Q for Spotify re Money-Laundering12 Jan 2021 18:27
Hi Spotify,
On 6th Jan you shared that .." In my working life (now retired) I was a Money Laundering Investigations Officer / Police liaison, and came across some truly despicable characters. I've no time for the 'crooked' element and have happily called them out thus far, and will continue to do so, if necessary..."
In light of this, would you kindly share your professional opinion as to what liability SYME management (or , indeed , any management) might have if it inadvertently picked up some of these rogues ? What steps is a company's management expected to take ?
Earlier today I posted :
..."I've posted months ago about this 'early-stage' flipper /investor in the RTO : https://www.focusrisparmio.com/news/supply-me-fintech-gamma-capital-markets-investitori
from Gamma Capital Markets, Malta.
[ Side observation : I've discovered that Malta seems to have a lot of boutique financial services firms run by Italians. Not prejudice, just an observation. I guess location plays a part. Parrot Capital (Global Capital plc) Malta, Chair Paolo Catalfamo, , for instance, is listed as a 4.98% shareholder in the Prospectus. ]
Looking more closely at this entity https://www.gammacm.com.mt/about.php says it's run by Eros Lombardo /Enzo Fillipini (although the photos change), both of whom appear here, along with Alexander Vella https://offshoreleaks.icij.org/nodes/55045674
The thing is , Gamma Capital Markets , Enzo Fillipini and Alexander Vella are also all named here : https://www.catholicworldreport.com/2019/12/21/the-vatican-centurion-global-financial-scandal-a-cna-explainer/
an article about .."a Vatican financial scandal involving a multi-million-dollar investment fund, Centurion Global.."
which shares an office in Malta, as well as a single phone number and email address, with Gamma Capital – Centurion’s formal investment manager.
From this article and the ICIJ searchable database , there are a lot of other rabbit-holes one could go down, eg drilling down on the individual names and their connections. It's a whole parallel universe out there.
Coming back to the RTO and SYME, I've no idea what due diligence , if any , a company is expected or required to perform on the background of prospective investors - I can imagine that in today's KYC culture , that might be quite tiresome - and whether it can subcontract that to third parties.
But there's at least the possibility that, in the Vendor Placing, Gamma Capital may not have been the only 'wrong 'un' to slip through the net.
Maybe Spotify [ AIUI , works in anti-fraud and /or money-laundering ] can comment ? "
It's a little more urgent now , because I've since been sent this https://twitter.com/SupplyMECapital/status/1313011750032363521?s=20
where it turns out that AZ has - unfortunately - re-tweeted the Gamma Capital article.
TIA