Iranian money launderer Ali Sadr Hashemi Nejad, at Malta’s Pilatus Bank.

A sworn statement involving the investigation into the transfers through which the Government of Iran was able to evade US sanctions, by funneling payments to a major residential project in Venezuela that far exceeded the actual amount necessary to cover the costs of construction, included the names of the financial institutions whose compliance departments cleared the wire transfers. If we had not drilled down into the information, the identities of the banks would not have been revealed.

The fact that a bank, wittingly or unwittingly, moved millions of dollars from a dodgy Swiss bank into Venezuela, through the New York banking structure, as the money was in US Dollars, is important to all who deal with, or have accounts at, that bank. Since the United States does not always publicize thew fact that American banks were involved in specific money laundering acts, and since the Death Penalty for banks, charter revocation by regulators, has never been implemented on violators, it is up to compliance officers to learn which banks they should be careful with , in their dealings.

In this case, involving $115m moved by the Ali Sadr Hashemi Nejad organization, the money generally passed through Hyposwiss Private Bank Ltd. The banks that thereafter were involved in these massive funds transfers included:

(1) HSBC Bank.
(2) JP Morgan Chase Bank.
(3) Espirito Santo Bank, now renamed Brickell Bank, in Miami.
(4) Commerzbank AG.
(5) Bank of America.
(6) Wells Fargo Bank.

US banks, which operates risk-based AML/CFT compliance program, should take this information in to account hen assessing ANY transaction involving Venezuela, given that these banks let more than  $115m pass through their hands.



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