 10, 2020, will discuss illegal distant fishing, money laundering and TCOs (see YouTube below), if you want to learn more about this important area of financial crime risk intersecting with environmental issues and food security.

The US government established a fraud portal here, designed to provide information in respect of the goal of stopping fish and seafood from IUU fishing from entering the US market place.

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York Regional Police bust illegal casino in Ontario operating from luxury mansion by Chinese PEPs and seize $11 million in assets and cash, illegal guns and arrest 29

By Christine Duhaime | October 8th, 2020

Project Endgame

York Regional Police in Ontario announced the arrest of 29 people following the raid of an illegal underground casino at a 20,000 square-foot mansion in Markham, Ontario, during the summer. The operation dubbed “Project Endgame”, resulted in several raids of illegal underground casinos operating in York region.

The first bust was on July 3, 2020. Police raided a commercial unit at 3276 Midland Avenue in Scarborough, that was being used as an illegal casino and seized gambling tables, slot machines and $20,000 in cash. Five people were arrested.

Luxury mansion casino

Then on July 23, 2020, York Regional Police, together with the OPP and Durham Regional Police raided a $9 million mansion at 5 Decourcy Court in Markham that was being used as a large high end casino called “Mackenzie No. 5 Club”, replete with slot machines, mahjong tables, a full service bar, a restaurant that served shark fin, a cash exchange area and hotel-style rooms above.

The mansion is owned by Wei Wei, a Chinese foreign national. He, his wife, Xiang Yue Chen, and their two children were charged with various offences related to operating a gaming house, possession of firearms, illegal sales of alcohol and dealing with proceeds of crime.

Mansion raid during Project Endgame (Source: OfficialYRP YouTube Channel)

Loaded guns and semi-automatic rifle seized

Police seized 11 guns, including a semi-automatic AR-15 rifle, $1 million in cash, shot machines, thousands of chips, gambling tables and $1.5 million in alcohol. The $9 million mansion was restrained.

Gun seized from Wei Wei’s mansion (Source: York Regional Police)
Gambling equipment from Wei Wei’s mansion (Source: York Regional Police)

York Regional Police believe that the mansion owned by Wei Wei and his wife, Xiang Yue Chen, may have been used for human trafficking of women for sex, and continue to investigate.

Large box of cash in Wei Wei’s mansion (Source: York Regional Police)

Investigation continuing

A third raid took place in Vanghan. Three people were arrested and more than $70,000 in cash was seized.

Wei Wei was reported as having met with Canada’s Prime Minister and advocates for the Government of China in Canada.

29 charged with criminal offences

Several Chinese foreign nationals were found gambling at the underground casinos and were charged. They are Chiu-Wing Luk, Wei Xia Lu, Qian Zhang, Guo Jiang, Yuan Jin, Dan Li, Mei Ying Pang, Rui Qian Huang and Chi Shing Yeung.

Several additional Chinese foreign nationals and three Bulgarian foreign nationals were charged with keeping a common gaming house –  they are Yuan Hung Li, Nan Chen, Haibin Chen, Tseng Hsiu Lee, Yan Yu Yang, Ivo Milnaov, Jianyang He, Xinran Wang, Qihan Tang, Emily Ho, Sinuo Du, Jun Liu, Siwen Zhang, Edmond Bilbili, and Nikolay Kolev.

The foreign nationals charged may also be naturalized Canadians but typically underground gambling operations in Canada for mahjong are set-up, funded by, operated by, loan sharked by and frequented by foreign nationals from China who continue to use their Chinese ID and have dual lives in two countries.

Wei Wei a high risk PEP

Wei Wei, his wife and two children are foreign and domestic (both) politically exposed persons under anti-money laundering law, which made them, and continues to make them, high risk when it comes to banks, for money laundering. It is surprising that they were able to obtain a large mortgage and financing to buy the mansion in the first place when it was foreseeable, given their PEP status, that they may be implicated in proceeds of crime allegations that would put the asset at risk for banks.

Link to organized crime

York Regional Police said that the illegal underground casinos was organized crime exploiting and demonstrating their money and position in a belief that they were above the law.

“Money moving through underground casinos leads to huge profits for criminals that fund other ventures such as prostitution and drug trafficking,” York Regional Police Chief, Jim MacSween, said in statement.

“This illegal high-stakes gambling also leads to gun violence, armed robberies, kidnappings, extortion and other serious violent offences within our community.”

Because Bulgarian foreign nationals were arrested and organized crime is involved, it is possible that it is the Bulgarian mafia – they offer crime as a service to the Italian mafia.

Even The Bridal Path once had an underground casino

Toronto and its surrounding area have a history of underground luxury casino operations in mansions that have been shut down by police.

People who grew up on The Bridal Path, a ritzy street in Toronto with 40 or so of the most expensive mansions in Canada, say that an owner of one of the mansions on The Bridal Path ran an unground luxury casino for several years. Cars would line up all the way down the street on casino nights and the parties would last until 6am. It was often raided and would re-open a week later.

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Bitcoin exchange owners charged by CFTC and US DoJ with various federal violations

By Christine Duhaime | October 2nd, 2020

The Commodities Futures Trading Commission (“CFTC“) today filed a civil enforcement action in the SDNY against the owners – operators of a digital currency exchange called BitMEX, for alleged violations of the Commodity Exchange Act. BitMEX processed trillions of dollars in transactions, received over US$11 billion in Bitcoin and made more than US$1 billion in fees. The CRTC says that BitMEX has customers that are US residents and that it transacted using the US financial system.

In a parallel proceeding, the US Attorney for the Southern District of New York unsealed an indictment against the three owners of BitMEX, namely Arthur Hayes, Ben Delo and Samuel Reed, for alleged violations of the Bank Secrecy Act.

With respect to the CFTC, it says BitMEX solicited and sold swaps, futures options and futures contracts and derivatives in digital currencies through their online platform, without being registered to sell such financial products, and further, that it did not have anti-money laundering procedures in place to protect the financial system.

The CFTC alleges, for example, that BitMEX altered on-boarding records of a US resident to “Canada” in order to have records that did not reflect the on-boarding of US residents, and that it was searching for a “favourable jurisdiction” to operate from (Isle of Man, Jersey and Gibraltar (typically used by illegal online gambling websites)).

BitMEX corporate entities HDR Global Trading Limited, 100x Holdings Limited, ABS Global Trading Limited, Shine Effort Inc, Limited, and HDR Global Services (Bermuda) Limited, were named as defendants in the CFTC filing. The CFTC says that as opposed to having the entities operate distinctly with different functions, all the corporate entities operated as one digital currency platform, sharing the same resources, personnel and one email address. The CFTC pleadings set out in length, the ways in which BitMEX attorned to the jurisdiction of the US, perhaps anticipating a defence argument of a lack of jurisdiction.

With respect to the indictment in the SDNY, Hayes, Delo and Reed, as well as Gregory Dwyer, were indicted for a failure to implement and maintain an adequate anti-money laundering program, and conspiracy to evade anti-money laundering legislation.

The indictment states that BitMEX set up a paper company in the Seychelles in part because they said that it costs “just a coconut” to bribe regulators in that country.

From its inception in 2014 to the date of the indictment, BitMEX did not file one SAR with an FIU anywhere in the world, and accepted financial transactions from Iran irrespective of sanctions. Further, BitMEX implemented TOR access to allow users to trade on BitMEX anonymously using the darknet.

The indictment states that one of the executives lied to US federal investigators, and in order to attract attention to the exchange in the US for client growth, rented three Lamborghinis for the 2018 Consensus Conference in New York and left them parked on the street for media attention – a move that BitMEX referred to as a “stunt”.

Hayes discusses selling Bitcoin derivatives on CNBC (Source: YouTube).

BitMEX’s CEO’s last point of reference was Vietnam.

It is expected that the US government will file to forfeit assets at BitMEX, currently at US$2 billion, otherwise there is a risk of liquidation.

In announcing the indictment today, the FBI Assistant Director William F. Sweeney Jr. said that the defendants will soon learn that the price of their alleged crimes will not be paid with tropical fruit but rather could result in prison time.

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SEC charges 3 Canadians with various securities violations, including pump and dump schemes, involving over 20 microcap issuers

By Christine Duhaime | September 22nd, 2020

SEC complaint

The US Securities and Exchange Commission (the “SEC“) filed charges against three Canadians, four Americans and nine private companies in the US District Court for the Southern District of California, for numerous violations of the Securities Act of 1933 and the Securities Exchange Act of 1934, for alleged manipulative market behaviour, including pump and dump schemes involving at least 20 microcap issuers.

One of the issuers, Abby, Inc., lists its principal securities regulator as Alberta and another, VMS Rehab Systems, is based in Ottawa. A third, Argus Worldwide Inc., had an office in Ottawa and its contact telephone number is in Ottawa: (613) 731-5935, a number shared with VMS Rehab Systems and several past issuers such as NPS International Corporation, AuraGenix and Seakinetics Corp.

The SEC alleges that the defendants made over US$6.6 million from illegal trades.

The nine companies named as defendants are Adtron Inc., dba, ATG Inc., DOIT, Ltd., DOJI Capital, Inc., King Mutual Solutions Inc., Optimus Prime Financial Inc., Orca Bridge, Redline International and UAIM Corporation.

Canadians allegedly participated in scheme

The three Canadians are Andrew McAlpine, who resides in the Cayman Islands and operated a brokerage firm in Belize; Ontario-based Ashmit Patel, a securities lawyer who practices in Illinois; and Ottawa-based Michael S. Wexler, the CEO of two of the microcap issuers.

The four Americans are Ongkaruck Sripetch, who goes by other aliases; Amanda Flores; Brehen Knight; and Dominic Williams. Williams allegedly controls Optimus Prime. (Optimus Prime is the name of the leader of the autobots from the film Transformers).

Entities associated with McAlpine have been charged by the SEC in the past.

McAlpine (Source: Cayman Compass)

Activities undertaken in concert

The SEC complaint alleges that all of the defendants worked in concert to: acquire shares of various microcap issuers; pay for the promotion of those issuers using third parties, such as, in order to cause the price of the shares to increase; and sell those shares when the market prices had been artificially increased from paid promotional activities.

One of the microcap issuers that the network allegedly paid for the pumping of, using, was Argus Worldwide Inc.

A Stockpalooza promotion of ARGW

The SEC also alleges that some of the defendants engaged in scalping and wash trading to cause share prices and trade volumes to increase artificially. Some defendants are also accused of selling restricted shares before the expiry of the hold periods. The alleged pumping and dumping of the shares of two Canadian entities – Abby Inc. and VMS Rehab Systems, are described in the SEC complaint in detail here. issued a promotion campaign of other issuers not named in the SEC complaint, including for an issuer named Largo Resources Ltd.

A promotion of Largo Resources Ltd.

Securities lawyer alleged participation

Based on the allegations in respect of Patel, he appears to have acted somewhat like a broker and a banker for some of the defendant entity clients, selling their shares, receiving proceeds from the sales and disbursing the proceeds back to the clients, minus commissions – if accurate, the activity appears to be a type of law firm washing of funds whereby the firm acts as banker, clearing house and perhaps even as obfuscator.

Patel was accused in the past by the Alberta Securities Commission of participating in a pump and dump fraud scheme with another lawyer in Calgary, Canada. The two lawyers allegedly made false claims in respect of mining interests in Africa and Alberta to boost the share price of an Alberta-based mining microcap issuer, and then allegedly sold shares of that mining issuer when the prices were artificially high and subsequently, violated the terms of a regulator’s order by trading during a cease trade order.

Network illustrated

Although the SEC complaint is a set of allegations, it illustrates the classic method of how securities fraud works, and in particular pump and dump schemes. They operate like a network in which the same actors are used repetitively over multiple years moving from one microcap issuer to the next, to complete aspects of the work required to achieve the goals in a manner that attempts to anonymize the actors in the network and their activities, to shield them from detection.

It also illustrates the role of professional facilitators in this type of securities activities with the use of professional firms. In this case, the SEC alleges that a professional firm was a witting participant (as opposed to unwitting, which also happens).

It demonstrates the sophistication, planning and advanced preparation in a sustained manner of the actors who form the nodes of a network to undertake the fraudulent activities, as alleged in the SEC complaint.

Parellel criminal indictment unsealed

A parallel criminal case was filed by the US Attorney’s Office for the Southern District of California following an indictment obtained in January, 2020, against Sripetch, Wexler, Patel and McAlpine for pump and dump activities associated with the same scheme.

Sripetch was arrested in the US. He was transferred to California from Washington State.

McAlpine arrested en route to Toronto

McAlpine was arrested by the FBI when a private jet he appears to have arranged from the Cayman Islands to Toronto, made a stop in Florida.

The C-FCGF McAlpine booked (Source: FlightAware)

Chances are that Sripetch and McAlpine were arrested on the same date because it was the first date following the filing of the indictment in January 2020, that McAlpine booked a flight out of the Cayman Islands and traveled over US air space. Indictments are often sealed until arrests can be coordinated, especially if it involves foreign nationals.

The Canadians, Wexler and Patel, are in Canada. An arrest warrant was issued for each of them in the US. Wexler is a long time member of the Rideau Club in Ottawa and no doubt easily locatable from that close membership network as a result.

List of microcap issuers

The microcap issuers whose shares were manipulated by one or more of the defendants, according to the SEC complaint, are:

  1. Abby Inc.,(ABBY) (it shares a CEO telephone number with Smart Ventures Inc.);
  2. Acadia Diversified Holdings Inc., (ACCA);
  3. American Transportation Holdings Inc., (ATHI);
  4. Andiamo Corporation;
  5. Angus Worldwide Inc., (ARGW)
  6. Capital Ventures Europe PLC, (CPVNF);
  7. Freedom Energy Holdings Inc., (FDMF);
  8. Formosa Liberty Corporation, (FLIB);
  9. Global Green Inc., (GOGC);
  10. Glow Holdings Inc., (GLOH);
  11. Kabe Exploration Inc., (KABX);
  12. Mirge Energy Corp., (MRGE);
  13. NI Technologies Inc., (NTCHF);
  14. One Step Vending Corporation, (KOSK);
  15. REAC Group Inc., (REAC);
  16. Smart Ventures Inc., (SMVR);
  17. Super Directories Inc., (SDIR);
  18. Textmunication Holdings Inc., (TXHD);
  19. Transnational Group Inc., (TAMG);
  20. Van Gold Resources Inc., (VGRI); and
  21. VMS Rehab Systems, Inc., (VRSYF).
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Vancouver issuer cease traded by Ontario Securities Commission

By Christine Duhaime | September 18th, 2020

A Vancouver issuer named Mountain Valley MD Holdings Inc. (“Mountain MD“), was cease traded by the Ontario Securities Commission today for a failure to file its required disclosure documents and based on the fact that a director, officer and insider had or may have, material information in respect of Mountain MD that such person did not disclose to the market place. Mountain MD says on its website that one of the five members of its management is a lawyer at a firm.

As an aside, in Canada, Bitcoin companies frequently put a lawyer’s name and likeness on their website and in pitch decks without the consent or knowledge of the lawyer. No big firm that I am aware of allows any of its lawyers to cross over into management of an issuer, client or not, or to use their name, likeness or logo on a website or pitch deck for, among others, liability reasons. Here, the SEC charged a Canadian Bitcoin person for misrepresentation for using the names of people in a pitch deck without their knowledge or consent.

Mountain MD is a triple listed issuer and a mining company that pivoted to cannabis and pharma. On or around July 31 2020, it issued a press release referencing vaccines, Covid-19 and approvals from the US government. In August 2020, it issued another press release mentioning vaccines and Covid-19. There is no known cure for Covid-19 at this time.

Mountain MD shares an office in Vancouver with two other BC issuers: Pepcap Resources Inc.; and Cielo Waste Solutions Corp.

Mountain MD’s office mate, Pepcap Resources Inc. is interesting. It was cease traded recently, and the order was revoked. It has no functional website, although it allegedly owns a mine in Indonesia according to its Sedar filings. Its Vancouver office rings to an Australian telephone number (61-40-301-8601) for Tek Sian Kwan.

Mr. Kwan’s is the founder of One Tech Platforms LLC, a California corporation, according to its website, located at Suite 750, 1920 Main Street in Irvine. Except that a law firm occupies the whole of Suite 750, 1920 Main Street in Irvine, California, not a tech company.

According to its website, One Tech Platforms is a FinTech that allegedly owns the “sole patent” for QR codes for mobile payments (pause; reflect upon the likelihood of the accuracy of that representation). It is, it says, a payment processing company used by major banks and law enforcement.

It is allegedly the “only FinTech that provides US federal and state regulators full transparency” (pause; reflect upon the likelihood of the accuracy of that representation) in respect of financial transactions, as the alleged “gold standard in traceability,” able to create an unbreakable audit trail for the Banking Services Act (there is no Banking Services Act in the US; pause; reflect upon the likelihood of the accuracy of that representation). No FinCEN or California state registration appears to exist for One Tech Platforms.

Mr. Kwan’s third company recently appears to have filed for receivership in Australia. He has a fourth company in the Cayman Islands which is a Hong Kong issuer.

Gek Suan Margaret Wee, aka Wee Gek Susan Margaret, aka Margaret Wee, aka Margaret Ang, was a director of Pepcap Resources Inc. until a few months ago. She is the founder of JMC Technologies in Singapore, although her telephone number is actually in California ((213) 908-1418). Mr. Kwan says he works at JMC Technologies in Singapore as well, so they are non-arms length parties in some way in respect of PepCap Resources Inc.

The address of JMC Technologies is actually the address for International Health Management Pte. Ltd., Sin Coal Pte. Ltd., and several others, and appears to be an R&R office used for Offshore Leaks entities, and so it looks like there is no physical office of JMC Technologies in Singapore, just like there appears to be no physical office of One Tech Platforms in Irvine, California.

What they actually do between Vancouver, California, Hong Kong and the Cayman Islands and where they actually are, seems a bit of a mystery.

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Things you find on Wikileaks – from spies who use fentanyl to kill people, Russian agents who use fentanyl to extract intel; to Iranian money movers with Canadian ties

By Christine Duhaime | September 8th, 2020

Wikileaks, fentanyl, murder and spies

I went on Wikileaks this week to find what information, in any, was discussed in diplomatic channels during the early days of fentanyl trafficking. I didn’t quite find what I was expecting but I did find a series of emails from analysts at a US private intelligence firm discussing Israeli and Russian spies who use fentanyl to take out people or extract information from them.

A bit of background.

According to this article in Vanity Fair, in 1997, the Israeli prime minister approved a hit on a then-little-known Hamas operative named Khalid Mashaal, who was working in Amman. The hit involved Mossad agents with fake Canadian passports confronting Mashaal on the street, inserting fentanyl into his ear and waiting for him to die.

Attempted murder of Khalid Mashaal

It may have worked except that Mashaal had body guards. The agents succeeded in inserting fentanyl in Mashaal’s ear but the body guards caught the two fake Canadian spies and apprehended them. Mashaal was on death’s door when the King of Jordan intervened with Israel.

A deal was brokered for Jordan to release the two spies who attacked Mashaal and for Israel to disclose what poison had been inserted into Mashaal’s ear so that he could be saved and to release several Palestinian prisoners. Mashaal was saved with Narcan; the two spies returned to Israel; and several Palestinians were released from Israeli jails. Mashaal became legendary among Hamas as “the man who would not die,” eventually becoming the leader of Hamas from 2004 to 2017, and amassing a fortune of US$2 billion.

Khalid Mashaal commenting on the attempted hit on his life with fentanyl

Fast forward to 2010.

Murder of Mahmoud al-Mabhouh

According to some Wikileaks emails, at the end of January of 2010, analysts at a US private intelligence firm began emailing each other about a news report alleging that a commander of Hamas named Mahmoud al-Mabhouh, was poisoned with an unknown substance at a hotel in Dubai by Israeli spies.

al-Mabhouh followed to his room by two alleged assassins

al-Mabhouh was one of the founders of the al-Qassam brigades, the military wing of Hamas. He arranged arms supplies from Iran to Gaza. He lived in Damascus, where Mashaal lives. He was killed at the Al Bustan Rotana Hotel in Dubai, after having been followed from the airport by several Eastern European men. The Dubai Police said that lab tests confirmed that he was poisoned with something and possibly smothered as well.

The hotel floor during the murder of al-Mabhouh in CCTV footage

Fentanyl to extract intel

Some of the dialogue in the Wikileaks emails from the private intelligence firm in connection with the hit on al-Mabhouh in 2010, are eye-popping as to the use of fentanyl by spy agencies to take out people. I’ve summarized the more interesting excerpts below:

“With fentanyl, the point is that it should look like a natural death.”

“Ck [check] with GF; he knows infectious diseases.”

I think he may be the assassin.”

“Mossad likes a modified form of fentanyl to kill.”

“Putting fentanyl into the ear is what the Izzies did to Meshaal [Mashaal].”

“If you have a pure form of fentanyl, it would be easy to kill someone very quickly … If you’re actually intending to kill someone, doing it in the ear would be a good bet as long as you can keep the person from showering.”

Fentanyl has been used by the Soviets for years to get some information.”

Typically, it would cause the person to go to the doctor for a minor ailment. The doctor would prescribe fentanyl … the person would be messed up so much that they were grasping for something to orient to, so that if someone came and gave them a little sympathy, they would grasp onto that person who would then manipulate them into giving whatever information they wanted.”

(In reference to fentanyl being used by spies to kill people): “J&J is a strong buy. You lads should buy as many shares as you can.”

Dutch or Danish company, correct. Israelis and Russians especially were playing with this stuff.”

“No, it was made by Johnson & Johnson (love that company) … the Israelis stole the patent from some Eurotrash company.”

“I’ve been in touch with Mayo [Clinic] and Dr. Wilson who worked on the Mossad bunged poisoning of the Hamas terrorist Khalid Mishal [Mashaal]. Can’t go into how I know him … In the Khalid hit, the bungled op was gummed up.”

Perhaps the lads got it right this time? Nice field test for the next dude marked for death.”

That list is long.”

In conclusion as to the hit on al-Mabhouh, the US private intelligence firm alleges: “so, the Mossad did do it.”

Wikileaks, lawyers, Iran, China, oil and methanol

I had only used Wikileaks once before this week and that too was fruitful. It was to read up on a lawyer and a law firm in Malta that, in 2008, had made an in-person disclosure to Malta’s bank regulator and to the US Embassy about their client from Iran. The client was a politically exposed person (“PEP“) close to the Iranian leadership who ran its oil export operations, with indirect ties to Canada, named Reza Hamzehlou, aka Reza Hamzelou, aka ضا حمزه لو، مدیر.

Disclosures by lawyers

A disclosure is more of an American law firm process, not well-known in Canada and it involves making a disclosure to protect against client conduct and sometimes involves a public disassociation statement for the same reason. It stems from the common law that holds that if a lawyer or law firm was used or abused for actions that were in furtherance of unlawful conduct, there is no client-lawyer relationship that ever took root. Since no relationship ever took root, the lawyer has no duty of anything owed to the supposed client. If that supposed client then undertakes unlawful conduct that impacts the lawyer or law firm, a disclosure may be warranted.

Malta, a money laundering hub

Hamzehlou sets up shells

The Wikileaks cable in respect of Hamzehlou showed that his Malta lawyer and the Malta law firm went to the governments of Malta and the US and disclosed Hamzehlou, his business associates, the advice Hamzehlou had sought and all of the companies in which Hamzehlou was associated with that were relevant to the Iranian government’s oil movements and payments back into Iran through Hamzehlou’s many companies.

The law firm provided emails and other evidence to both governments. The lawyer and the law firm made the disclosures because they said that they did not want any issues with the US government. No doubt they were concerned with prosecution for facilitating sanctions avoidance. The Wikileaks cable is a rare window of visibility into the secret disclosure process of lawyers and law firm to foreign and national governments.

Methanol sales to China

Fast forward two years.

Hamzehlou was often in the news, promoting his sanctions avoidance success and one such touting of sanctions avoidance prowess was reproduced in a Wikileaks email, highlighting Hamzehlou saying that US sanctions have not only not impeded Iran’s oil exports but that Iran was increasing sales and shipments of methanol to China.

Fast forward ten years to today.

Iran has become almost a sole source supplier of methanol to China. Why was Hamzehlou selling methanol to China and in such high volumes? For vehicles. China blends methanol into gasoline and liquefied petroleum gases. Blending methanol into gasoline allows China to extend the gasoline supply.

Xi’an announces methanol taxis in China

Hamzehlou indicted in Iran

Clearly, the Malta law firm who made a disclosure was on to something.

Hamzehlou is on trial in Iran, indicted in connection with a massive financial crime fraud case. His co-indicted defendants are an Iranian-Canadian who obtained Canadian permanent residency and an Iranian whose children acquired permanent residency in Canada, from Iran.

Canadian ties to indictment

They are accused of perpetrating the biggest fraud in the history of Iran using state-sponsored sanctions avoidance methods in which billions of dollars funnelled through shell companies (e.g., the reason for the legal advice in Malta that Hamzehlou sought) wasn’t returned to the government; allegedly, large portions were siphoned off and parked in other countries. The Iranian government has accused Hamzehlou of pocketing €7 million cash and acquiring €8 million in property from funds that are proceeds of crime. The amount alleged to be missing from Iran, though, at the hands of Hamzehlou and his co-defendants, including the one Iranian-Canadian, is much larger – it is €6 billion.

Irancell used Hamzehlou to move money

Irancell, the Iranian state-owned telecommunications company that controls Internet and cell phone access (and now 5G) in Iran, which is 51% owned by the Iranian government (some Iranians say its an open secret that the 51% is owned by the Iranian Revolutionary Guard), used Hamzehlou’s company and his team to move money out of Iran, according to Mohammad Reza Mokhber Dezfuli, the former CEO of Irancell. If that team included the co-indicted Iranian-Canadian, its unclear what that means for Canada, especially considering the IRG allegedly majority owns Irancell.

Mohammad Reza Mokhber Dezfuli left Irancell and now operates the Supreme Cultural Revolution Council (the Iranian revolution organization) in Qom for the Supreme Leader Ayatollah Khamenei. The connections to money movements and the Ayatollah seem awfully close to Canada.

The two other co-indicted persons in the financial crime case in Iran with Hamzehlou that are either Canadian permanent residents or have children that are, are known in Farsi as مرجان شیخ‌الاسلامی آل آقا and سید امین قرشی سروستانی.

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CFTC files fraud complaint against 5 Canadians, one American over binary financial trading scheme

By Christine Duhaime | September 3rd, 2020

The US Commodity Futures Trading Commission (the “CFTC“) has filed a complaint in the US District Court for the Western District of Texas, against five Canadians and one American, alleging that they operated a binary options financial scheme illegally, which was in effect a fraud.

The five, all from Ontario, are David Cartu, Jonathan Cartu, Joshua Cartu, Leeav Peretz and Nati Peretz. The American is Ryan Masten.

According to the CFTC’s complaint, the Cartu brothers operated a binary options trading service that was a massive fraud and in concert with the Peretz brothers, they offered binary options trading of commodities to Canadian and American investors through an online platform, one of which was called “Beeoptions.”

The CFTC alleges that the two groups of brothers made material misrepresentations to secure money from innocent investors, promising them quick returns of up to 85%, and operated through a number of offshore companies incorporated in, among other places, Belize, Seychelles and Ireland.

The CFTC alleges that the binary options sold by the defendants were managed like a casino where the investor always plays against the “house”, so to speak. The orders from investors to place a bet on a binary option were not actual transactions on their platform; rather, the CFTC says that mere book entries were made on the back end to give the illusion of trades through an account. The payments from investors were payments to the binary options enterprise and no money ever changed hands after the investor paid the Cartu brothers’ branded platforms to place a bet.

A binary option is a securities. This type of option, like the casino example that the CFTC used, is a gamble on the future price of a commodity, a stock or Bitcoin, for example, at a precise date and time. The gamble on the future price is a yes / no proposition which yields returns to the person if the price increases and nothing to the person if the price decreases and in the latter case, the person is out their money entirely.

In the case of Beeoptions, and similar platforms like it operated by the defendants, regulators allege that the house always won even when it didn’t. Here, David Cartu allegedly said in an Israeli Court proceeding that he did not own Beeoptions but also allegedly said that it had a payments processing relationship with the now defunct WireCard.

Beeoptions promo on YouTube which promises that when an option
expires “your account is immediately credited”

The Times of Israel reported that Joshua Cartu operated an online gambling website in Cyprus (possibly He is Ferrari-endorsed.

In order to obfuscate the financial transactions and minimize being de-risked by banks, the CFTC alleges that the Cartu brothers set up a FinTech payment processor in Ireland called Greymountain Management Limited. It did not have a licence to operate as a payments processor. It processed US$165 million in transactions for the Cartus and other third-party providers. Among other terms, the Canadian brothers referred to their payment processor as “SnowPay.”

SnowPay’s users were primarily from the US and Canada (60%); 20% were from Africa; and 10% from the EU.

SnowPay made large payments to the brothers in offshore companies, according to the CFTC. Two Cartu brothers received US$9.2 million each in payments from SnowPay and the third received US$4.8 million.

The CFTC is seeking an order for disgorgement, restitution and monetary fines as against the 5 Canadians, and one American. The restitution amount sought may be at least US$165 million, equal to the amount of payments processed by SnowPay. It could be more because that is just the amount processed through their FinTech payments processor, Greymountain.

In terms of assets, Joshua Cartu was fairly transparent about his wealth acquisition. He has a private jet and several luxury vehicles, and likely an account at HitBTC. He lives in a luxury condo at Vörösmarty 1 Building, Vörösmarty Square in Budapest.

Vörösmarty 1 Building, Budapest

He may have ties to the online gambling website – it crosses over at the same events that Joshua Cartu was at for periods of time.

Betsafe is operational in Canada and accepts bets from Canadians, even though that is contrary to the Criminal Code and provincial gambling statutes. It processes payments, and has funds on deposit at Canada’s Interac and with Visa, MasterCard and PaySafe. No Canadian provincial gambling regulator has made a move to shut down betsafe from Canada so there are assets there if it is or was tied to the defendants during the relevant time described in the CRTC complaint.

Betsafe’s Canadian payment processors for online gambling
Joshua Cartu’s car

David Cartu is believed to be in Ontario. Jonathan Cartu is believed to be in Israel. Joshua Cartu is believed to be in Budapest. The Peretz brothers are believed to be in Israel. Masten is believed to be in Texas.

In May of this year, the Ontario Securities Commission commenced proceedings against the Cartu brothers (here).

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SEC asks California Court to impose US$1M fine against pump and dumper tied to old Vancouver Hell’s Angels house shoot-out case

By Christine Duhaime | August 27th, 2020

Shaughnessy mansion

A very long time ago, July 2007 to be exact, a Shaughnessy mansion located at 1178 Lau​rier Avenue in Vancouver, Canada, was shot up. No one was hurt.

People said the shooter was a member of the Hell’s Angels, angry over losses he incurred from a pump and dump stock scheme that dumped too early, before he could liquidate his shares.

Scott Marshall

The owner of the mansion, now worth $14 million, was Canadian Scott Mar​shall, who was alleged by both the RCMP and the SEC to be a pump and dumper of at least two micro cap companies. People say that after his mansion was shot at, Marshall fled to the US.

Typology of pump and dumps

Pump and dump activities are a different breed of financial crime. In terms of typologies, they more closely resemble acts of terrorism because they involve actors who engage in a variety of preparatory criminal conduct prior to the commission of the crime.  In terrorism, these acts could include crimes related to the creation of false identities for group members, thefts to procure funding for the group and thefts of weapons or explosive materials.  These behaviours may ultimately culminate in acts of terrorism.  

The preparatory behaviour of pump and dumps is sophisticated – it involves a lot of planning with co-conspirators and can often take a year or more and involve domain name registration, offshore shell company formation, the issuance of fake stock certificates, opening of offshore bank accounts, locating a lawyer to unwittingly write false legal opinions to release restricted shares, and the recruitment of touters and promoters. Like terrorism, it is the preparatory activities that can lead more quickly to the detection of the criminal activities, rather than the commission of the predicate culminating offence.

House of fraud

Sometimes a particular pump and dump does not involve a significant ramp up of preparatory activities. In those cases, it’s because the same facilitators are already in place. These guys build a house of fraud and simply run different companies through the front door and out the back.

Intertech Solutions, Inc.

According to the SEC, Scott Marshall undertook preparatory activities from his office in Vancouver, to line up a pump and dump scheme tied to an issuer named Intertech Solutions, Inc., which raised US$7 million from investors fraudulently.

One of the touters that Marshall hired to solicit investments from the public was a man by the name of Clinton Maurice Tucker II.

Clinton Tucker II

Tucker II is reclusive. Since the shoot-out in 2007, he has gone a little off the grid. But not entirely.

From December 2014 through at least May 2019, the SEC says he became re-activated and began to assist in the fraudulent pumping and dumping of the stock of different companies using the same techniques, mostly from the area around Trabuco Canyon, California. Some of the investors Tucker II pumped stocks to, were from Canada. The SEC says he pumped stocks for Scott Marshall.

In May of this year, the SEC filed a complaint against Tucker II, charging him with various serious violations of US securities laws. Tucker II stayed hidden and did not participate in the SEC action. Today, the SEC obtained a default judgment against him and asked the Court to impose sanctions that could exceed US$1 million.

The SEC had pursued Scott Marshall as well, together with another Vancouver man, a CPA named David Michael Naylor, in connection with Intertech Solutions Inc. They settled with the SEC and agreed to pay US$7.4 million.

During the course of those years, a number of reporters covered stories of the alleged infiltration of the Hell’s Angels in the capital markets of Vancouver. For example, here and here.

The RCMP, together with the British Columbia Securities Commission, took action against Scott Marshall in respect of pump and dump activities but some of those efforts did not succeed in a British Columbia Court.

A snake pit

Back then, a reporter wrote that peo​ple should worry about the number of Van​cou​ver com​pa​nies trading on the OTC market because it was a “snake pit” and those people with companies on the OTC make “lousy neigh​bours, some representing a clear and present dan​ger”, to which he meant the danger of living beside Scott Marshall.

According to the SEC, Marshall and Naylor both have homes in Los Cabos, Mexico, a seaside city favoured by Vancouver and Mexican transnational criminal organizations.

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Canadian pump & dumper whose tip exposed the US college admissions test scandal, given longer sentence by judge than recommended

By Christine Duhaime | August 13th, 2020

Morrie Tobin, the Canadian financier who tipped authorities off about the college admissions scandal, was sentenced today to a year and a day in prison after pleading guilty to securities fraud for pumping and dumping stocks.

Despite his crucial tip and his cooperation in the investigation that led to the college admissions prosecutions, the judge in Tobin’s case today rejected the recommendation by the US government for no jail time, saying that he could not allow a felon who admitted trying to fleece investors of US$15 million to avoid prison. 

EPTI touters touted that your billions in EPTI will become allegedly even BIGGER!

Tobin is a wealthy financier – although Canadian, he lives in Los Angeles. In 2017, he participated in a scheme with others to falsely promote a microcap company whose shares he secretly controlled in a shell company. He participated in causing the shares to be artificially pumped, with others, to increase the share price and then when the share price was high, he dumped his shares.

Pump and dumpers benefit from the increase in the price of shares of a public company at the expense of innocent investors. In the case of Tobin, the company he pumped was called Environmental Packaging Technologies Inc. and he pumped it by representing, among other things, that the share price was going to go up by 1,118%, it had a patent pending that could forever change the packaging industry; and that as a result of President Trump, an investor in EPTI would gain whopping profits – for example, every US$2,000 invested would become US$22,360.

According to the Sentencing Memorandum filed by the lawyer for Tobin, two lawyers were part of the pump and dump scheme. At least one of the lawyers was charged.

The Tobin case is also very important – it crossed-over with Roger Knox, who is part of another SEC case with ties to Vancouver.

Tobin’s conviction means he will likely be deported to Canada at the conclusion of his federal incarceration in 2021.

Tobin was personally part of the college admissions scandal as well – he was in the process of bribing an athletic coach at Yale University an amount of US$450,000 for one of his children to be admitted to Yale who didn’t qualify, when he gave the tip to authorities.  

The tip led to the discovery of Rick Singer, who brokered deals for wealthy teenagers to attend Ivy League schools who could not enter under their own steam. Singer pled guilty. Over thirty people were charged in the US college admissions scandal, including Vancouver’s David Sidoo.

But for the tip about Tobin, the college admissions scandal, and the Roger Knox file, all tied to Canada, may not have been discovered.

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