We are being reminded by the Federal Reserve that the new NACHA Rule for international ACH payments takes effect in one year. On 20 March, 2009, NACHA rules will require every ACH payment entering or exiting the US to be identified and formatted as an international ACH (IAT) Transaction. I have given an Internet address in the main article which contains several helpful hyperlinks for education and training.

Miguel Angel Melchor Mejia Munera, the leader of Los Nevados, a major Colombian narcotics trafficking ring, was reported killed this week in an operation conducted by the Colombian National Police. Mejia, who was wanted in the United States, with a $5m reward posted by the Drug Enforcement Administration (DEA), was a former AUC member who was doing business with the FARC, and has been described as the most wanted of all Colombian criminals by the country's Defence Minister. He was described as wearing a US military uniform when he died in an engagement between his bodyguards and the police, in which two members of his gang were killed, and three arrested. The problem is, nobody seems to be sure whether it was Miguel, or his twin brother, Victor Manuel, his partner in the Nevados drug cartel. So who was it?

Bulk cash smuggling continues to thrive in the Caribbean. A Bermuda national, Winston Franklin Robinson, together with a Trinidadian, were arrested and charged with money laundering after US$1.6m was found concealed on board a yacht anchored in a harbour in St. Vincent. Mr. Robinson, a reputed regional drug trafficker who apparently had made several prior trips to that country, reportedly has a prior conviction for narcotics possession in the Netherlands Antilles. He was deported to Bermuda from St. Martin in 2003, after serving one half of a sixteen-month sentence.

The US State Department has released its annual Country Reports on Terrorism and Patterns of Global Terrorism. The report includes a strategic assessment, country reports by region, a State Sponsors of Terrorism overview, and a chapter on the Global Challenge of WMD Terrorism. See below for the URL; it is in html format.

The Financial Crimes Enforcement Network, FinCEN, has withdrawn Advisories 21 and 21A concerning transactions involving the Republic of Nauru. To simplify, Nauru's reforms, new laws and effective implementation means that enhanced scrutiny of transactions involving that country are no longer necessary. FinCEN has withdrawn its finding that Nauru is a jurisdiction of primary money laundering concern, and has withdrawn its proposed imposition of "special measures" sanctions. See below of the URL of the text of the Advisory.

A scandal of giant proportions is brewing in Nicaragua; of the $250m transferred for a petroleum refinery, only $1m can be accounted for. To add to the mystery, the funding source was Petroleos de Venezuela, (PdVSA), the Venezuelan government-owned petroleum agency, which sent the money to a joint governmental venture, Alba de Nicaragua SA (Albanisa), to build what was to be the largest refinery in Central America. Was this actually a well-executed money laundering operation, with the planned recipients being cash-poor politicians from the Sandinista National Liberation Front (FSLN) who are up for re-election? That's what many Nicaraguans are saying, and this time, they maybe be right on the money. The funds are likely to be covert illegal campaign contributions, just like those previously injected into election campaigns in Ecuador, Peru, Bolivia, Mexico, and even Colombia, by corrupt Venezuelan elements.

FinCEN and the Office of the Comptroller of the Currency have imposed concurrent civil penalties of $15m against the New York Branch of United Bank for Africa, for its failure to implement an effective AML programme, notwithstanding prior Cease & Desist orders, and civil money penalties. The FinCEN Assessment of Civil Money Penalty recited the bank's history of AML deficiencies, and the regulator's many attempts to motivate it into building an operational anti-money laundering programme. The large penalty may signal that American patience with UBA has come to an end. Will the bank "death penalty," or loss of its charter, be the next, and final, sanction imposed? See below for URLs of the agency orders.

Please feel free to search the archives for relevant material for your compliance needs. You may also use the pull-down menu to access any of the thirteen article subject topics. Specific research enquiries are always welcome.

The Iranian government, reportedly reeling from the economic impact of UN Security Council sanctions, with banks Saderat, Sepah, Melli and Mellat unable to operate in international commerce, is allegedly taking extraordinary steps to evade sanctions. The Revolutionary Guard Corps, operating out of the Iranian Embassy in Caracas, is taking preliminary steps to purchase three Venezuelan financial institutions. Perhaps the owners of those banks might like to know that the real identity of the buyer represented by those prominent attorneys is the Islamic Republic of Iran, especially since those sales, if they are completed, will expose the sellers to material support of terrorism charges under US criminal laws. We list those three banks below, with the caveat that the sales, as of this moment, have not yet closed. However, when and if they do, one should expect an immediate and powerful response from US regulators and law enforcement.

Those readers who are keeping long hours this weekend will find Chapter 62 of "Confessions of a Money Launderer" on the website. Enjoy.