‘Black Money’s’ Origin of Funds mystique

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By

Ricardo Swire

The “Origin of Funds” policy is selectively enforced, but mandatory where there is no accurate data related to individuals who made suspicious or flagged payments to an American corporation.

Senior Federal Bureau of Investigations (FBI) analysts have put pieces of a puzzle together that relate to a group of Caribbean entertainment promoters, who front as money launderers for America based transnational drug cartels and criminal organizations. Entertainment services payments are usually monitored, similar to other service sector entities.

FBI proof shows a common methodology, where cash is paid to US based talent booking agencies on behalf of the suspect Caribbean promoters. Host island event representatives remunerate American based promoters an agreed percentage of the show’s revenue. The US artistes used as innocent conduits for black money, laundered offshore on select islands out of US law enforcement’s direct reach. Both Origin and Source of funds are of paramount importance to banks, especially since AML legislation is strictly enforced internationally.

Risks and regulatory penalties intimidate financial institutions to the point where they prefer not to be legally charged or fined for poor corporate banking compliance. Corporate banking is completely different from private banking, although the business element also request proof regarding Origins of Funds, mostly when large financial investments subsidize a new company or project. If the Beneficial Owner already has a long term, established banking relationship, the new bank depends on the previous bank’s Know Your Customer (KYC) criteria. The handling of both Origin and Source of Funds require the last bank statement and withdrawal receipt copies.

Not long ago a law enforcement monitored New York crime character made a US$1.2 million deposit with a booking agency, on behalf of a Bahamian connected promotional entertainment organization. The black money represented ninety percent of performance fees. The contract’s Origin of Funds section was deliberately ignored for an extended period, until FBI agents contacted the booking agency with inquiries. A featured US R&B artist was booked for performances starting April 2017 in Barbados, the Bahamas, Guyana and Trinidad & Tobago.

Previously the same Bahamian entertainment entity successfully promoted events in Curacao and Grenada. Past occurrences helped strengthen the FBI’s theory. The costly series of Caribbean no shows, by Jamaican entertainer Vybz Kartel is one scenario. Prior to his incarceration for murder in Jamaica Vybz Kartel and his “Portland Empire” were contracted for a string of “Love Fest” concerts in Guyana and St Lucia. Advertised as main act the Jamaican deejay missed his commercial flight to Guyana twice, while his support entourage arrived at Cheddi Jagan International airport on schedule.

Guyana’s Conscious Minds Promotions representative was instructed to dispatch a chartered plane to transport Vybz Kartel. After the special flight arrived, at Norman Manley International Airport’s runway, it remained idle for an extended period. The entertainer and featured act again refused to leave Jamaica. St Lucia’s show promoter was compelled to pay more than US$20,000 cash, to guarantee Vybz Kartel’s performance at the annual Castries event.

Ricardo Swire

Ricardo Swire is the Principal Consultant at R-L-H Security Consultants & Business Support Services and writes on a number of important issues.