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Sayari Analyst Insight: How Understanding Naming Conventions Can Enhance Investigations
Whether you’re running know your customer (KYC) checks, conducting supply chain due diligence, or investigating a cross-jurisdictional money laundering scheme, properly understanding naming conventions across the globe can help you cast your net wide to find the right...
Public Records Shed New Light on the Alleged Forced Bankruptcy of Serbia’s Termoelektro
Following the 2013 bankruptcy of the then recently privatized Serbian company Termoelektro JSC, the workers – many of whom had been laid off – filed a criminal complaint in 2014 alleging numerous abuses by the company’s new Russian management. At the time, much of the...
Indicted Paraguay-Based Money Launderer Linked to Broader Illicit Finance Schemes in South America’s Tri-Border Area
A Paraguay-based currency exchange operator indicted in two U.S. jurisdictions on several money laundering-related charges is linked to broader contraband and money laundering schemes in South America’s Tri-Border Area (TBA), according to public records. These cases...
Shareable Dataset: At-Risk, Non-Obvious Subsidiaries of BIS-Listed Chinese Military End Users in Tech, Aerospace, & Metals
U.S.-identified Chinese military end users (MEUs) control more than 80 previously unnamed entities, according to our public records analysis. These companies, while not explicitly named as MEUs, may be at risk of directly or indirectly supporting China’s military. ...
Counterfeit Goods Series: Shareable Dataset on Seizures in Hotspot Shenzhen, China
We are pleased to launch the first of our quarterly reports on intellectual property infringement based on goods confiscated by the Shenzhen Customs Administration during the first quarter of 2021. In order to discourage production and sale of illegal facsimiles, the...
Chinese Communist Party Cells in Private Companies: Though Not Yet Universal, Increasingly Situated to Play Greater Roles in Corporate Governance
Private companies in China are under greater pressure than ever before to give the Chinese Communist Party (CCP) more say in corporate governance. Yet in spite of this pressure, less than half of all enterprises in China house Communist Party cells, most citing an...
XPCC Ownership in Xinjiang’s Solar Industry Hidden by Complex Ownership Structures
Sanctioned last year for human rights abuses, the Xinjiang Production and Construction Corp (XPCC) is in the news again for links to the region’s solar energy industry. Corporate records reveal that the XPCC owns multiple entities that operate in solar energy...
The Khalil Majzoub Brothers’ Corporate Network: Possible Vehicle for Money Movement & Sanctions Evasion on Behalf of Venezuelan Government
Almost a year has passed since authorities in Cape Verde arrested Alex Nain Saab Moran, an alleged financial fixer and deal maker for the Maduro regime in Venezuela. Saab’s arrest and potential extradition to the U.S. will likely curtail his direct role in any future...
Records from Iran’s Securities Regulator Can Help Unwind UBO Obfuscation Techniques
A common sanctions evasion technique used by Iranian companies is to obscure corporate ownership ties behind a complex layer of offshore shell companies and affiliates. This technique makes it difficult to identify the offshore holdings of sanctioned Iranian entities,...
PIF Investments in U.S. Companies Could Create Vulnerabilities to Potential Sanctions & Complicate Planned Strategic Projects
A recent report from the U.S. intelligence community concluded that Mohammed Bin Salman (MBS), the crown prince and de facto leader of Saudi Arabia, ordered the “capture or killing” of journalist Jamal Khashoggi in 2018. Now calls are coming from human rights...
U.S. AML Posture Tightening But Gaps Remain: Open, Connected Data Can Help Ease Challenges
The AML Act (“the Act”) enacted in January 2021 includes several measures to help financial institutions (FI) not only better understand their risks but also better mitigate their risks. However, gaps remain that raise important questions for FIs. In particular, quite...
Proliferation Financing: FATF Now Calls on Banks To Mitigate Risks
The Financial Action Task Force (FATF) in October 2020 adopted amendments expanding Recommendation 1 to include proliferation financing (PF) risk, in addition to money laundering and terrorist financing risks. Key PF typologies clearly demonstrate that certain open...
Tax Havens & Offshores: Public Registries & Network Analysis
While the lack of corporate transparency in offshore jurisdictions poses a significant due diligence challenge, not all offshores are as opaque as they seem. Easily accessible public registries from offshore jurisdictions combined with creative analytical techniques...
Trademark and Tax Records Tie Multi-ton Cocaine Seizure in Hamburg to Paraguayan Paint Company
A multi-ton cocaine seizure in the city of Hamburg, Germany conducted earlier this month is connected to a company based in Paraguay, according to Paraguayan tax and trademark records. The seizure itself highlights the continued role of European ports in receiving...
UK Property and Corporate Records Highlight Real Estate Holdings of Gulf Elites
Major business leaders and political figures from the Gulf Cooperation Council (GCC) monarchies invest billions of dollars into the UK real estate market annually. UK property records show that some investors are members of or even lead these royal families. The UK...
Downstream Holdings of China’s HNA Group Vulnerable After Multi-Billion Dollar Embezzlement Scandal
Chinese aviation investment conglomerate HNA Group is facing bankruptcy proceedings that will result in restructuring for 500 of HNA’s subsidiaries, according to media sources. By combining public records with network analytics, we were able to find more than 5,000...
New BIS Guidance Calls for Enhanced Due Diligence of Military End Users in China
The U.S. Department of Commerce has tightened restrictions on exports to China, Russia, and Venezuela to counter the acquisition of U.S. technology for military use. Now, military end users in all three countries are subject to licensing requirements. Identifying...
Public Records And Network Analytics Enhance Investigations for More Useful SAR Narratives
Regulators and law enforcement have made it clear — financial institutions (FI) must do more to enable investigators to craft more useful Suspicious Activity Reports (SARs). Data from public records enhanced using automated graph technology can transform AML/financial...
Addition of Tranche 5 Military-Affiliated Companies Under Section 1237, E.O. 13959
We have updated our dataset of Chinese military companies identified under Section 1237 of the National Defense Authorization Act to reflect the U.S. Department of Defense’s addition of nine entities on January 14. The updated dataset also includes 34 entities we...
Corporate Records Provide Additional Insight into Companies and Individuals With Alleged Financial Ties to Mexico’s Jalisco Cartel
The freezing of nearly 2,000 bank accounts last year with alleged ties to Mexico’s Jalisco New Generation Cartel (Cártel Jalisco Nueva Generación, CJNG) suggests that Mexican authorities may be upping the pressure on the organization’s finances. Mexican corporate...
Sanctions and Stables: Public Records Show Recently Sanctioned Horse Trainer Controls Companies in the U.S. and UK
A recently sanctioned UAE-based horse trainer maintains a network of previously unreported companies within the U.S. and UK. The network, which also has ties to Gulf-based Arab elites, highlights a unique case of risk within an industry not regularly subject to...
How Iran’s National Shipping Company Used Offshore Companies to Dodge U.S. Sanctions
Iran’s national maritime carrier used front companies in Cyprus, Hong Kong, China, and Turkey to hide its ownership and management of four sanctioned vessels, according to public records. Our investigation demonstrates the richness of data from offshore jurisdictions,...
How to Identify Military-Civil Fusion Companies in China Using Public Records
This is a follow-up to our previous posts on the highest risk entities owned by “Chinese Communist Military Companies,” the Section 1237 designations, and China’s Military-Civil Fusion strategy. Participation in Military-Civil Fusion can be identified in public...
Inclusion of Tranche 4 Military-Affiliated Companies Under Section 1237
We have updated our previous dataset of Chinese military companies identified under Section 1237 of the National Defense Authorization Act to reflect the U.S. Department of Defense’s inclusion of four additional entities (Tranche 4) on December 3. This updated dataset...
Emiratis for Hire: The Role of Nominee Shareholders in Sanctioned Iranian Networks
The U.S. Treasury’s Office of Foreign Assets Control (OFAC) sanctioned key players in Iran's oil industry in October for providing financial support to the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF). In the official press release, OFAC claims that the...
Public Records Indicate Lebanese PEP May Have Used Corrupt Assets to Build Real Estate Empire
The Middle East can be a lucrative business environment due to the continued liberalization of foreign investment laws and its relatively large and young working-age population. Unfortunately, the region suffers from a dangerous combination of public corruption and...
The World’s Largest Shareholders: Understanding China’s National and Regional SASACs
Anyone investigating China’s state-owned enterprises (SOEs) will eventually come across their primary owner, one of the State-owned Assets Supervision and Administration Commissions (SASAC). There are multiple commissions at every level of government in China, from...
Identifying High-Risk Entities Owned By “Chinese Military Companies” on Section 1237 & E.O. 13959 List
Recent U.S. regulations have targeted the risks posed by Chinese military companies, including 31 companies designated by the Department of Defense under Section 1237 of the National Defense Authorization Act of 1999 and later named in Executive Order 13959 (“the...
Peru’s Fishing Industry Involved in Laundering Money through GTO-Covered Miami Beach
An alleged money laundering scheme carried out by a family network based in Peru underscores how the Peruvian fishing industry has become a viable channel to clean illicit proceeds from a variety of predicate crimes. The network — composed of several immediate family...
U.S. Import Ban on Xinjiang Cotton Could Impact More Than 2,400 Chinese Firms
U.S. Customs and Border Protection (CBP) announced last Wednesday that shipments of cotton and cotton products from China’s Xinjiang Production and Construction Corps (XPCC) will be detained at all U.S. ports of entry. CBP’s Withhold Release Order (WRO) applies to...