Should digital finance, FinTech & The Internet of Everything be regulated?

By Christine Duhaime | August 10th, 2015

The regulation of digital financial services, including those that are peer to peer (P2P) such as Bitcoin, engage the Blockchain or that involve other new FinTech, remains a hotly debated issue. Financial institutions want equal regulation and innovators in FinTech want a regulatory environment that is proportionate and allows new technology to thrive.

Adding to the complexity is the fact that with the Internet of Everything, the connectivity of services that are M2M (machine to machine) will have to involve micro-payments, the regulation of which must be efficient and streamlined as we move towards the digital economy.

The issue of the regulation of digital finance and FinTech, emerging payments and remittances, including its anti-money laundering and terrorist financing risks and prospect of regulation, will be discussed at the Digital Finance Institute Conference in Toronto on September 30, 2015. Our Keynote Speaker is Cisco’s chief strategist on The Internet of Everything, who will discuss the “Intersection of payments with The Internet of Everything to Grow Business Lines and Revenues.”

Also included will be a discussion on financial inclusion and regulation, as well as the role of artificial intelligence in the regulatory regime. As with all the Digital Finance Conferences, it will conclude with a Happy Hour social for attendees and speakers alike at a local bar (Vertical), included as part of the Conference fee.

The website is DigitalFinanceToronto.com to register.

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Nigeria says US$150 billion stolen from state coffers in 10 years by politically exposed persons

By Christine Duhaime | August 9th, 2015

Whopping $150 Billion Stolen from Nigeria in 10 Years

Nigeria’s new President, Muhammadu Buhari, today said that the government believes that its officials have stolen approximately US$150 billion from the state in the past ten years.  In anti-money laundering law, high ranking government officials with access to state property and assets are politically exposed persons (“PEP“). Every penny of the US$150 billion is proceeds of corruption or theft, hence laundered funds.

The Money Laundering of 1/3 of Economy of Nigeria

To put it in perspective, US$150 billion is almost one third of the whole value of the economy of Nigeria. The Government of Nigeria is effectively saying that approximately 1/3 of its economy has disappeared overseas in corruption payments or outright theft, into the bank accounts of private persons – in this case, PEPs and 1/3 of its economy has been laundered out.

PEPs

PEPs are a high risk for financial crimes, such as money laundering, tax evasion, corruption and terrorist financing because they have access to large sums of financing and the political power and banking relationships to launder money to offshore locations for their personal benefit. All banks in Nigeria, including Western banks, are required to undertake proper enhanced due diligence in respect of all PEPs to ascertain that any assets and money they deposit and move is legitimately earned, otherwise they are required to de-risk and terminate the accounts.

“Mind-Boggling” Assets Stolen in Oil Sector

President Buhari also disclosed that “mind boggling” sums of money had been stolen from the country’s oil and gas sector, which accounts for 70% of Nigeria’s national revenues. Likely by PEPs. Nigeria is the largest producer of crude oil in the region.

President Buhari said that the government would engage professionals to undertake asset recovery of state assets and recover the assets. There is likely more than US$150 billion in state assets missing and to the extent such assets landed in foreign banks held by PEPs, should be relatively easy to freeze and recover.

Nigeria Conducted Business with Non-Government Bank Accounts

Shockingly, President Buhari said that up until now, some official government business had been conducted using non-government bank accounts, suggesting that PEPs and government agencies in Nigeria use personal or private company bank accounts to conduct official government business on behalf of the people of Nigeria.

Effective today, every government agency in Nigeria has been ordered to use only government-approved bank accounts to conduct government business. The order is designed to introduce transparency into Nigeria’s government financial transactions and to stop so-called “leakage” – a polite term that refers to corrupt and other payments made under the table.

Terrorism, Immigration & Foreign Corporations

Nigeria is a terrorism hot spot with a large group of ISIS members connected through Boko Haram and although the economy of Nigeria is growing, it is plagued by constant terrorist attacks and serious problems of terrorist financing throughout the country, not just the northeast. The economy is unstable and the banking system is consistently used for the receipt and export of corrupt payments and to fund terrorism, however unwittingly.

An increasing number of Nigerian foreign nationals who are PEPs are seeking to immigration to terrorism-free countries with proceeds of corruption and they prefer Canada, the US, France and UK. Banks who banks such PEPs and immigration officials and agents need to be exceedingly cautious that they are not banking or processing persons who have proceed of terrorism or proceeds of corruption, and with respect to persons, that they are not Boko Haram members seeking to immigrate on instructions from ISIS.

Foreign corporations that do business with Nigeria should be only providing payments to the Government of Nigeria pursuant to agreements to government bank accounts and should ascertain that none of the payments represent corrupt payments, or facilitation payments to Boko Haram, particularly for the oil and gas sector that the government has identified as problematic.

As a financial crime mitigation strategic, global banks should assume that significant sums being patriated for immigration purposes to other countries involve PEPs and involve some percentage of proceeds of corruption, hence is dirty money that was laundered through banks or in other ways, unless established otherwise. PEPs who are corrupt the world over fit the same typology — they seek to move proceeds of crime to safer, stable economies through immigration, and to move their families there as well, to attend elite schools and establish a lavish lifestyle in the new country of residence. Due diligence on the banking side, as well as the immigration side, will ensure Western countries and the financial system are not used as safe havens for proceeds of corruption.

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Why Cecil The Lion’s killing has money laundering & simplified extradition implications

By Christine Duhaime | August 3rd, 2015

Cecil The Lion

Surprising as it may seem, the Cecil The Lion incident is a money laundering issue.

First some background facts.

Background

According to the Zimbabwe Parks and Wildlife Authority, on July 1, 2015, Cecil The Lion was killed by Dr. Walter Palmer, a US citizen who lives in Minnesota, and a Zimbabwe national, Theo Bronkhorst.

Dr. Palmer is a dentist. Mr. Bronkhorst is a professional hunter who works with a company called Bushman Safaris and is affiliated with a place called Antoinette Farm, beside Zimbabwe’s Hwange National Park. The owner of Antoinette Farm is a person surprisingly named Mr. Honest Trymore Ndlovu.

Cecil The Lion was a “protected animal” under Zimbabwe law.

In early 2015, Honest Ndlovu was authorized to provide hunting services at his Farm for certain animals for 2015. He was not authorized to provide hunting services of lions but he did anyway, to Dr. Palmer.

Mr. Honest Ndlovu and Mr. Bronkhorst have both been charged in Zimbabwe, as has Dr. Palmer.

Zimbabwe Hunting Laws

Pursuant to Zimbabwe’s Parks and Wildlife Act, it is an offense to hunt a protected animal that is not a threat without permission, punishable on conviction to a term of imprisonment of 20 years. It is also an offense for a professional hunter to allow a person to hunt a protected animal or any animal outside of authorized zones. And further, it is an offense to transport or ship, animal parts (a trophy) of an illegally hunted animal, an offense which has legal ramifications for airlines.

Before the Cecil The Lion incident, Emirates Airlines took a leadership role by eliminating the carrying of trophy lion parts on its airlines pursuant to the UN Convention on International Trade in Endangered Species of Wild Fauna and Flora.

Left Cecil The Lion to Bleed for 40 Hours

According to Zimbabwe officials, Mr. Palmer paid $70,000 to his guides to hunt a lion.

On the day of July 1, 2015, they allegedly placed animal meat on a vehicle and drove around at night to lure a lion out of the National Park. Cecil took the bait and he was shot, but not killed, with a cross bow by Dr. Palmer. The team decided to let him bleed out for 40 hours until they ultimately shot him dead when he was weak and dying. Dr. Palmer then cut off Cecil’s head and skinned him, for trophies. Cecil The Lion was collared and GSPed. Dr. Palmer allegedly subsequently made arrangements with an airline to have the lion’s body parts shipped to the US.

On July 7, 2015, the Zimbabwe authorities learned Cecil had been killed from an informant.

The Zimbabwe authorities say that, in additional to conducing an illegal hunt, Dr. Palmer illegally financed the illegal operation.

There are about 30,000 lions left in the world. Zimbabwe has about 1,000 of them left. Over a ten year period, Zimbabwe allowed 800 lions to be hunted legally. Many more are apparently hunted illegally. Most of the hunters are American. In 2013, 49 lion parts (trophies) were legally shipped to the US by hunters from Zimbabwe by willing international airlines. Zimbabwe issues permits for 100 lion killings annually.

Wildlife Crimes

Now for the money laundering part.

The illegal killing of big game, as a Cecil The Lion, is a type of wildlife crime of which there are several components but materially, the three key ones are the illegal killing, the unpermitted export and import of dead animal parts (the trophies) and the trade thereof, which is the business aspect of the activity. Wildlife crimes can be purely commercial enterprises or conducted by an individual.

The US government confiscates large volumes of animal parts from wildlife crimes when their citizens return from hunting trips, or attempt to import parts. This photo is of seizures of trophy cats either illegally killed or illegally imported into the US.

The US enforces its domestic Endangered Species Act and the UN Convention on International Trade in Endangered Species of Wild Fauna and Flora. Both protect endangered and protected animals of concern globally.

Money Laundering 

Persons such as Dr. Palmer, who make arrangements to travel overseas to kill big game, must pay their safari guides – in this case Mr. Bronkhorst and Mr. Ndlovu, tens of thousands of dollars for the hunt by wires into their banks in Zimbabwe.

Because the killing of Cecil The Lion appears to be illegal in the criminal sense in Zimbabwe, and a predicate offense, dealing with the proceeds of that crime is money laundering under the Zimbabwe Serious Offences (Confiscation of Profits) Act, 2001. What this means is that Mr. Bronkhorst and Mr. Ndlovu are both holding proceeds of crime in their bank accounts, i.e., the money Dr. Palmer sent them to commit the crime.

Pursuant to that the Serious Offences (Confiscation of Profits) Act, 2001, a person need not be convicted of a predicate offense in order to establish that the property involved is proceeds of crime. Where there is no evidence to show that a person participated in the predicate offence but that he benefited from it, he can be prosecuted for money laundering. This applies to all three of the people who hunted Cecil The Lion.

One would suspect that the reason the Zimbabwe government mentioned the financial aspect of the transaction, is because the extraction of Mr. Palmer would be expedited and simplified if there are allegations of money laundering on the table. Most countries have made a money laundering charge an extraditable offense in and of itself.

Dr. Palmer is not a particularly sympathetic player in the story, especially when it emerged that he has killed several other big game animals, such as this leopard. The Zimbabwe Government has said they are seeking his extradition, and in the meantime, Dr. Palmer quit practicing dentistry and has gone into hiding.

What Should the Average Person Do?

Airlines – Vote with Your Wallet

If you personally care about the issue of the killing of protected species or big game animals for sport, one constructive thing people can do is vote with their wallets by not using airlines that ship big game trophies into countries like Canada and the US, particularly where those airlines do not verify the kills were legal and permitted.

Take a look again at that picture, above, of the voluminous number of stuffed big cat heads seized by the US government in just one of their offices –> each of those decapitated animal trophies was shipped for profit to the US by airline companies and was an illegal importation  (unpermitted at the shipping or receiving end), hence they were seized. The same happens in Canada. Ethical business practices matter a great deal to consumers.

Big game hunters want lion heads and such, hanging in their homes for show. Depriving them of the ability to ship animal parts internationally when they break the law, helps to curb the practice of illegal hunting of endangered cats like Cecil The Lion.

Scams & Donations

Many scams will crop up all over the world to raise money, purportedly for Cecil The Lion – one should exercise financial crime common sense when donating to such causes. Because of the financial crime issues, and corruption problems in Zimbabwe, sending money to agencies associated with Zimbabwe, or the Government of Zimbabwe, is not recommended, even if they purport to work for wildlife preservation.

It is preferable to make donations to an organization in the US or Canada, for example, where they enforce financial crimes, including for charities, and their customs agents stop trophies entering the country illegally.

One should also exercise caution with crowdfunding sites raising money for Cecil The Lion that just cropped up – some sites do not have financial crime rules or policies in place and some campaigns are raising money for Zimbabwe, which is to be avoided due to the financial crime concerns.

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‘Twitter terrorist’ a danger, says panel at ACAMS Conference

By Christine Duhaime | July 17th, 2015

The Lawyers Weekly has a good story covering the ACAMS Conference in Toronto’s panel on terrorist financing in which we participated with FINTRAC, Standard Chartered and the OPP to discuss the risks and issues of terrorism threats in Canada.

The article, available here, discusses Ontario and security concerns, as well as how FINTRAC deals with terrorist financing reports, with coverage on how the Islamic State uses social media for recruitment and financing efforts. It also summarizes risks, including how a certain Bitcoin online exchange advertises that it offers services in Syria with the use of bank accounts from Canadian and US banking institutions.

As noted in the article, ISIS’ social media efforts represent a major threat to Canada.

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In 2015, more countries become terrorist hotspots; Canada moves up ranks to become 35th in terrorism threat index; US moves up to 17th place

By Christine Duhaime | July 5th, 2015

US and Canada move up on the terrorism threat index

2014 and thus far in 2015, have been marked by a dramatic increase in terrorist incidents and in the number of countries that have been pulled into terrorist activity and for which financial institutions have been used for terrorist financing. Western countries are becoming less safe, as they increasingly become targets of terrorist attacks, or attempted attacks. They are also being used more than ever before as a breeding ground to radicalize terrorists in the West over social media (see the “Twitter Terrorist” for more) to defect and to undertake domestic lone wolf attacks.

Canada, for example, now ranks 35th globally on the country terrorism threat index released on July 5, 2015, ahead of (more of a risk than) Mexico, the Palestinian Territories, Thailand, and Sierra Leone. China ranks 36th and Turkey ranks 34th. Spain, which ranks 33rd, just issued a “maximum alert” for terrorism saying that the country was at the same level of terrorism risk as the Madrid attacks in 2004.

The US now ranks 17th under the country terrorism threat index. According to the US Committee on Homeland Security, since early 2014, there have been 47 planned or executed terrorists plots against Western targets, including 11 inside the US that were inspired by ISIS. Moreover, there have been more ISIS-linked plots against Western targets in the first half of 2015 (28 thus far), compared to all of 2014, in which there were 19. The number of “home grown” terrorist plots have tripled in the US in the past five years.

The country threat index is an artificial intelligence created risk assessment based on numerous inputs including messages from terrorist groups and injuries and threats that have occurred. It is created by the Intel Center Database and is updated in 30-day increments.

High risk generally for terrorist attacks

According to our research, countries in which there is a high risk of a terrorist attack, and terrorist financing, include:

  • Syria
  • Iraq
  • Nigeria
  • Somalia
  • Tunisia
  • Yemen
  • Libya
  • Afghanistan
  • Pakistan
  • Ukraine
  • Egypt

Terrorist safe havens for financing and illegal movements

Terrorist safe havens are pockets within countries where terrorist affiliates offer safe haven services (financing, terrorist banking, passage of terrorists, fake identity, movement of other people and goods illegally). They are  at risk for terrorist financing and commercial and immigration fraud, as well as money laundering. According to the US Committee on Homeland Security, the key safe havens for terrorist organizations, and of concern for fraud and terrorist financing, are as follows:

  • Afghanistan
  • Algeria
  • Egypt
  • India
  • Indonesia
  • Iraq
  • Jordan
  • Kenya
  • Libya
  • Lebanon
  • Nigeria
  • Palestinian Territories
  • Pakistan
  • Philippines
  • Russia (North Caucasus)
  • Somalia
  • Sudan
  • Syria
  • Tunisia
  • Yemen

High risk for terrorist attacks on tourists in select locations

According to the Foreign & Commonwealth Office, the following are high risk in certain locales for terrorist attacks that may affect tourists:

  • UK
  • France
  • Thailand
  • Spain
  • Israel
  • Australia
  • Lebanon
  • Indonesia

High risk for terrorist attacks at hotels

According to the Intel Center Database, the following are the countries with the highest incidents of hotel terrorist attacks in 2015:

  • Somalia
  • Libya
  • Afghanistan
  • Yemen
  • Tunisia
  • Kenya
  • Columbia
  • Egypt
  • Iraq

High risk of terrorist refugee claimants

According to material released out of Syria and Iraq, the following are at high risk for being so-called “fake” refugees, i.e., persons who are members of, affiliated or aligned with, or are former foreign fighters from, the Islamic State who have been commissioned by the Islamic State to infiltrate the West by claiming refugee status:

  • Individuals arriving in migrant boats from Libya to the EU who avoid refugee camps or formal refugee registration
  • Individuals arriving by foot in Iraq, Lebanon or Turkey from ISIS-controlled areas who avoid refugee camps or formal refugee registration

Foreign fighters returning home

With respect to foreign fighters who joined ISIS and are attempting to return to the West, according to locals in Syria, they have apparently been trained by ISIS to recite a similar story, namely that the atrocities committed by ISIS were not only abhorrent to them but that they refused to commit them, and that once they arrived in Syria, they had an immediate change of heart, tried to defect from ISIS and at great personal risk, eventually managed to escape. Things they will not be able to substantiate to Western intelligence agents (where their stories will be contradicted or internally inconsistent) will centre around, inter alia, their identity documents; access they have to funds; access to mobile devices; alleged change of religious radicalism; alleged renunciation of ISIS way of life; and change of physical appearance (especially hair and facial grooming) and clothing back to blend in with Western styles.

Unchartered waters

No one, and no agency appears willing to discuss this issue, but separate and apart from the complex constitutional and treason-related legal issues all courts will face with defectors returning home, there are additional issues to consider with respect to such persons, namely that eventually a war crimes tribunal will be established in the EU, and private actions will be commenced by victims against foreign nationals who defected to join ISIS. Such foreign nationals will be defendants in multiple class and separate actions for a host of crimes and atrocities committed.

Foreign governments that re-admit them need to be exceedingly careful about how they treat and process such persons in order to avoid their own exposure in such lawsuits.

Countries should be establishing policies now for immigration purposes to address these issues so that its officials have guidance and a process to follow that is consistent with the combination of refugee, constitutional, and war crimes law. Nationally and legally, we are entering unchartered waters where experience, expertise and a balanced approach will matter in every country.

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ISIS becomes a central bank and releases its new terrorist currency

By Christine Duhaime | June 22nd, 2015

True to its word, the Islamic State (ISIS) has released its own currency, the gold dinar, pictured above.

The creation of an ISIS central bank issuing currency and taking control of, and managing monetary policy, is an obvious further step towards fulfillment of “statehood” for members of ISIS and sympathizers.

Unfortunately, the legacy of an Islamic State currency and functioning central bank, even when ISIS is defeated, will live on for decades to come and will fuel the flames of terrorism long after that. The fact that they got this far, in and of itself, will become part of future terrorist propaganda to recruit more sympathizers and funding for terrorist activities.

According to Tweets we picked up from ISIS sympathizers and such, ISIS reportedly said they were acquiring a mint in late 2014 for $100 million from the EU to produce the coins, and at that time Tweeted that “money was no object”, as well as the suggestion to sympathizers that buying the new ISIS gold dinar was a way “to support” ISIS.

The sale of a mint to a terrorist organization, or parts thereof, is terrorist financing and presumably the vendor will be easy enough to determine for the purposes of prosecution.

The new ISIS currency is created entirely from terrorist funds and is a new form of terrorist financing not seen before. The purchase, collection and use of such currency, being derived from terrorist financing, is in and of itself terrorist financing for a person who purchases, collects and uses it.

An earlier post on the plans of ISIS to create a new currency is here.

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The FIFA scandal and why banks may be facing regulatory issues over KYC failures

By Christine Duhaime | May 31st, 2015

FIFA Indictment against PEPs

The 47-count Indictment against 14 persons employed or engaged by FIFA by the US District Court for the Eastern District of New York (“EDNY“), and their arrest may do more than shake up international soccer – it also has the potential to result in significant fines against many global banks who processed transactions for the indicted persons for failures of anti-money laundering law. US authorities announced charges against nine FIFA officials and five sports executives associated with FIFA, who were part of a scheme in which they received $150 million in bribes for commercial rights to soccer.

FIFA is the international body governing organized soccer and is registered under Swiss law and headquartered in Zurich.    The Indictment alleges that the defendants solicited, offered, accepted, paid and received bribes and kickbacks acting in their capacities as affiliates with FIFA and engaged in fraud and money laundering in respect of the proceeds of crime. In addition, they are alleged to have corrupted the sport of international soccer.

According to the Indictment, in order to hide the proceeds of corruption from being detected, the defendants are alleged to have established trusts, set up shell companies, and used banks for illicit payments in tax havens. In 2012, when US law enforcement began interviewing FIFA officials in connection with the investigation, the Indictment alleges that several defendants obstructed justice by, inter alia, destroying evidence. The Indictment alleges that the bribery scheme deprived youth leagues of funds to support soccer and run soccer programs.

KYC & PEP Failures

The banks that processed the transactions that involved money laundering may be facing regulatory issues under anti-money laundering law because the defendants were politically exposed persons (“PEPs“) in multiple countries (which was ignored by banks in multiple jurisdictions) because they were senior officers of FIFA or business associates of senior officers, and because the transactions were suspicious. Transactions were suspicious because the indicted persons did not earn anywhere near the amounts they allegedly received as proceeds of crime through bank transactions, to justify the transactions, hence money they received was suspicious ab initio. Clearly, the KYC procedures failed at these banks.

With respect to PEPs, had PEP laws been complied with at the banking level, many of the later transactions would have been refused by banks. Conducting due diligence of respect of one PEP typically involves a due diligence investigation of many more people associated with the PEP who are, by definition, also PEPS and in foreign jurisdictions can take months if bank statements are required to be translated. PEP law is just a more involved aspect of KYC. Most banks de-risk PEPs rather than undertake the requisite due diligence because of the expense of banking a PEP.

According to the Indictment, the defendants relied heavily on the US financial system and correspondent banks. The US government said it is looking at the banks that are involved. According to the Indictment, just one US bank refused to process one transaction that was alleged to be proceeds of crime. The other banks processed close to $150 million in alleged proceeds of bribery.

The PEP issues in respect of the FIFA Indictment are similar to those facing banks in Hong Kong, the US and Canada who bank PEPs from China without complying with PEP laws, as described here.

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Canada’s Chief Justice talks about defectors who leave Canada

By Christine Duhaime | May 30th, 2015

The Chief Justice of Canada, Beverley McLachlin, delivered a keynote speech yesterday in Toronto and therein, discussed briefly the phenomena of jihadism affecting Canada and tolerance. In discussing tolerance, she said that it has its limits and that there may be some things that should not be tolerated by society because they harm people or institutions, and noted that the line between what is acceptable in society and unacceptable ultimately falls to lawyers to determine (qua legislators or judges).

Continue reading

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How come the Coalition keeps missing large ISIS convoys on satellites and oil trucks of terrorist oil a mystery

By Christine Duhaime | May 26th, 2015

Palmyra was an ISIS target

How the Islamic State managed to take control of Palmyra, Syria seems to be raising questions about the effectiveness of the intelligence-gathering ability of the Coalition. ISIS has stated on numerous occasions and in multiple languages, and on various media, that they are going to destroy the heritage sites of Syria and Iraq one by one. In Syria, the Crown Jewel of significant heritage sites is Ancient Palmyra, thus a foreseeable target for quite a few months at least.

How did we miss a convoy of flagged ISIS trucks in the desert with 1,800 troops?

ISIS apparently approached Palmyra, as it usually does, via convoy of hundreds of vehicles carrying 1,800 troops along one highway. ISIS has specially equipped vehicles emblazoned with its logos and flags and drive in formation, and such a convoy would be hard to miss smack in the middle of the Syrian desert. The desert is, well, sand colored. ISIS’ trucks in Syria are, as we know, usually white. Such a long, moving convoy of military vehicles sticks out like a sore thumb from the sky, the highway and from satellites and should have been easy to take out whether by jet, missile or drone.

How difficult is it to bomb an ISIS convoy?”

Here is a news report taken a few days after ISIS seized control of Palmyra and in it, a local Syrian asks the question everyone is asking: “How is it that American satellites missed them [ISIS]; the desert is like the palm of a hand and the militants and their trucks, pick-ups and tanks are moving. What is this Coalition doing then?”

Press TV: “Exclusive footage of ISIL held Palmyra”

And here is an Intragram post by KurdTV in which they ask rhetorically: “Wondering why it is so difficult for US to bomb these ISIS convoys of trucks and stop them conquering cities?”

If some or all of Ancient Palmyra is razed, the average person will wonder why nothing was done to prevent it from happening and inevitably may place the blame at the feet of the Coalition – not because they are to blame (they’re obviously not), but because they had the intelligence and military capacity to prevent ISIS reaching Palmyra and failed to exercise that power to save lives and preserve a landmark of significance to humanity. They could have taken out a convoy of 1,800 ISIS troops and irreconcilably, elected not to. In this radio interview, an ISIS commander says that they will destroy all the statues in Ancient Palmyra but that they will not destroy the Ancient city.

Taking out oil tanker trucks to stop terrorist financing

This is not the first time that questions have been raised about how come ISIS vehicles are not being wiped out with air strikes. It has happened before in the context of counter-terrorist financing. In November 2014, before testimony at the US House Financial Services Committee, David Cohen, now Deputy Director of the CIA who is not only very clever but usually not rendered speechless, couldn’t (or elected  not to) answer questions posed to him by Rep. Steve Pearce on why the Coalition wasn’t stopping terrorist financing by blowing up oil tanker trucks and the delivery mechanisms used by ISIS to transport terrorist oil to market.

Rep. Steve Pearce said:  ”You have access to that. Every movement, every highway, every oil field. You know which oilfields are under their control. I wonder why you’re not stopping the oil today because you can do it. It is well within your grasp. You have the technology and the information…You can blow up the trucks…or the delivery mechanism. This is a very simple operation…they could do it this afternoon…just stop the oil. We can shut it off today.”

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Digital Finance Conference to Include Hot Money Laundering & Terrorist Financing Issues with FINTRAC & RCMP

By Christine Duhaime | May 24th, 2015

The Digital Finance Institute’s 1st Conference on FinTech and Banking Innovation is holding two sessions on anti-money laundering, terrorist financing and regulatory compliance that will cover the latest issues facing government agencies, regulators and financial institutions relevant to financial technology and innovation.

The session is approved by ACAMS for CLE credit for professional financial crime experts to attend, and is approved by the Law Society of British Columbia for CPD credit for lawyers to attend.

The first session is chaired by the Editor of ACAMS’ Money Laundering publication, Kieran Beer and will cover “Hot Issues in Anti-Money Laundering in Vancouver; a Potpourri Discussion on AML Compliance in Vancouver that impacts all financial institutions including FinTech such as Real Estate, Hot Money from China, Politically Exposed Persons, Terrorism and Risks from Transnational Criminal Organizations and Bitcoin” and includes speakers from the RCMP and FINTRAC, as well as ACAMS Certified Anti-Money Laundering Specialists.

The second session is devoted to digital currency and Bitcoin issues, including financial inclusion and regulatory matters and is chaired by the Financial Crime and AML lawyer for the digital currency company Ripple Labs, who recently negotiated their settlement with FINCEN, and will include prominent speakers in digital currencies, digital banking and digital innovation, including Sarah Martin from the Digital Currency Council and Ebru Pakcan from Citi Bank, both from New York City.

Registration is www.digitalfinance2015.com.

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