Thread by @DawsonSField

Treasury OIG report on FinCEN designation of banks & countries as being of Primary Money Laundering Concern under the Patriot Act.
Not much detail, nothing exciting, but lots of questions.
Looked at the process used to designate 3 between 2013-Sept. 2016.
oversight.gov/sites/default/…

These are the criteria for designating a jurisdiction or country as an area of Primary Money Laundering Concern:

These are the factors for designating a bank, transaction or type of account as of Primary Money Laundering Concern:

The audit also looked at 3 of the 6 cases where FinCEN chose to not designate a bank or country as a Primary Money Laundering Concern and the lack of policy over what to do afterwards. Drop it, pass it off to another country to investigate or keep monitoring the situation.

The OIG auditors found problems with this process, including a lack of policy & management approval of actions taken. But the report provides no details, only stating that those policy issues & oversight have been fixed under the Trump Admin.

I have my suspicion that now that the OIG has ratified the procedures & policies, that these Patriot Act designations can be weaponized by the Trump Admin against the global money laundering networks.

So there is no evidence of which 6 banks or countries escaped sanctions & designation as a Primary Money Laundering Concern.
SO hard to investigate if they were letting anyone skate to allowing any suspect institutions or countries to escape...

The only really interesting part is a chart of banks & countries that were designated as of Primary Money Laundering Concern. Some were designated but curiously final rules never adopted... Not to mention those who are missing from the list.

Such an interesting list.

First thing that jumped out at me, who cancelled the designation of Ukraine in 2003 & let them off the list?

Second thing, why was Iran added to the list in 2011, but in 2019 the sanctions have still not been finalized?

Questions? Absolutely!

Why were no banks or jurisdictions designated between 2005 & 2011? Almost 6 years across 2 administrations with no new designations.
It's not Republians, it's not Democrats, it's #Corruptocrats belonging to both sides of the Swamp!

Why was North Korea not designated between 2002 & 2016? They were a designated state sponsor of terrorism, in violation of nuclear accords & laundering money to pay for it all.of that time.
Why was the final rule approved the day after Trump won the 2016 election?

Why were Moldavia, Cyprus, Malta, Azerbaijan and so many other money laundering jurisdictions not added to the list?

Is it because those were the places where the Swamp laundered it's money?
#ButNothingsHappening right?

Why were Jersey, Bahamas, Bermuda, U.K. Virgin Islands, and all of the other UK Commonwealth territories that serve as off-shore tax havens for shell companies never added to the list?
Because that is where the Swamp & multinational corporations hid their money?

What happens if the Trump Admin's leadership at Treasure starts using Section 311 as a weapon against the global corruption networks?
What if they designate these areas that enable money laundering & tax evasion?

One section of Patriot Act Section 311 that has not been used is the ability to designate "types of accounts" of Primary Money Laundering Concern.

What if they designate off-shore accounts set up by Mossack Fonseca as identified in the #PanamaPapers as of mny laundering concern?

Why was Venezuela never designated as a PMLC?
Was it because they were laundering a lot of their money into the US & China?

Was it because it would show that the socialists were running out of other people's money because they were stealing it!

Or did Venezuela escape designation because it bought friends in the Swamp?
Why do the investigations Venezuelan money laundering keep touching on Chicago, NYC & Miami?

Did Venezuelan crooks hiring Fusion GPS to run a PR campaign to hide the corruption play a role?

The same Fusion GPS that went after Browder for the Russians.
Went after Trump for the Democrats.
Went after Nunes to obstruct a criminal referral by Congress.

That Fusion GPS...

I found the Treasury document removing Ukraine from the list. They did it on the ground that Ukraine passed new laws criminalizing money laundering & requiring reporting & info sharing. But as we have seen those laws were never really enforced!
treasury.gov/resource-cente…

The revocation was under the authority of James F. Sloan then Director of FinCEN.
Sloan was a retired Deputy Assistant Director of the Secret Service who was appointed the Director of FinCEN by Clinton in April 1999, he left in 2003 to take over Coast Guard Intelligence.

Mr. Sloan retired & passed away in 2009 after a long battle with Lou Gehrig's disease. en.wikipedia.org/wiki/James_F._…

In 2006, during the lull in designations, FinCEN lost 2 Directors being hired away by Merrill Lynch & Bank of America. Two of the big banks now on the hook in the #ButNothingsHappening cases.

But I've learned a lot of the work (and dirty deeds) is conducted at the Deputy Director level. It lets you blame the boss if you get caught!
William F. Baity was the DD at that time. He was appointed as DD in 1995 & watched a string of bosses pass thru! tax-news.com/news/Key_US_Tr…

Mr. Baity is now an Assistant Professor at University College, University of Maryland. I believe that is their online & remote campus... So it may be a part-time gig. napawash.org/mr-william-f-b…

I can't find a specific date when he left FinCEN though, but I'm sure it is out there.
But I did find a curious note that a William F. Baity, suspended his law license in Louisiana (he was with DOJ there) decades ago.
Active since 1988 but it was suspended 2 weeks ago!

I did find a diplomatic cable addressing questions from a Jordanian bank to Acting D of FinCEN Baity on how to deal with the Palestinian Authority's accounts as members of Hamas, one of Iran's terrorist groups, was joining the government.
wikileaks.org/plusd/cables/0…

I found him on a listing of Federal Employee pay, where he is listed as a former employee. The last year that it is showing for him is 2009 but it looks like a full year salary...

So he may have left at the end of 2009.

This is also very interesting, from 2002-2008 Baity was Chair of the Egemont Group or Egemont Committee. Looks like a global professional association for Financial Intelligence experts & units. That would be quite a networking group...
egmontgroup.org/en/filedepot_d…

Why do you join a unit as Deputy Director & stay as DD for 15 years across 3 Presidential Administrations? While the Director's chair is a revolving door & you spend time as Acting Director but never get the job. While those Directors get big jobs to join the banks you regulate?

More on the Egmont group, this "informal group" of national financial intelligence units to set & maintain standards for conducting financial crimes intel & investigations. And they are hanging out in money laundering centers like Brussels & Bermuda to do it!

Looks like all the money laundering havens have a Financial Intelligence Unit that has a seat at the table of the Egmont Group.

Why would they meet in so many of the Swampy places in the world?

Who are Egmont Group's big partners on setting standards for how to investigate money laundering? The World Bank & the IMF, two of the biggest enablers of money laundering on the planet...

Either this guy was the biggest crusader for anti-corruption initiatives on the planet. Or he was helping design the system for setting standards in how not to notice money laundering & crime.
I guess time will tell...
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