At the time of the Banco Latino insolvency, Venezuelan authorities accused the bankers of:

• Financial Irresponsibility

• Corrupt Practices

• Theft

• Fraudulent accounting (false entries)

• Insider lending

They allegedly used bank assets as their personal petty-cash sources. Their excesses were legendary, one of the worst of which was chartering a Concorde for their personal use whilst opening a branch, at the cost of US$300,000.

In the US and other countries, they have funded and financed major real estate and business ventures with their illicit wealth. No serious attempt has ever been made to bring them to justice, and they operate openly and freely in the United States, as well as other countries, including one of the Caribbean offshore financial centres, the Turks & Caicos Islands, which is a British Overseas Territory.

Some of them financed a major luxury real estate development on Key Biscayne, Florida, until the facts appeared in the press, and the developers quickly stated that yes, they were involved pre-construction, but they has been replaced since with other investors. Are they linked to fellow Key Biscayne resident, the fugitive Guido Alejandro Antonini Wilson? We cannot say, but as soon as Sr. Antonini surfaces, we intend to ask him.

Inasmuch as there is a presumption of innocence, we do not choose to list the 82 fugitives here*, but we humbly suggest that compliance officers at financial institutions that have high net-worth Venezuelan exiles as clients reexamine those customers as follows:

• Do you have Venezuelan clients who are former bankers? (do not limit yourself to Banco Latino; there were allegations of misconduct at other Venezuelan banks; Banco Republica, Banco Progreso & Banco Consolidado)
  

• Since you opened those accounts before 9/11, were Source of Funds even questioned? Check now, please.
  

• If you have suspicions, ask to see the client's current passport; do they not ever go to Venezuela?
  

• Enhanced due diligence, using databases and Internet resources in the Spanish language, may confirm the client's prior profession.
  

• Some still show up on Venezuelan government websites from criminal and civil proceedings held in the past.

Have you verified the client's information in file from independent sources? (that does not mean your account relationship officer, thank you). Who were the client's bank and personal references? Were they principal players in the Banco Latino scandal?

Since these individuals are quite wealthy, as the result of their criminal conduct, expect them to have quite large balances, and be business owners, not employees.

We hope you find these corrupt individuals, before they are indicted for some financial crime they commit in your country, and prosecutors find they were your customers for a decade.
________________________________________________________________________________________________________ *I will, however, verify whether specific individuals have been indicted, according to the publicly-avilable list of defendants.