A common technique that illicit actors use to hide their corporate connections and mask financial transactions is to have a nominee individual stand in as a shareholder or officer. This can help obfuscate true control of an entity as well as provide plausible deniability about the actual owner’s connection to it. Often, family members stand in on behalf of illicit actors. In these cases, mapping out an illicit actor’s family members can not only provide greater context to an investigation but can reveal previously unknown, high-risk commercial relationships.
Lebanese voter rolls, combined with a solid understanding of Arabic naming conventions, can be a powerful tool for uncovering these familial connections.
Nominee Shareholders and Family Connections
In most jurisdictions, nominee shareholders (also known as “straw owners”) aren’t strictly legal. Normally, if someone breaks a contractual relationship, the other party to the contract can turn to the courts for recourse. But because nominee shareholders aren’t legal in many jurisdictions, individuals who use nominees may have no legal recourse if their nominee disposes of an asset in a way that runs counter to the interests of the asset’s actual owner.
As a result, illicit actors will often turn to family members or close associates to serve as nominees. For example, relatives of Venezuelan President Nicolas Maduro have used nominees to hide their assets and discreetly siphon money from the government.
Start With a Name
When investigating Lebanese individuals, you can use information provided in the country’s voter rolls to identify the target’s family members. This includes parents, siblings, and sometimes even cousins.
Lebanon’s Directorate General of Personal Status maintains the Lebanese voter rolls. They are published electronically every year so Lebanese voters can confirm their voter registration information prior to elections. The rolls provide a wealth of identifying information: date of birth, national identity number, place of birth, father’s name, mother’s name, and religion.
The U.S. Department of the Treasury sanctioned Ayman Joumaa in January 2011. According to the U.S. Treasury, he is involved in drug trafficking and money laundering in South America. When sanctioning Joumaa, the U.S. Treasury published several pieces of information that serve as starting points to uncover companies and individuals connected to him:
— Full name: Ayman Saied Joumaa
— Passport: RL 0235074
— Citizenship: Lebanon and Colombia
All Lebanese citizens are registered in the Lebanese voter rolls by default. Because of this, we can use the information provided by the U.S. Treasury to identify Joumaa’s record.
Lebanon’s voter rolls contain one record for an individual named Ayman Joumaa (ايمن جمعه) with a father named Saied (سعيد). We can determine Joumaa’s father’s name from Joumaa’s full name, Ayman Saied Joumaa. In Arabic, the second name is usually a patronymic. As a result, we can be confident we have found the sanctioned Ayman Joumaa’s record in the voter rolls.
Leveraging Mother’s Name to Identify Siblings
From here, it is useful to investigate Joumaa’s relatives, as they may have commercial interests themselves. To do so, we will make use of the fact that the Lebanese voter rolls typically provide the first and last name of every individual’s mother.
Joumaa’s mother’s name is Ikram Youssef (اكرام يوسف). Searching the voter rolls for individuals whose mother’s name is Ikram Youssef, father’s name is Saied, and last name is Joumaa will return all of Ayman’s siblings. One of the five likely siblings this search uncovers is a brother named Akram Joumaa (اكرم جمعه).
Similarly, you can discover the names of Akram Joumaa’s children by looking for individuals with the last name Joumaa and a father named Akram. The place and date of birth can help confirm the individual is indeed his child. For example, if the individual is younger than Akram and lists a place of birth that matches an area where Akram previously lived, you can be more confident that the individual you’ve found is actually Akram’s son.
One of the many children returned for Akram is Jalal Akram Joumaa (جلال اكرم جمعه). Using this name, we can uncover companies that he is associated with. For example, Jalal is a seven percent shareholder and founder of Lebanese company ATLAPA Group LTD (اتلابا غروب ليمتد).
Atlapa is the name of a large convention center in Panama City, Panama. According to the U.S. Treasury, Ayman Joumaa and his associates are active in Panama City. Because of this, ATLAPA Group may merit further investigation to identify potential connections illicit activities related to the Joumaa network.
By leveraging the information contained in a Lebanese individual’s voter record, we can uncover their family connections. In cases where family members serve as nominee shareholders or directors to escape detection by authorities or enable money-laundering, identifying family members can be essential for uncovering risky commercial relationships beyond those held by the known illicit actor.
Techniques such as these are particularly helpful in cases where the subject has a common name. Using the voter rolls, it’s possible to identify potential siblings. By cross-referencing these siblings with other known associates of the subject that you’ve identified through corporate records, you can then narrow down and, in many cases, identify the individual in the voter rolls with a high degree of confidence.