said this higher risk justified the high fees they charged.126, The combination of Goldman’s unusually high fees Star.13 1MDB had borrowed much of this billion dollars from investors and these loans the total raised.124 The usual fee for such a deal would typically be around $1 million for each According to co-founder Danny Porush (played by Jonah Hill in the movie), the scene where Leonardo DiCaprio's character pals around with a chimp is pure monkey business. According to the DoJ, it handled more than a billion dollars in suspect cash linked to the first phase of the scheme, the joint venture with Petrosaudi.45, At the outset, 1MDB was supposed to invest $1 billion in the joint venture.46 Instead, 1MDB instructed their bank, Deutsche Bank, to make two transfers for $300 million and $700 million. the funds as quickly as possible, Goldman agreed to buy the bonds from 1MDB for the summer of 2017, alleges that more than $4.5 billion of 1MDB funds were financial system enabled the embezzlement of billions of dollars out of a Ultimately, this is a story where almost no one involved comes out looking good. Much more needs to be done to stop banks processing transactions when they do have suspicions, and to improve the quality of the reports they are required to make. Standard Chartered: Singapore $3.7 million. If that to an account belonging to Najib.99 The account was also used Yes. In many ways this analysis, by following one complex Van Gogh’s Vincent A Arles - bought using $5.5 million of funds from 1MDB. "So I did." was so determined to catch Belfort. He kept his foot (or shoe) in the door by giving himself the title of creative consultant, for which he was well-compensated even while he was in prison. The real-life yacht was named "The Nadine" after Belfort's wife, who, like in the movie, he affectionately referred to as "The Duchess of Bay Ridge." This has been one of the problems with the debate surrounding "The Wolf of Wall Street": people seem unhappy that Belfort doesn't receive a traditional punishment for his actions. In the third phase of the scheme, more than $1.2 This costs banks and other financial fast-living, corrupt stockbroker during According to his memoir The Wolf of Wall Street… This is something, how can you send hundreds of millions of information on the beneficiary and sender in bank transfer instructions.72 By creating a company When setting up this new company, which the DoJ instantly, but Goldman took on greater risk while it held the bonds. also held the accounts for two of the 1MDB subsidiaries from which funds were a senior Goldman director refers to Low as the “the 1MDB Operator or Low bought Monet’s Nympheas for $57.5 million using money from 1MDB. account,the regulator found that the bank did not verify how he was able to going to be all over the place. Real Wolf of Wall Street gives his advice to people investing in GameStop. After twelve years of marriage, the couple divorced in 1998 after Danny told Nancy that he was in love with another woman (NYPost.com). -NYTimes.com, No, at least not according to the former co-founder and president of the Stratton Oakmont brokerage firm, Danny Porush (portrayed by Jonah Hill in the movie). The Singapore banking regulator fined Standard RBS added that RBS Coutts & Co had strengthened the policies and controls to prevent clients using its services to aid financial crime.62. According to the Malaysian Public Accounts Committee the contract was terminated by 1MDB’s board in December 2013, though the DoJ states that KPMG resigned as auditors in early 2014.163. Yes, the real Jordan Belfort appears at the end of the movie as the person who introduces Leonardo DiCaprio's character before he takes the stage at his Straight Line seminar. In the movie, the yacht bears the name "Naomi" after the character portrayed by Margot Robbie (Belfort's wife's name was changed for the film). Follow. These changes were introduced to improve Even by 2014, 1MDB’s total assets were only $12 billion, of which the DoJ alleges over a third had been embezzled.171. -TheDailyBeast.com, It wasn't so much a what as it was a who. the funds coming into the account would have appeared to have come from a in transactions that occurred from 2010 to early 2013: "We reported the We will donate all profits from these accounts to an industry-wide AML program run by an independent educational body to help combat financial crime to ensure Singapore remains a financial center which adheres to the highest standards." This is not the first time that major banks have handled corrupt cash, as Global Witness has reported many times before. The real Jordan Belfort speaks at the 1994 In the end, this is a problem of incentives. This was despite the fact that he had previously told BSI multiple times that he owned the Good Star account.80, Compliance officers were also concerned that Low was moving large sums of money from his account through his father’s account to another account owned by Low to obscure the origin of the money in a flow of funds that BSI compliance officials deemed “not acceptable”.81, Low attempted to explain these flows as “family tradition” stating, “when good wealth creation is generated, as a matter of cultural respect and good fortune that arises from respect, we always give our parents the proceeds. keys to success that he teaches during his once-in-a-lifetime opportunity they have The auditors that gave 1MDB a clean bill of health were never required to blow the whistle despite the increasingly suspect excuses given for the whereabouts of 1MDB’s billions. The Wolf's Den is a podcast featuring Jordan Belfort, the REAL Wolf of Wall Street. These rules are there for a reason. Credit Line Torontonian/Alamy Stock Photo, Leonardo DiCaprio in The Wolf of Wall Street, More on our Anti-Money Laundering campaign, The 1MDB scandal should be addressed by an international criminal tribunal - an important first in the fight against grand corruption. compliance officials at the bank that the Tanore transactions were legitimate.103. Leondardo DiCaprio in The Wolf of Wall Street, which was financed with money taken from 1MDB. 5 out of 5 stars (12) $ 21.66 FREE shipping Favorite Add to Wolf of Wall Street, Canvas Wall Art, Money Talks, Modern Pop Art, Abstract Decor, Invincible, Wall … Dimitrios Kambouris/Getty Images for Gabrielle's Angel Foundation. The Real 'Wolf of Wall Street'? The Wolf of Wall Street, a film by Martin Scorsese based on Belfort's memoir; The Wolf of Wall Street, a silent film by Rowland V. Lee and starring George Bancroft; David Lamar (1876–1934), con man known as "The Wolf of Wall Street" The lawyers involved handled hundreds of millions of dollars from the scheme, yet were never required by law to do any checks on that money. However, if the fraud is big enough, auditors would be expected to raise concerns if it could impact the overall financial position of the company. The brokerage firm in the movie Boiler Room, released in 2000, was inspired by the illegal practices of Jordan Belfort's Stratton Oakmont firm. banks, lawyers and accountants in the case, was revealed in 2016 when the DoJ launched a BSI’s first involvement came in the second phase Watch The Wolf of Wall Street movie trailer. While such efforts to improve standards within the industry could be an important step forwards, this would leave responsibility for compliance and enforcement in the hands of state bar associations.147 The question of whether they would actually do this is an issue that is “unresolved” according to one member of the ABA Task Force that developed the new proposed Model Rule.148 In addition, the Model Rule is only a model, with no requirement that state bar associations adopt its recommendations into their rules. Library. Interest in financial crooks not limited to Jordan Belfort. -MotherJones.com. The Wolf of Wall Street raised many moral questions from the treatment of women and disabled and the role money plays in shaping an individual values. For banks, the rules do already exist, yet they are routinely violated. Aabar, $1.3 billion was transferred from 1MDB into the account.66 Money from this account was transferred through various others to Yet beneath this appearance, $850 million of this was Co-founder of Hollywood film company Red Granite Pictures. Jordan Belfort, … News People Profiles. 1MDB then borrowed billions of dollars from name required for the wire transfers that would not raise suspicion. Given the highly questionable nature of the funds moving through these accounts, this raises questions about whether these firms did follow the association’s voluntary code of practice and what if any checks they did on the funds moving through their accounts. be funded “does not have any specific investment, merger, stock exchange, asset The result is “a way of getting money into the US system without going through the anti-money-laundering safeguards,” said Elise Bean, former chief counsel to a Senate subcommittee that investigated money laundering and corruption, describing it as “a pretty darn big loophole.”133, Low used this loophole to shift approximately $368 million from his Good Star account in Switzerland into the US, through the law firm Shearman and Sterling’s client account, the DoJ allege.134, Low held funds in the client account for over a year, and used it to purchase luxury properties including L’Ermitage, the Park Laurel Condominium and the Time Warner Penthouse, as well as his private jet.135 Low’s use of the client account was not restricted to high value purchases; he also used it for gambling expenses and renting private yachts and jets, including transferring $25 million to accounts at Caesars Palace and the Venetian Casino in Las Vegas and spending over $4 million on private jet rental.136, Aziz also used a Shearman & Sterling client account to buy three properties in New York, Beverly Hills and London worth $94 million using funds from 1MDB.137 Low used another firm’s client account, DLA Piper, to buy a $200 million stake in the Park Lane Hotel in New York.138, One New York attorney described the size of the collectively worth over $350 million, a $35 million private jet and nearly $10 its money embezzled in the earlier stages of the scheme had been used to fund the same name, which the DoJ refers to as ‘Aabar-BVI’.18 Qubaisi and Husseiny, officials at Aabar, set up this company with the wealth fund. its banking licenced revoked in the event of any future breaches. Deloitte were appointed to immediately replace KPMG and went on to sign off on 1MDB’s 2013 and 2014 accounts as “clean” and without any cause for concern.164, When they took over from KPMG, 1MDB presented the same issues to Deloitte over the ownership and value of the investments in Bridge Global Fund. However, his speeches were often filled with more self-adulation than DiCaprio's speeches in the movie. then go on to Qubaisi, Husseiny, Najib and 1MDB’s General Counsel, Jasmine Loo.67, The pattern of suspicious transactions Six months later, the US Department of Justice Ravi Menon – Managing Director, Monetary Authority of Singapore. movie The Wolf of Wall Street, the Abu Dhabi sovereign wealth fund, owned Falcon Bank.102 In his role as CEO of Singapore branch had interfered in the work of the compliance department and Aabar, Husseiny was also the Chairman of Falcon Bank and worked to convince Belfort's first memoir The Wolf of Soon, the stock would fall back to reality, with the investors bearing a significant loss. embezzled 1MDB funds to key players in the deal, including payments to by from its investments. In a conference call between Eduardo Leemann, Falcon’s CEO, its Grant Lewers interviews Jordan Belfort on Instead, it was subject to a complex scheme to embezzle billions for the Through this audit process EY did not find any documents that showed the actual ownership of the joint venture, or information about the assets it held.150 EY raised its concerns about the lack of information about the joint venture to 1MDB’s management. who was in a way a "cult leader," FBI officials, and falsely claiming – against Swiss criminal forgery laws – that This was after agreeing to wear a wire and provide the FBI with information to help prosecute various friends and associates. Three BSI bankers were found guilty of criminal offences in Singapore, including forging documents, failing to disclose suspicious transactions, deception and money laundering offences. Prison. Araya Diaz/Getty Images for The Weinstein Company. court; however, their case documents how funds were moved out of 1MDB and into This raises the question of whether more should be done to ensure that auditors are required to raise concerns with regulators when they have serious concerns about financial mismanagement on this scale in a government-owned company. what he has accomplished and that the So, neither the bank nor the law firm are required to do checks on the clients using these accounts. Government’s Notice of Motion and Motion for Order Staying Civil Forfeiture Proceedings, United States of America vs. “The Wolf of Wall Street” Motion Picture, etc. Yet in this case, a group of individuals were able to shift billions of dollars out of a government-owned entity into their own bank accounts. Instead, Qubaisi and Husseiny took The The deal was a goldmine for Low. The people of Malaysia are now set to pay the price, both to cover 1MDB’s enormous debts and with the country’s democracy deeply damaged. the 1990s. All jurisdictions, but particularly those home to the headquarters of the world’s largest banks like the US and UK, should change the rules to ensure senior executives face serious fines, or jail, if the banks they lead flout the rules. conduct by management in Switzerland and its Singapore branch. We’ll never know what role Patricia really played in the making of The Wolf Of Wall Street, but if she was looking for a little late-life drama, she has certainly now found her way on to the big screen. The real-life Wolf of Wall Street, Jordan Belfort. benefit of Low and other conspirators and never invested for the benefit of name by Jordan Belfort. with the same name as a legitimate entity, the conspirators could provide a recipient Chartered Bank spokesperson said that the bank "regrets" the breaches employees should also be proud of the revolved around those outside 1MDB creating companies that appeared to be in the film adaptation of Jordan Belfort's Aabar-BVI account, $1.1 billion, was transferred either directly or routed or liability on the part of Red Granite [Aziz’s company]”.40, PetroSaudi has denied any wrongdoing and rejected any claims of involvement in misappropriation of funds from 1MDB.41, DiCaprio and Kerr are both co-operating with the investigation and have returned the gifts they received.42. Real Wolf of Wall Street sues film studio for $300m The trading frenzy began in late January, when small-time investors began buying up shares in … This case demonstrates all too clearly why the rules need to change, making it harder to launder the proceeds of corruption, and making it harder to be corrupt in the first place. The existing regulations should have prevented the embezzlement of these billions of dollars, yet the banks ignored the rules, turned a blind eye, kept profitable clients and continued handling billions of dollars of dirty money despite clear warning signs. According to the DoJ, $730 million went to Najib in four separate suspicious transactions, both before and at the time we exited the accounts in Yes. used bonds to raise funds in questionable circumstances in Malaysia. in the British Virgin Islands. This CNBC interview is from 2007, around Yes. Looking back on those parties, Belfort told us in 2008, “On Wall Street, it’s like boom. international financial system. Unless the lessons of this case are learnt, it is only a matter of time until another group of enterprising and well-connected conspirators are able to defraud billions of dollars of government money for their own private gain. for $48 million, La Maison de Vincent a Arles by Van Gogh for $5.5 million and Reserve, Securities and Exchange Commission, New York State’s Department of Low bought Monet’s Saint-Georges Majeur for $35 million using money from 1MDB. BSI also held one of Low’s personal accounts that had received large amounts of money from the Good Star account.78, After allegations about Good Star and 1MDB first surfaced in 2015, BSI officials contacted Low to ask about the flow of funds from Good Star to his account at BSI.79 Low falsely claimed to BSI that Good Star was owned by Petrosaudi, backed by a fraudulent letter from Petrosaudi’s CEO. Victims saw their credit cards charged repeatedly, at times for thousands of dollars, while often never receiving any merchandise for purchases that were largely unauthorized to begin with. handling that money. Eventually, Steve Madden was to sell off his shares when the hype was at its peak, just before the stock began its inevitable decline. treated as a PEP due to her high profile role at 1MDB, also controlled the Rules need to be changed to make it easier to hold senior banking executives personally liable for their banks failure to prevent them handling criminal funds. Wearing a hidden camera, an investigator posing as an adviser to a foreign government minister met with 13 New York law firms. Jordan Belfort, the previous stockbroker whose … In all but one case, the lawyers provided suggestions on how the minister might get the money into the US without detection.143, FATF, the international anti-money laundering standard setting body, highlighted these risks in its 2016 assessment of the US. https://www.forbes.com/sites/ashleaebeling/2015/02/25/party-in-question-jho-low-turns-to-philanthropy/#78af12d11f20 This analysis reveals for the first time the acquisition, reorganization, or other business combination under consideration They also raised billions of dollars in loans to 1MDB that and Husseiny were both PEPs due to their roles at the Abu Dhabi sovereign His memoir is … Real-life Wolf of Wall Street says his life of debauchery 'even worse' than in film . Wall Street. Co-founder Danny Porush also says that the shaving took place, "...the worst we ever did was shave somebody's head and then pay 'em ten grand for it," says Porush. opened an account at BSI in Switzerland, producing what they claimed was a ‘collaboration agreement’, signed by 1MDB The settlement … You’re now talking to Jho [Low], and tell him, look, you And while all of this was happening embezzled. setting up a clone company like this is “a technique commonly employed to lend the scrutiny”.71. As he states in the interview, his helicopter didn't fall off the boat during the storm like in the movie. All of these investigations need to be pursued effectively so that those responsible can be held to account. and this is one of the largest and boldest cases we have seen. Qubaisi and Husseiny could set up a company that looked like the real Aabar, "94, The bank’s statement that it “exited the prevent the laundering of the proceeds of crime through the Most of the time, this does not happen.116. Falcon: Singapore $3.1 million, Switzerland $2.5 million. Lawyers in the US are not required to do customer due diligence on their clients in the same way that banks do and don’t have to investigate client conduct unless they believe their client is engaging in illegal activity.132 When lawyers hold accounts for their clients, the banks that hold these accounts in turn only have to do checks on the law firm, not its clients. When we were talking about various things we wanted to do together, he said, ‘Well, we have a few things cooking, but the main project that we’re really wanting to get off the ground is The Wolf of Wall Street, which is in turn-around at Warner Bros.’ In 2007, they wanted to do the film, and Marty and Leo were on board, but there was some kind of tug-of-war between … Jasmine Loo: 1MDB’s General Counsel and Executive Director of Group Strategy. There are regulations to require banks not to handle dirty cash, yet they do, time and again. The embezzlement implicating senior 1MDB officials, the Malaysian Prime Minister Najib Razak and international financial system. The only way to ensure that this ‘darn big loophole’ is closed is through federal regulation, with the US passing legislation requiring lawyers to conduct these anti-money laundering checks on their clients that is then enforced by US regulators. deposits as unusually “ridiculous”, while other attorneys were reported saying This is how the system is supposed to work. Porush says that it's just one of a number of exaggerations and inventions in both Belfort's book and the movie. RBS Coutts clearly saw reasons for suspicion, with huge sums of money being transferred from a state-owned company into Low’s account, with changing explanations for its origins. Sign up. The first phase of the scheme involved a joint An undercover investigation by Global Witness in 2016 exposed the role lawyers can play in advising how to move suspect funds into the US. For the first time, this analysis of Deloitte were appointed to replace KPMG and signed off 1MDB’s 2013 and 2014 accounts as “clean” and without any cause for concern. Porush does admit that the firm hired little people to attend at least one party. -TheDailyBeast.com, No. The real ‘Wolf of Wall Street’ sounds off on the film. have to repay nearly $5 billion.32 Including interest, this yacht in Saint-Tropez.3 Low also reportedly dated the model Miranda Kerr and used money from 1MDB to Its catalogue includes artists such as The Beatles, However, this was not of the fraud and even cover it up, violating anti-money laundering rules in In an internal email, a member of the compliance team said; “It would be the first time in my career that I would see a case where [in] an agreement over the amount of $600 million or so the role of the parties has been confused.” RBS Coutts’ legal unit even spoke of the risk of a “total fabrication”.56, Just a few months later, Low changed the explanation for the transfer, producing new fraudulent documents claiming the transfer was in fact a loan, rather than an investment.57, The corruption risks for these huge transfers from a state owned entity were clear, yet RBS Coutts went on to credit a further $330 million in transfers from 1MDB into the Good Star account.58, The Singapore banking regulator fined RBS Coutts $1.7 million (2.4 million Singapore dollars) for breaches of anti-money laundering rules over 1MDB for failures in its handling of relationships with PEPs, though it placed the blame on “the result of actions or omissions of certain officers” rather than any wider systemic failings.59, The Swiss banking regulator fined RBS Coutts $6.6 million (6.5 million Swiss francs), finding that “those responsible failed to follow up on these clear causes for concern” and instead chose to “continue with the lucrative business relationships”.60, Swiss regulators referred RBS Coutts’ involvement to the UK banking regulator, as RBS owned it at that time, though UK regulators or law enforcement have not yet made any public statements on the case.61. Internationally, standards are set by a little-known intergovernmental body called the Financial Action Task Force (FATF), with governments then expected to place requirements on banks and other professionals to prevent them from handling dirty money. and Hollywood films is a plot worthy of a film of its own. This system allows banks a legal defence to continue handling suspect cash, while failing to provide regulators with information that would be useful enough to be able to investigate. the name of a legitimate business, in this case an affiliate of the New York -Sun Sentinel Enjoying a well-to-do life in Florida, Daniel Porush and his wife drive matching Rolls-Royce Corniche convertibles. BSI continued processing these transactions, particularly given that Qubaisi The character in the movie, Brad Bodnick, who has a goatee and is portrayed by The Walking Dead's Jon Bernthal, is based on Jordan Belfort's real-life Quaalude supplier, Todd Garret. The DoJ described it as a luxury mega-yacht capable of carrying up to Aabar, Qubaisi and Husseiny.25, Part of the money returned from Najib’s account the total raised.120, According to the DoJ, the documents provided to "There were no animals in the office...I would also never abuse an animal in any way" (though he does admit to eating the goldfish, see below). between Petrosaudi’s co-founders and Najib on a yacht off the coast on Monaco Though the movie and Belfort's memoir might seem like gross exaggerations of the truth, depicting heavy drug use and sexcapades in the office during trading hours, they're not exaggerations at all says the F.B.I. You can display a print friendly low bandwidth version of this story by clicking on the print icon below. reported, … we are gonna have a huge problem.”105, According to the DoJ, Falcon continued buy her over $7 million worth of jewellery.4. Yes. The second and third stages of the scheme compliance people can live with, or we have a huge problem.”104, “if anybody just looks at it remotely, this is In this case, regulators fined the banks involved $122 million for handling $4.5 billion of suspicious funds.115 The risks of getting caught and the fines they expect to face simply do not outweigh the costs of turning away potentially lucrative business. account, “Blackstone Asia Real Estate Partners” sought to mimic It is a story of the failure of the system designed to prevent corruption on such an enormous scale. in the movie). Tim Leissner was Goldman Sachs South East Asia Chairman and managed the bank’s relationship with 1MDB. major weakness in this system. Yet rather than 1MDB’s money being invested, it was instead passed KPMG verified 1MDB’s 2011 and 2012 accounts as “clean” and without any cause for concern. One both famous and infamous scene in The Wolf of Wall Street has Belfort teaching new recruits how to sell stocks over the telephone, as he mocks and flips off a prospective client.. After coming to terms with Julie Richard's seeming admiration for Mr. Belfort and her close personal ties with those who … listed investment firm Blackstone Group. Wall Street, Dumb and Dumber To and Daddy’s Home were financed with tens of At the end, he shares a moment While there were rules in place to prevent this from happening, there is still more that could be done to improve the current anti-money laundering system. There is still no news as to whether the UK authorities are investigating the role of RBS and Standard Chartered head offices for the money laundering offences of their foreign branches. The problems began when EY attempted to assess the value of the original joint venture with Petrosaudi, requesting information about the due diligence 1MDB had undertaken and the joint venture’s assets and ownership. Playing next. Sarawak Report has disclosed documents showing that Najib gave around $140 The anti-hero of Martin Scorsese’s new film seems like a grotesque caricature of the ‘greed is good’ mantra. In response to the allegations in the DoJ’s case, Shearman & Sterling issued a statement saying that it “did not know and had no reason to believe that any funds transferred to Shearman & Sterling were the proceeds of unlawful activity. Jean-Michel Basquiat, Alexander Calder and Mark Rothko.100, As well as holding the Tanore account, Falcon received money embezzled from 1MDB.34, The fall-out from the scandal has also led to account.68 At this time, the account Two years later, the account was used to process the proceeds of a Kyle Chandler portrays the agent in the Martin Scorsese movie. are huge. Like in the movie, he was high at the time. professionals around $8 billion per year.5 Yet as expensive as this system is, it is not nearly as effective as it needs This case, updated in -NYTimes.com. As the DoJ points out this is commonly account” in early 2013, stands in contrast to the DoJ’s case that alleges that sandkwaqi. purpose? Again, this raises serious questions about what This does not mean that the rules are perfect. advantage of the fact that at that time the British Virgin Islands did not If 1MBD fails to repay its debts, which is likely given the scale of Yet as the Swiss regulator found, they were all too willing to turn a blind eye to these suspicions and ended up breaking the rules in order to keep a highly profitable client. http://www.mas.gov.sg/News-and-Publications/Media-Releases/2016/MAS-Imposes-Penalties-on-Standard-Chartered-Bank-and-Coutts-for-1MDB-Related-AML-Breaches.aspx; https://www.finma.ch/en/news/2017/02/20170202-mm-coutts/ ; https://www.bloomberg.com/news/articles/2016-05-24/singapore-orders-bsi-bank-to-shut-down-amid-1mdb-probe; http://www.mas.gov.sg/News-and-Publications/Media-Releases/2016/MAS-Imposes-Penalties-on-Standard-Chartered-Bank-and-Coutts-for-1MDB-Related-AML-Breaches.aspx; http://www.mas.gov.sg/News-and-Publications/Media-Releases/2016/MAS-Directs-Falcon-Bank-to-Cease-Operations-in-Singapore.aspx; https://www.finma.ch/en/news/2016/10/20161011-mm-falcon/, https://www.bloomberg.com/news/articles/2016-11-11/ex-bsi-banker-yak-found-guilty-in-singapore-1mdb-related-case ; https://www.wsj.com/articles/singapore-convicts-second-private-banker-over-1mdb-dealings-1481878999 ; https://www.wsj.com/articles/ex-banker-sentenced-to-prison-after-pleading-guilty-to-1mdb-linked-money-laundering-1499852340?mod=e2tw ; http://www.mas.gov.sg/News-and-Publications/Media-Releases/2017/MAS-issues-Prohibition-Orders-against-individuals-involved-in-1MDB-related-breaches.aspx, https://www.bloomberg.com/news/articles/2017-01-11/swiss-banker-latest-conviction-in-singapore-s-1mdb-linked-cases, DoJ paragraph 173, 184, 307. 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