DISCLOSURE

November 2016: Issue 2

The quarterly
Newsletter for
Civil Recovery
Investigators and
Attorneys

INTRODUCING the
second edition of
DISCLOSURE,
a
quarterly magazine to
enhance your civil
recovery knowledge.

in Antigua. Read on to learn about

their latest fantastic result!

This issue of Disclosure looks at

Recovery Orders. This final stage of
the civil asset recovery process can
be complicated and it is important
that you get it right. Inside you will
fi n d i n f o r m a t i o n , a d v i c e a n d
precedent orders to assist you with
your claim for recovery of assets.

I want Disclosure to be for you and

about you. Therefore, any
contributions will be greatly
appreciated please!

Finally, dont miss our attorney

and investigator of the quarter!
Disclosure updates on current
issues, and importantly, is an
opportunity to share successes
and lessons learnt.

Nicola Suter
For any contributions please contact me on:

Inside you will also find an article

from our first contributing author,
Curtis Bird, attorney at the ONDCP

nicsaunders1977@yahoo.co.uk

THE RECOVERY ORDER EDITION!

In this Edition:

Page

Recovery Order Issues.......................3

What should my affidavit include?...........4
FINCEN Requests............................12
Civil Recovery Training Antigua ...........13
ONDCP v Tagliaventi........................15
AML Seminar in Grenada ....................16
Lawyer and Investigator of the
Quarter....................................17
Civil Recovery v The Cartels...............18
Stop the Press ............................20

RECOVERY ORDERS
Civil Recovery Proceedings property freezing order or an interim Civil recovery orders are not like
under the Proceeds of Crime Act
enable your recovery authority
(usually the Attorney General) to
issue proceedings in the High Court
against any person who he or she
believe holds property which is, or
represents, property obtained
through unlawful conduct, or tainted
property. It is important to note that
property obtained through unlawful
conduct and tainted property are not
the same thing. Property obtained
through unlawful conduct is
property obtained by, or in return for,
unlawful conduct. Tainted property
is property that has been used in, or
is intended to be used in, connection
with criminal conduct.
The advantage of going to the High
Court is that it provides a civil
procedure. The recovery authority
need not bother with the
cumbersome task of obtaining a
criminal conviction from a jury who
are convinced beyond reasonable
doubt that the suspect is indeed a
criminal. In fact there is no need at
all for there to be any criminal
proceedings and there is nothing in
the legislation preventing the
recovery authority from seeking a
civil order even if you have been
acquitted in the criminal courts. It is
important to understand the concept
that civil recovery is all about the
property, not the guilt of the person
holding it.
In man y cases the recover y
authority will first of all apply for a

receiving order. The effect

will
prevent the respondent from dealing
with, potentially, any of their assets
up to a certain value. The Act
provides a 12 year limitation period.
In other words, the recovery
authority can seek recovery orders
for property which a person
obtained as long as 12 years before
the proceedings were issued.
The burden of proving that property
was obtained by criminal conduct
lies with the recovery authority but
the standard is the civil standard
the balance of probabilities - and
the rules of evidence allow for
hearsay. In essence, once a person
has been served with a property
freezing order or interim receiving
order, they may seek to vary or
discharge it. In the likely event that
the order is not discharged, the
respondent will have to defend the
application in the High Court. What
that involves depends entirely on the
case. The recovery authority, or the
respondent, may need to instruct
forensic accountants or track down
witnesses who can testify that their
sports car came from winnings at
the bookies. The arguments may
simply rely on inferences about
criminal conduct and any lack of
obvious legitimate income or tax
returns which could support the
p u r c h a s e o f p r o p e r t y. E a r l y
preparation will be vital in the more
complex contested cases.

confiscation orders. With the latter

the Court determines the
defendants (as opposed to the
respondents) benefit and then
decides the recoverable or available
amount. With civil recovery orders,
it is the actual property which is the
subject of the order whether it be
cash or an oil painting. If that
property was obtained through
unlawful conduct, represents
property obtained through unlawful
conduct or is tainted, then it will be
recoverable.
This approach makes it easier for
the recovery authority to trace
property. For example, if a criminal
has given away his ill-gotten gains,
that may not protect the receiver of
those goods. As the recovery
authority, you will have a choice. Say
a drug dealer uses his proceeds to
buy a speedboat. The boat is
brought exclusively with drugs
money. The seller knows this. The
Recovery Authority could seek to
recover the cash from the boat
seller, or the boat itself from the
drug dealer. It gets complicated
when not all the cash comes from
drug dealing or where the boat
seller then invests the money in
different ways. In these
circumstances, it is vital to
demonstrate a clear financial path in
respect of each item of property
see the next section on what to put
into your affidavit.

The affidavit in support of the claim for a Recovery Order is the backbone of your case.
Unlike the affidavit in support of an application for a Property Freezing Order, this affidavit
must be suitably detailed to satisfy the court that each and every item of property is either
recoverable, or associated property. It may be that there is also a forensic accountants
report to support the Recovery Authoritys case. See below a precedent affidavit. This is
only a basic precedent and may be used as a guide. It is almost definitely the case that you
will include further or different information, depending on your case.
THE EASTERN CARIBBEAN SUPREME COURT
IN THE HIGH COURT OF JUSTICE
ANTIGUA AND BARBUDA
Claim No.

of 2016

BETWEEN:
THE ATTORNEY GENERAL

APPLICANT
-AND-

[NAME]

FIRST RESPONDENT

IN THE MATTER OF A CLAIM FOR A RECOVERY ORDER PURSUANT TO

SECTION 60K OF THE PROCEEDS OF CRIME ACT 1993
_________________________
AFFIDAVIT
_________________________
4

I, [INSERT], Financial Investigator of the Office of National Drug and Money Laundering
Control Policy (ONDCP), SOLEMNLY DECLARE AND AFFIRM:
1.

That I am acting under the authority of the Attorney General for the purposes of
applying for a Recovery Order pursuant to Section 60K of the Proceeds of Crime
Act1993 (hereinafter referred to as the Act) with respect to the following property:
Recoverable Property
Vehicles
List each vehicle, including the make and model, registration number and registered
owner.
Real Estate
List each item of property, including the full address, title number and registered
owner. You do not need to list the contents of a house, unless there is an item of
specific value.
Accounts
List each account, including the bank, account number, name of account holder.
Associated Property
Remember that any associated property has to be listed separately. This may mean, for
example, that you list an item of property that is already listed above, because there is
a tenant in common.

2.

A copy of claim form number [INSERT] was served upon the Respondent/s and
[INSERT NAMES OF ALL PERSONS WHO HOLD ASSOCIATED PROPERTY IF
RELEVANT] on [INSERT DATE]. A copy of affidavit/s of service is hereto exhibited
as [INSERT NO.].
5

3.

Paragraph [INSERT] of claim form no [INSERT NO] identifies that property in

relation to which the Attorney General seeks a Recovery Order. Paragraph
[INSERT] of the claim form states, in relation to each item of property, whether the
property is recoverable

property or associated property, and who is alleged to hold

the property.
4.

In the event that this Honourable Court makes a Recovery Order in respect of the
property that is the subject of this claim, the property will vest in the Trustee for
Civil Recovery, pursuant to section 91(2) of the Act. At paragraph [INSERT] of the
claim form, the Attorney General requests that this Honourable Court appoint
[INSERT NAME] as the Trustee for Civil Recovery, and submits that [INSERT
NAME] is a suitably qualified person to act as Trustee for Civil Recovery pursuant
to section 62(1) of the Act. [INSERT NAME] is an insolvency practitioner
who holds an accountancy degree [INSERT DETAILS OF ALL RELEVANT
EXPERIENCE]. [INSERT NAME]s qualifications are hereto exhibited as
[INSERT NO.].

5.

A Property Freezing Order was granted by Justice [INSERT NAME] on [INSERT

DATE] in respect of the items of property listed in paragraph one (1) above. A copy
of the Property Freezing Order was served upon [NAME OF RESPONDENT/S] on
[INSERT DATE]. A copy of the affidavit of service is hereto exhibited as [INSERT
NO.].

6.

The Attorney General now invites this Honourable Court to make a Recovery Order
pursuant to section 60BB(1) of the Act if they are satisfied that the items of property
listed at paragraph one (1) are recoverable property.

BACKGROUND
7.

Insert here a background to the Respondent. Include their nationality, the name of
their wife and children if relevant, any alias they use and the evidence to
support that contention. Any other relevant matter relating to their background
should be included.
6

8.

[NAME] has been under

observation

by

law enforcement authorities,

including the ONDCP, from [INSERT DATES]. Based on police observation

and intelligence gathered over this period I verily believe that he is [STATE
THE

TYPE

INVOLVED

OF

CRIMINAL CONDUCT

IN.

BE CLEAR

HE/SHE

IS

OR

WAS

IE. DRUG TRAFFICKING/ FRAUD.

OUTLINE THE FACTS RELATING TO THE CRIMINAL C O N D U C T .

IF

RELEVANT

RESPONDENTS
9.

STATE

YOUR

ROLE IN THE

UNDERSTANDING

OF

THE

OPERATION].

That by virtue of the results of my investigations, I believe that the property

that

is

the

subject of this claim is recoverable property. It is the Attorney

Generals case that the property listed at paragraph one (1) of this affidavit
was

obtained

through unlawful conduct, namely [INSERT CRIMINAL

CONDUCT]/ is tainted property.

LEGITIMATE INCOME
10.

Here is where you set out all known sources of legitimate income. It may be
that the Respondent runs a business. In which case you should set out the
details of the business, how many persons are involved, how long it has been
operating, the size and scale of the business and how many staff it employs.
At recovery stage, you should know how profitable the business is/was.

11.

If the Respondent has a salary, this should be included. Likewise any known
income from trusts or inheritance.

12.

If the Respondent has stated on any applications or in any statements that

they have an income from a certain source, you must disclose this. This
information must either be discredited or verified.

13.

You should include all information relating to income declared to the Inland
Revenue Department here. Also any information from the NIS should be included
if such information exists.

UNLAWFUL CONDUCT
14.

All information pertaining to the Respondents criminal conduct should be

included here. This can include prior convictions and also circumstantial evidence.
It is not necessary to show any particular offence, committed on a particular
occasion. It will suffice to identify a type or kind of offence, but you must be
specific about the type of kind of offence (ie. drug trafficking/fraud etc). At
recovery stage, you should have completed your investigation. Any overseas
enquires pursuant to a Mutual Legal Assistance Treaty (MLAT) should have been
completed and all information intact.

15.

It is not uncommon for a Respondent to have amassed assets, however their

criminal activity is unclear. This is a complex and unclear area, however a lack of
explanation from the Respondent, or an explanation that turns out to be untrue,
will create an inference that the property has been obtained through unlawful
conduct. See the Guide to Civil Recovery for more detail on this point.

RECOVERABLE/ASSOCIATED PROPERTY
16.

In this section, you must satisfy the court (on the balance of probabilities) that the
property that is subject to the claim is recoverable or associated property. Unlike
the affidavit in support of an application for a Property Freezing Order, this
affidavit must clearly set out how each item of property was obtained and why the
Attorney General submits, on the balance of probabilities, that the property was
obtained through unlawful conduct. The following must be addressed:

Limitation
You must accurately state when each item of property was obtained (was it
purchased/obtained inside of the limitation period?)
Ownership
You must accurately state the owner of the property. If it is your case that the
beneficial owner of property is a different person to the registered owner, you must
explain why, with supporting documentary evidence. Issues you should include in
these circumstances include (where relevant):
- who has possession of the property;
- whether consideration paid;
- who holds registration documents;
- all evidence relating to who paid for the property;
- who pays the utility bills; and
- whether any third party has claimed ownership.
Path of Property Ownership
You must clearly explain how the property has been dealt with since it became
recoverable, with reference to the relevant sections of your legislation. Is the
property still held by the person who obtained it through unlawful conduct? Must
you follow the property into the hands of another person? Must you trace the
property into another asset? Is the property mixed with legitimate property? Each of
these concepts is dealt with separately under your legislation.
How the Property was Obtained
This is a vital part of this section. You must address (according to relevance) the
following points:
- How exactly was the property obtained?
- Was the property obtained with the benefit of a mortgage or loan?

- If so, how was the mortgage or loan re-paid?

- How did the respondent state they would service the mortgage or loan on
the application form?
- Has the respondent declared the source of funds for all repayments?
- Could the respondent have serviced the loan based upon their legitimate
income?
- Did the purchase of the property coincide with the respondent receiving
unexplained Westin Union deposits?
- If property was purchased using cash, was it local currency or
international currency?
- Could the respondent have paid cash for the item based upon their
legitimate income?
- Would it be expected that such property items would be purchased using
cash?
- If the property was gifted, what consideration was paid?

Current Valuation
A current valuation of each item of property will be required.

17.

In cases involving complex financial transactions, it may be the case that the
Forensic Accountant has conducted an investigation and written a report. This
report must be exhibited in the affidavit.

18.

Based on investigations carried out by the ONDCP, I verily believe that [NAME]
is the beneficial owner of the listed properties and that each item of property is
either recoverable property or associated property. The properties are:

10

RECOVERABLE PROPERTY
Vehicles
List each vehicle, including the make and model, registration number and registered
owner.
Real Estate
List each item of property, including the full address, title number and registered
owner. You do not need to list the contents of a house, unless there is an item of
specific value.
Accounts
List each account, including the bank, account number, name of account holder.
Associated Property
Remember that any associated property has to be listed separately. This may mean that
you list an item of property that is already listed above, because there is a tenant in
common.
19.

The total value of the aforementioned properties is [INSERT VALUE] (value of the
Real Estate subject to appreciation) and the Attorney General hereby seeks a Recovery
Order in respect of the aforementioned properties.

AGREEMENTS
20.

If the claim includes any items of associated or joint property, you must include a
section on agreements. You should state whether you have reached any agreement by
consent relating to how the property should be dealt with. Any agreement must be
made in accordance with the mechanisms set out in your legislation. If you have not
reached any agreement by consent, you should set out how you propose to deal with
the property again this must be within the boundaries set out in the legislation.

21.

The foregoing is true and correct to the best of my knowledge, information and belief.
11

FINCEN

FinCEN is an excellent tool that is already used by many investigators in the Eastern
Caribbean, but how effective are your FinCEN requests? Nicola Suter met with
FinCEN in Washington DC last month to discuss requests and how they could be done
better. FinCEN advised that despite an overwhelming number of requests received
every year, many requests do not result in the most thorough or best response, because
the request was not made properly. See below some basic tips on how to make the best
of your FinCEN request and ensure that you get the most helpful response possible.
Provide sufficient detail of the person who is the subject of the request. This
should include name, date of birth and (if possible) address.
Provide some guidance regarding what information you hope to obtain, however
be careful not to limit your request. Where possible, provide any additional
identifiers such as:
Bank account numbers
Telephone numbers
Email addresses
Passport or other official government identification numbers
FINCEN has the capacity to link such information to other key names/numbers/
addresses. When including additional identifiers (such as those listed above) it
will be best to request individual searches be made of each identifier.

Flag any urgent matters as these will be given priority attention by

FINCEN.
12

WHAT SHOULD MY AFFIDAVIT

CIVIL ASSET RECOVERY ADVOCACY TRAINING
INCLUDE?
Left: Ms Shannon
Gittens and Ms Carla
Brooks-Harris.
Below: Her Ladyship
Justice Henry giving
her opening address.
Civil recovery is an
eective way to make
criminals disgorge
their ill-gotten assets
Below: Mr Curtis Bird
applies for a Property
Freezing Order.

On Wednesday 2nd November,

INL, working in partnership
with the Judicial Education
Institute of the Eastern
Caribbean Supreme Court,
conducted civil asset recovery
advocacy training in the High
Court in Antigua.
Their Ladyships Justice Pearletta
Lanns and Claire Henry presided
over the day of mock civil recovery
applications and claims. Four
attorneys from the Oce of National
Drug and Money Laundering Control
Policy (ONDCP), Attorney Generals
Chambers and Oce of the Director
13

of Public Prosecutions presented

applications and claims throughout
the day.

Angela Brooks were also in

attendance to observe the training
and take part in discussion.

In her opening address, Her

Ladyship Justice Henry pointed out
that the majority of defendants have
specialist lawyers, ready to assist
them in with asset recovery cases.
She stated Defendants have their
specialists, so too must you
become specialists in this field.

INL Financial Crimes Advisor,

Nicola Suter and Mr Paul Garlick
Q.C travelled from London to
facilitate on the day.

Antigua and Barbuda are

becoming increasingly better
equipped to deal with civil
recovery cases. With an
increasing emphasis on this work
in Antigua, we look forward to
seeing the first civil recovery
matters before the court.

Director of Public Prosecutions, Mr

Anthony Armstrong and Acting
Director of Public Prosecutions of
the Turks and Caicos Islands, Ms

Her Ladyship Justice Lanns, Mr Paul Garlick Q.C and Nicola Suter.
14

YOUVE
SERVED!
ONDCPBEEN
v TAGLIAVENTI
BY CURTIS BIRD
On June 18th, 2016 the High Court of Antigua and Barbuda made
an Order forfeiting to the State all of the property of Dante
Tagliaventi, a well-known Antiguan businessman. The forfeiture
order attached to six (6) parcels of real property valued at
approximately $1.2 million EC, three (3) vehicles, all of the stock
of his various stores, and all
hidden assets.
Tagliaventi had been convicted in
Puerto Rico of conspiracy to import
narcotics into the Customs Territory of
the United States after he was arrested
by U.S. authorities and indicted in April
2012. He was accused by the U.S. of
planning and arranging large
shipments of cocaine into the U.S. He
was sentenced to 87 months
imprisonment, and thereafter to 5
years of supervised release.

Prior to his conviction, in reliance on

the U.S. indictment against Tagliaventi,



Antiguas Oce of National Drug and
Money Laundering Control Policy (ONDCP), had obtained a freeze order over all of
Tagliaventis property in Antigua and Barbuda under the Money Laundering (Prevention)
Act. Upon Tagliaventis guilty plea before the U.S. Court, the ONDCP applied to have
Tagliaventis property forfeited. He provided the court no basis that would have justified
excluding any of the property from the forfeiture order. The Antiguan law provides for
conviction-based forfeiture which can be applied to a foreign conviction for a money
laundering oence.

Dante Tagliaventi

This brought to an end a long-running encounter between Tagliaventi and the ONDCP.
This was the second time the ONDCP had had cause to freeze all of Tagliaventis
assets. Previously, the ONDCP in collaboration with Canadian and U.S. authorities
assisted in an operation in which Tagliaventi had been directly implicated that resulted
in the seizure of a sailboat named Friendship that departed Antigua. On 5 July 2004, the
RCMP intercepted the Friendship o the coast of Nova Scotia loaded with 550 kilos of
cocaine. The drugs seized from the boat were valued at approximately $18 million
Canadian dollars. Tagliaventi was subsequently charged with others by Canadian
authorities with conspiracy to import cocaine into Canada. While his co-accuseds were
convicted, Tagliaventi resisted extradition and those proceedings were eventually
discontinued upon the death of a key witness in the case, at which time his property
had been unfrozen. From thereon, the ONDCP set out to await Tagliaventis next
misstep, which culminated with his arrest in Puerto Rico in 2012.

15

AML SEMINAR IN GRENADA

On Saturday 5th November, INL worked in partnership with the
Grenada FIU and Grenada Bar Association to host an anti-money
laundering seminar in Grenada. The event was a huge success,
with approximately forty five members of the Bar attending.
Director of the Grenada Financial Intelligence Unit, Mr Tafawa
Pierre stated The training was well received. We had a lot of
positive feedback. We believe that it will greatly help with
compliance with the particular sector. We intend to build on the
interest and continue to engage the Bar
Money laundering is an increasing global threat. It has a devastating eect on the
soundness of financial institutions and undermines the political stability of
democratic nations. Emerging market countries are particularly vulnerable to
laundering as they begin to open their financial sectors.

It is vital that each country works to identify weaknesses in their own systems to
slow the tide of laundered funds from pervading their economies.By hosting this
anti-money laundering seminar in Grenada, members of the Grenada Bar

Association were
given a greater
understanding of
how
money
laundering may
aect their work
place, their money
l a u n d e r i n g
obligations and the
oences set out
under the Proceeds
of Crime Act.
16

disclosure investigator and

attorney of the quarter
This is the first time Disclosure has included quarterly
awards. With so much hard work and eort among regional
attorneys and investigators, it seems only fitting that this is
recognised. Congratulations Ivo and Curtis!
INVESTIGATOR OF THE

ATTORNEY OF THE

QUARTER

QUARTER

Ivo Ash is a financial investigator with the

Curtis Bird is an attorney with the Oce

Civil Asset Recovery Division (CARD) of the

of National Drug and Money Laundering

Saint Vincent and the Grenadines Financial

Control Policy (ONDCP) in Antigua. Since

Intelligence Unit.

joining the ONDCP in 1999, Curtis has

worked predominantly on asset recovery

Since joining the CARD at its inception in

and money laundering cases.

January 2016, Ivo has worked on civil asset

recovery cases resulting in approximately

Curtis has recently worked on major civil

1.4 million Eastern Caribbean dollars worth

forfeiture cases including Dante

of assets being frozen in Saint Vincent. Ivo

Tagliaventi, Pavlo Lazerenko and Ahmed

is now working to ensure final recovery of

Williams. These cases have recently

these assets, in addition to investigating

resulted in the forfeiture of approximately

numerous new cases.

70 million Eastern Caribbean dollars

worth of criminal assets. Congratulations

Congratulations on your hard work and

on your dedication and persistence

great results Ivo.

Curtis.
17

A record seizure of
almost

$700

million raised
questions in
Colombia about
how two brothers,
linked to the Norte
del Valle Cartel,
amassed such
power and wealth
whilst almost

CIVIL RECOVERY V THE CARTELS

completely
unknown

to

authorities.
The case of the Alvarez Meyendor brothers (pictured below), allies of some of the
most notorious drug trackers in Colombia's recent history, raised serious
questions about several top Colombian politicians, and demonstrated that it is not
always the most famous players who wield the most power in the international drug
trade.

Ignacio Alvarez Meyendor, all but unknown to the public until his arrest in
Argentina in 2011 and younger brother Juan Fernando, who turned himself over to
US authorities in April 2013, worked closely with now-imprisoned leaders of the
Rastrojos drug tracking organisation and key players in the defunct Cali and
Norte Del Valle cartels. The full extent of their influence was unknown until the
seizure of 200 properties in Colombia, with an estimated value in excess of $700
million, leading the ocial responsible for the raids to describe it as "the biggest
blow inflicted in the history of the Attorney General." With 80 more properties
coming under scrutiny, as well as 65 in Argentina, the total value of the brothers'
assets could exceed $1 billion.
The most concerning
element to this case relates
to the formal ownership of
the property. Among those to
appear on the titles of the
seized properties include
senators, religious leaders
and even a former president
Right: The Meyendor Brothers - on the
drug tracking board of directors.
18

The Meyendor brothers are reported to have emerged in the Colombian

underworld during the 1990s, forging strong links to the Norte del Valle Cartel and
the Rastrojos. By the 2000s, the Meyendors were working alongside Luis
Velandia, alias "Don Lucho" and operating on the same level as renowned drug
lord Daniel Barrera. Alongside Don Lucho, Barrera and emerald trader
Julio Lozano Pirateque, the brothers formed the so-called "El Dorado Cartel
described by US authorities as a "drug tracking board of directors. The El
Dorado Cartel was apparently responsible for shipping up to eight tons of cocaine
to the US and Europe each month.

The manner with which the two brothers were able to escape the notice of
authorities for so long will be of some concern to both Colombian and US law
enforcement. The pair joined the thriving community of expat drug lords living in
Argentina in the mid-2000s. Until his arrest, Ignacio had openly lived with his
family in an upscale neighbourhood of Buenos Aires, where he built up and
managed an extensive portfolio of business interests used to launder money. In
2008, he faced money laundering charges in Colombia but, according to Clarin,
wrangling over how to process the case prevented its progress.

The trail leading investigators to the Meyendors apparently began to emerge

once an investigation began into Don Lucho, who had also been living undetected
in Argentina. It is unclear whether Don Lucho gave the brothers up, or whether
investigators had been building a case against the Meyendors for some time.
What is certain is that, alongside Don Lucho, the brothers remained largely
unnoticed as they laundered up to $1.5 billion through Colombian soccer clubs.

Following his April 2011 arrest at an airport in northern Argentina, Ignacio was
deported back to Colombia, where he awaits extradition to the US. Juan Fernando
evaded capture until handing himself over to DEA agents in Haiti in 2013.

While it is dicult to say exactly how the brothers amassed such wealth
undetected, their move abroad was likely a key factor. It is possible that they saw
other major Colombian drug trackers elect to leave the country, and were savvy
enough to follow suit before becoming major targets. It is also possible that the
assets recovered by Colomba's Attorney General's Oce were not all purchased
with their own funds, but were intermingled with other members of the Cartel. One
thing is certain, recovery of these assets is an enormous blow to the El Dorado
Cartel and the ramifications go much wider.

On thing that remains unclear is the extent of the brothers' political connections.
With prominent political figures already exposed by the investigation, it remains to
be seen who else might be dragged into the limelight once Ignacio arrives in the
US and begins talking to prosecutors.

19

STOP THE PRESS

Anti-Money Laundering Seminar Grenada November 2016

http://nowgrenada.com/2016/11/lawyers-warned-client-fraud/

http://nowgrenada.com/2016/10/grenadian-lawyers-give-back-widercommunity-annual-law-week/

Civil Asset Recovery Advocacy Training Antigua and

barbudahttp://suntci.com/turks-caicos-islands-dpp-visits-antiguahigh-court-p2534-106.htm

Please send us articles

We are always looking for interesting news to share and experiences to demonstrate good practice to
others in the region.
If you have had any great results or would like the region to know about what you are doing in the
civil recovery field then please contact Disclosure at:

nicsaunders1977@yahoo.co.uk

20

!21